Date: June 28th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of the University of Southern California, for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, University of Southern California ("USC") hereby applies for an exemption from the Federal

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting controlled flights for aerial 

research to create 3D city and landscape models, aerial photogrammetry, and precision aerial surveys.

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as but not limited to these accompanying USC documents; 

1. USC’s Operations Manual and;

2. USC’s Operations Manual

3. USC’s PIC Operating Manual 

(collectively referred to as " USC' Operations Manuals")

4. DJI Phantom II and S900 User Guide and;

5. DJI Phantom II and S900 User Manual

(collectively referred to as "Manufacturer's Manuals").

1

The USC submits these as well as other USC supporting materials as confidential documents 

pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary

information that the USC has not and will not share with others. Additionally, these documents contain 

operating conditions and procedures that are not generally available to the public and are protected from 

release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins.
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Page 2

This Petition is organized as follows:

I. Petitioner

II.Description of Proposed Operations

A. Aerial research to create 3D city and landscape models

B. Aerial photogrammetry, and precision property aerial surveys.

II.Relevant Statutory Authority

IV. USC’ Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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I. DESCRIPTION OF PETITIONER

Based in Los Angeles, California, USC is a well-known university graduating thousands of students 

annually in many different areas of science, technology, engineering, mathematics and the arts. The 

university has a University Affiliated Research Center (a UARC) called The Institute for Creative 

Technologies located in playa vista which is dedicated to providing immersive learning experiences utilizing 

artificial intelligence, simulations, virtual humans and technologically innovative solutions for education, 

industry and government. The ICT is working on research related to photogrammetry and precision 

aerial surveying. On behalf of USC, and its’ Assoc Director for Digital Training & Instruction, Ryan 

Mcalinden, along with a small staff, are creating a unique method of acquiring imagery for the initial and 

principle use of creating 3D models of the terrain, city, and landscape models. As part of USC’ vision 

of providing new and innovative solutions building upon its extensive history of education and 

innovation, USC seeks an exemption to allow for the commercial operations of small, UAS less than 55lbs

to research aerial photogrammetry and precision aerial surveying.

The contact information for Petitioner is as follows:

Ryan Mcalinden

Assoc Director for Digital Training & Instruction

University of Southern California

Institute for Creative Technologies

12015 Waterfront Drive

Playa Vista, CA 90094

310 448-5387

mcalinden@ict.usc.edu

II.DESCRIPTION OF PROPOSED OPERATION

USC seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Phantom II 

and a DJI S900 UAS for the proposed operations discussed below. All UAS operations will occur under 

tightly controlled conditions at locations where USC has received permission to operate from the

landowner, controller or authorized representatives. The proposed UAS operations will be conducted in 

accordance with the conditions and limitations of this Petition for Exemption and USC’ Operations 

Manuals. As detailed in USC' Operations Manuals, all UAS operations will be limited to daytime VFR 

conditions, within visual line-of-sight ("VLOS") of the operator and or (“VO”) visual observers, in 

uncontrolled airspace, and will occur at least 5 miles away from an airport. Moreover, USC’ Operations 

Manuals incorporate redundant safeguards to assure that the aircraft does not travel outside the controlled 

area of UAS operations, including GPS "geo-fencing" technologies.

A. Aerial Photogrammetry and Precision Property Aerial Surveying

USC seeks to use small UASs for the purpose of conducting aerial photogrammetry and precision 

property aerial surveying. 
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USC has tailored its operations to meet the requirements established by the FAA in prior grants of

exemptions authorizing commercial use of UAS in aerial photogrammetry and precision aerial property

surveying including:

 Michael Baker International, LLC (Exemption No. 11711)

 M2 Flight Solutions, LLC (Exemption No. 11519)

 BizUAS Corp, (Exemption No. 11351)

All UAS aerial photogrammetry and precision property aerial surveying operations will be conducted

on USC and other approved property in a controlled area, away from spectators and persons not involved. 

All UAS aerial photogrammetry and precision property aerial surveying will be conducted during daylight

hours, VFR conditions, at altitudes below 400' AGL. As set forth below, USC’ operations provide a

superior level of safety and quality compared to performing the same aerial photogrammetry work using 

conventional fixed-wing aircraft or helicopters.

USC seeks to use small UASs for the purpose of conducting aerial photogrammetry and precision 

property aerial surveying. Traditional methods of aerial photogrammetry and precision property aerial 

surveying are extremely costly and present uncalled for risk, physical harm, serious injury and death to 

manned aircraft participants and pedestrians on the ground. Further, the use of traditional aircraft exposes 

participants and pedestrians the risk of dangerous low level aircraft engine failure making recovery or 

emergency landings as one of the extremes. The use of small UASs mitigates these hazards and is 

ultimately a much safer method of performing these and most other types of aerial photogrammetry and

precision property aerial surveying.

Small UAS aerial photogrammetry and precision property aerial surveying is also safer than 

traditional manned aircraft performing the same function. Conventional operations using rotorcraft and 

fixed-wing aircraft in low level operations present risks associated with vehicles weighing thousands of 

pounds and carrying large amounts of fuel. It is important to note that the use of small UAS in this area

will not only be safer and more cost effective, but the quality of collected data and information is far 

superior. 

Small UAS aerial photogrammetry and precision property aerial surveying is more reliable, and 

allows for the collection, dissemination, and storage of visual and other sensory data with greater precision 

and duration. Small UASs are also capable of accessing and inspecting areas that would otherwise be

inaccessible to humans or cannot be completed with conventional aircraft.
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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in 

the National Air Space ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from §§ 44701(a), (b) and;

§§ 44702 – 44716, et seq.). A party requesting an exemption must explain the reasons why the exemption:

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would provide

a level of safety at least equal to the existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. USC' PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333

OF THE REFORM ACT

The small UAS operations proposed by USC in this Petition for Exemption qualify for expedited

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are

satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the DJI Phantom II & S900 UASs due to

its size weight, speed, and operational capability.

 The DJI PHANTOM II & S900 has been approved for use in prior Section 333 Grants of 

Exemption from the FAA.

2

2

See e.g., Grant of Exemption to Michael Baker International, LLC (Exemption No. 11711),

M2 Flight Solutions, LLC (Exemption No. 11519), BizUAS Corp, (Exemption No. 11351).
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 The DJI PHANTOM II & S900 weighs less than 55 pounds, including payload.

 The DJI PHANTOM II & S900 will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety

and predictability of the system. If connection to the remote control or ground control station is 

lost, failsafe systems will permit the UAS to return to a predetermined location and safely land

without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the DJI PHANTOM II & S900 is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference

in weight between the DJI PHANTOM II & S900 and a helicopter significantly reduces the potential harm 

to the participating and non- participating individuals or property in the event of an accident or incident. In

addition, the risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in USC’ Operations

Manuals

USC’ Operations Manuals and the Manufacturer's Manual for the selected UASs will contain all the 

procedures and limitations necessary to safely and successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of USC’ proposed operations, 

below is a summary of operational limitations and conditions that USC will adhere to, and which will

ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission from the

land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight operation.
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3. All UASs operated under the Grant of Exemption will 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 will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission.

5. PICs shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The

PIC will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which

the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the USC’ 

Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and 

USC’ Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence

and must be followed. Otherwise, USC shall follow the procedures outlined in their Operations Manuals.

10. USC may update or revise its Operations Manuals. Revisions will be tracked and a revised copy of

the Manual will be provided to the Administrator upon request.

USC will also present an updated and revised Operations Manuals if it petitions for extension or amendment to

its Grant of Exemption. If an update or revision would affect the basis upon which the FAA grants the

exemption, USC will seek an amendment to its Grant of Exemption. USC will contact the FAA’s UAS

Integration Office (AFS-80) if questions arise regarding updates or revisions to the operating documents.

11. USC’ Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

12. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising

speed, to fly after that for at least 10 minutes.
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13. Maximum total flight time for each operational flight using the DJI PHANTOM II & S900 will be

limited to 40 minutes or the amount of time the UAS can be flown and still maintain a reserve battery power 

of no less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the structure

being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest 

point on the structure, and no more than 50 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, 

vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue

hazard to those persons per § 91.119(a).

16. 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.

17. The UA may not operate within 5 nm of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the USC COA. The letter of agreement

with the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. 

The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, 

not already covered in the relevant sections of the operating documents. The PIC shall not operate the UAS

if the inspection reveals a condition that affects the safe operation of the UAS until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. The ground 

control station shall be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS records as required by USC’ Operations Manuals.
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19. USC will carry out its maintenance, inspections, and record keeping requirements in accordance

with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the UAS records, 

including total time in service, description of work accomplished, and the signature of the authorized person 

returning the UAS to service.

20. 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 in

accordance with USC Operations Manuals. The PIC who conductsthe functional test flight must make an

entry in the UAS aircraft records of the flight. The requirements and proceduresfor a functional test flight and

UAS record entry shall be included in the USC’ Operations Manuals.

21. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

USC’ Operations Manuals.

23. USC will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or

emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner

consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a UAS 

rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.
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30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a manner

consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 logged hours as UAS

pilot operating the make and model of UAS to be utilized for operations under the exemption and thirty takeoffs and thirty landing in the preceding 90 days.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

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

gliders, etc.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAs will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, the radio frequency spectrum used for operation and control of the

UA will comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3

USC seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a

UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety better 

than or equal to the rules from which exemption is sought.

4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to that provided by the rule from which you seek

exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally

used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, however, 

the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements 

of the Reform Act, an exemption is requested.

Equivalent Level of Safety

USC’ use of the DJI PHANTOM II & S900 is safe when taking into account their size, weight, speed,

and operational capability. As set forth in the description of proposed operations in Section IV (A), 

the DJI PHANTOM II & S900 weighs less than 55 pounds, including payload and will not be flown at 

a ground speed in excess of 50 knots. UAS is also equipped with safety features that will allow 

Petitioner to operate the UAS safely after experience certain in-flight contingencies or failures.

6 7

Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within the parameters stated in USC's Operations Manuals.

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [DJI S1000] has the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. The

UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link event with a 

pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as

a backup. These safety features provide an equivalent level of safety compared to a manned aircraft 

performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The DJI PHANTOM II & S900 with upgrades can be operated entirely by a touch-screen, mapbased interface. This means the operator only needs to command the system where to go, and the

system does all the flying for the operator. The DJI PHANTOM II & S900 can be operated in both 

semi and fully autonomousflight modes. In addition, the DJI PHANTOM II & S900 with upgrades 

comes with pre-programmed no fly zones the UAS cannot enter areas deemed unsafe or

unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling

which allowsthe DJI PHANTOM II & S900 to detect a system fault while in the air and automatically 

fly back to its takeoff location and land. Faults that can be detected include: loss of communication;

exceeding pre-set wind thresholds; and low battery levels.
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Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. USC will also provide the FAA with advance notice of all operations via NOTAMs as required by

the applicable COA. In all cases, operation of the DJI PHANTOM II & S900 under the proposed conditions 

will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that USC's small UASs would otherwise require

certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness standards for 

the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

{continued from previous page}

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. The flight control system employs not only GPS positioning but

a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly

away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

USC seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, 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 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.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UA flown by USC will bear N-number markings that are as large as practicable in accordance

with 14 C.F.R. Part 45, Subpart C.

11

10

FAA Docket No. FAA-2014-0352.

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

USC seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by USC’ Operations Manuals, the PIC will conduct a pre-flight inspection of the UAS 

and all associated equipment to account for all discrepancies and/or inoperable components. Maintenance

will be performed and verified to address any conditions potentially affecting safe operation of the UAS and

no flights will occur unless, and until, all flight critical components of the UAS have been found to be 

airworthy and in a condition safe for operation. A functional test flight will be conducted following the

replacement of any flight-critical components. As required by USC’ Operations Manuals, the PIC who 

conducts the functional test flight will make an entry in the UAS aircraft records of the flight.

USC’ Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, USC’ Operations Manuals also includes 

procedures to document and maintain a record of the UAS maintenance, preventative maintenance,

alterations, status of replacement /overhaul component parts, and the total time in service of the UASs used 

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in USC’

Operations Manuals ensure that an equivalent or higher level of safety will be achieved.
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June 28th, 2015

Page 15

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

USC seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from 

flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for

hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions USC has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial. USC will operate on private property away from persons and property not

involved in the operation. USC will also obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 

NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, USC will further ensure safe operation by requiring that any

PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators 

but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will have

experience not only in UAS operations generally but have logged flight time in the specific make and model 

used for the operations before they are permitted to participate in commercial flights on behalf of USC. The

pilot qualification, training, and currency requirements in the Operations Manuals ensure that USC’ pilots are 

competent and proficient in the UAS they are operating. USC’ training and qualification requirements are 

consistent with those contained in prior FAA Section 333 Grants of Exemption, and will provide a higher

level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety.

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
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June 28th, 2015

Page 16

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the UASs, USC seeks an exemption 

from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The

FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of 

Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the requirements for § 

91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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...

(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.

13

See id. at 13-14, 22 
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June 28th, 2015

Page 17

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has 

no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be

achieved by ensuring that the pilot has access to the documents at the ground control station from which he

or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

USC seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the USC’ Operations Manuals and the 

Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the USC’ Operations Manuals, including checklists covering

Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather,

flight requirements, battery charge, landing and takeoff distance, UA performance data, and contingency

landing areas—before initiation of flight. USC’ Operations Manuals and the Manufacturer's Manual will

be kept at the ground control station and will be accessible to the PIC at all times while operating the UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
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June 28th, 2015

Page 18

USC seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 

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." UASs and remotely piloted aircraft, by their design, 

do not have functional dual controls. Instead, flight control is accomplished through the use of a device

that communicates with the aircraft via radio communications. Accordingly, an exemption will be required

for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that USC intends to use, an equivalent level of safe training can 

still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required 

by the USC’ Operations Manuals, all persons will be a safe distance away in the event that the UAS

experiences any difficulties during flight instruction. Moreover, as required by the USC’ Operations

Manuals, all flight training will be conducted in controlled and sterile environment. As a whole, the safety

procedures provided for in USC’ Operations Manuals ensure that the proposed UAS operations provide an 

equivalent or higher level of safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

USC requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c).

15 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 

feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 

C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes 

when it can be operated "without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the

FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and within 

50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or

Observers(s) may need to be less than 500 feet away from the UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b)

will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial 

(FAA-2014-0534 at 15)
U.S. Department of Transportation

June 28th, 2015

Page 19

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the UASs, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved

given the size, weight, and speed of the UASs, as well the controlled location where the operations will 

occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or 

below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest 

point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person 

is in a position where he or she is shielded from the UAS and any possible debris resulting from UAS failure. 

As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet 

of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from 

vehicles or structures unless the property owner/controller has granted permission and the PIC has made a

safety assessment of the risk of operating closer to those objects and, operations near the PIC or Observer 

will not present an undue hazard per § 91.119(a). Adherence to these restrictions in the elevation of the 

departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out. USC’ Operations Manuals will ensure operations can 

be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

USC seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out.

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the

UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons

afforded such protection. The operator must also 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. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons. In

addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles

and structures when the owner/controller of any such vessels, vehicles orstructures grants permission

for the operation and the PIC makes a safety assessment of the risk of operating closer to those 

objects and determines that it does not present an undue hazard.”
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June 28th, 2015

Page 20

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that USC intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by USC’ Operations Manuals, the PIC will be required to calibrate

the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the UASs USC intends to use, and the safety mitigation procedures contained in the Operations 

Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of Exemption to the 

requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

USC requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states: 

(a) 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.

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required.

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more

than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
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June 28th, 2015

Page 21

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a DJI Phantom II & S900 flight unless (considering wind and forecast 

weather conditions) there was enough power to fly to the first intended point of landing and, assuming 

normal cruising speed, to fly after that for at least 10 minutes. 

In reaching this conclusion, the FAA considered that the UAS batteries for the DJI Phantom II & 

S900 provided provide approximately 20 minutes of powered flight (with payload) and provided battery 

level and battery time remaining in minutes and seconds to the PIC.19 The FAA also considered the fact 

that the DJI Phantom II & S900 operating manual states: “start every flight with a fully charged battery in 

the aerial vehicle”, and that in the event that the UAS should run low on power, the PIC will be alerted and 

can land the DJI Phantom II & S900 as soon as possible. Like the VDOS Grant of Exemption, USC use of 

the DJI Phantom II & S900, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the DJI PHANTOM II & S900 unless (considering wind 

and forecast weather conditions), there was enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. USC will adhere to this limitation for 

DJI PHANTOM II & S900 flights. 

The DJI PHANTOM II & S900 includes a low battery warning system and the amount of battery 

reserve power remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS 

to a ground-based-on-screen display.20 As required by USC’ Operations Manuals, the PIC will promptly fly 

the UAS back to the home launch location or pre-determined abort location where the UAS may safely 

land, while still maintaining a minimum of 25% reserve battery power. USC submits that the procedures 

requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighting less than 

25 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide 

an equivalent or higher level of safety to that provided by the regulations from which exemption is sought. 

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The DJI Phantom II & S900 ground control station displays, the UASs position, navigation route, tail 

number, altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and 

sensor heading and orientation relative to the UAS. 
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June 28th, 2015

Page 22

VI. DRUG AND ALCOHOL PROGRAM

USC will have policies in place to ensure that no person may participate in UAS flight operations if 

they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting USC’ Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe working

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk harm or serious injury to inspecting engineers. Traditional methods of inspecting monitoring 

industrial and construction sites, and utility power-generation facilities and infrastructure requires 

inspectors to climb towers or otherwise perform elevated work, which exposes them to the risk of 

dangerous falls. Inspectors are often exposed to hazardous chemicals or oxygen-deficient atmospheres, 

burns from steam or from hot equipment, and other mechanical hazards associated with industrial sites and 

construction facilities. The use of small UASs can eliminate these hazards and is ultimately a much safer 

method of performing these types of inspections. 

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no passengers 

or crew. Further, in the unlikely event of an accident, USC small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit from a reduction in 

harmful emissions associated with conventional aircraft performing in the same functions proposed herein. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UASs provide 

an additional tool for the aerial filming industry, adding a greater degree of flexibility, which supplements 

the current capabilities offered by manned aircraft.22

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh 

less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard pilot 

and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation." 
U.S. Department of Transportation

June 28th, 2015

Page 23

VIII. PRIVACY 

All USC UAS operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & 

(b).

The exemption will enhance safety by reducing risk to the general public and property owners from 

the substantial hazards associated with performing equivalent film work and aerial inspection and 

environmental monitoring of industrial sites, transmission and storage facilities, construction facilities and 

precision aerial surveys with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

USC Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 

2012 including weight, speed, operating capabilities, proximity to airports and populated areas, operation 

within VLOS and national security. The proposed UAS operations will benefit the public as a whole by 

improving safety and reducing risk by alleviating human exposure to danger. In consideration of the 

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing USC to use small UASs for controlled flights for aerial research to 

create 3D city and landscape models, aerial photogrammetry, and precision property aerial surveys

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).