U.S. Department of Transportation

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Regulatory Docket No.__________

Exemption Request Under Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations

Submitted on July 02, 2015

Craig Taylor Abington Jr.

Project Lead, Commercial UAS 

4905 Research Drive Northwest

Huntsville, Alabama 35805-5905

Tel: (256) 327-7182

taylor.abington@avioninc.com
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Table of Contents

Table of Contents..........................................................................................................................................1

Glossary of Abbreviations.............................................................................................................................3

Summary Letter ............................................................................................................................................4

Introduction and Interests of Avion..............................................................................................................6

Basis for Petition ...........................................................................................................................................7

Name and Address of Avion......................................................................................................................9

14 CFR Sections for Requested Exemption.............................................................................................10

Reasons Why Requested Exemption Would Be In Public Interest .........................................................21

Reasons Granting Exemption Would Not Adversely Affect Safety.........................................................23

Key Personnel .............................................................................................................................................25

General....................................................................................................................................................25

Operators................................................................................................................................................25

Requirements......................................................................................................................................25

Training ...............................................................................................................................................25

Visual Observers .....................................................................................................................................25

Requirements......................................................................................................................................25

Training ...............................................................................................................................................25

Maintainers.............................................................................................................................................26

Requirements......................................................................................................................................26

Training ...............................................................................................................................................26

Operations ..................................................................................................................................................27

Maintenance ...........................................................................................................................................27

Training ...................................................................................................................................................28

Flight .......................................................................................................................................................28

Privacy.........................................................................................................................................................31

Aircraft ........................................................................................................................................................33

DJI Innovations Phantom 2 .....................................................................................................................33

DJI Innovations Phantom 3 .....................................................................................................................35

DJI Innovations Inspire............................................................................................................................38

DJI Innovations Spreading Wings S1000 .................................................................................................42

Summary That Can Be Published In the Federal Register...........................................................................44
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Conclusion...................................................................................................................................................45

Appendices..................................................................................................................................................46

A. Avion Solutions Inc. Unmanned Aircraft Systems (UAS) Standard Operating Procedures.............46

B. DJI Phantom 2 Documentation.......................................................................................................47

C. DJI Phantom 3 Documentation.......................................................................................................48

D. DJI Inspire 1 Documentation...........................................................................................................49

E. DJI Spreading Wings S1000 Documentation...................................................................................50
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Glossary of Abbreviations

AGL Above Ground Level

ATO Air Traffic Organization 

AV Aerial Vehicle 

Avion Avion Solutions Incorporated

C.F.R. Code of Federal Regulation 

CFR Code of Federal Regulations 

COA Certificate of Waiver or Authorization 

CS Control Station

CTAF Common Traffic Advisory Frequency

DOD Department of Defense 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation(s)

FCC Federal Communications Commission 

GCS Ground Control Station 

GHz Gigahertz 

NAS National Airspace System 

NM Nautical Mile 

NOTAM Notice to Airman 

PIC Pilot In Command

POC Point of contact

R&D Research and Development

Avion Avion Solutions Inc. 

Phantom Phantom Unmanned Aircraft System 

RTB Return to Base

Section 333 FAA Modernization and Reform Act of 2012 

SOP Standard Operating Procedures 

sUAS Small Unmanned Aircraft Systems

UAS Unmanned Aircraft System(s) 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VO Visual Observer
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Summary Letter

July 02, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request under Section 333 of the FAA Modernization and Reform Act of 2012

and 14 C.F.R. Part 11

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 and 14 CFR Part 11, Avion Solutions Inc., Operator of Unmanned Aircraft 

Systems (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of its UAS, so long as such operations are conducted 

within and under the conditions outlined herein, as described in the attached appendices, or 

as may be established by the FAA as required by Section 333.

These limitations provide for at least an equivalent or higher level of safety (LOS) to operations 

under the current regulatory structure. Specifically, Avion Solutions Inc. will provide a safety 

enhancement and economic relief to those individuals/corporations who currently rely on 

manned aircraft to perform aerial data collection services.

The issuance of these requested exemptions will permit Avion Solutions Inc. to safely operate 

UAS under controlled conditions and in the National Airspace (NAS) for the purposes of UAS 

flight training, research and development (R&D), and aerial data collection. Approval of this 

exemption request will provide for safe, professional , commercial UAS operations, and fulfill 

the FAA Administrator's responsibilities to “... establish requirements for the safe operation of 

such aircraft systems in the national airspace system" Consistent with Section 333(c) of the 

Reform Act.
5

Acknowledging the FAA’s mission to provide the safest and most efficient airspace system in 

the world, our commercial operation of UAS will comply with applicable FARs, as well as the 

Avion Solutions Inc. Proprietary Standard Operating Procedures (SOP), to include safety, 

training and aircraft maintenance procedures, which are attached as appendices.

Avion Solutions will operate its UAS in accordance with all applicable FARs, this exemption, 

and any additional guidelines as provided by the Administrator.

Thank you for your consideration. Any additional information required by the FAA for approval 

purposes will be provided in an expedited manner. 

Respectfully, 

Evan Wagner

Vice President, Chief Operating Officer

Huntsville, AL 35805

Office: (256)-327-7109, Fax: (256)-721-7007

Email: ewagner@avioninc.com
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Introduction and Interests of Avion

Avion Solutions Incorporated (Henceforth identified as Avion Solutions or Avion) is a national 

engineering, logistics, software engineering, test and evaluation small business, specializing in 

material solutions and technical support for military grade products. Headquartered in 

Huntsville, Alabama, the company has been providing aviation related support to the U.S. 

Army for over 23 years in the form of contract support and subject matter expertise in a 

number of technical areas and on all of the Army's rotary-wing, fixed-wing and unmanned 

platforms. Avion has worked to develop a strong reputation for quality services within the 

military aviation community and is seeking to expand into the commercial UAS market. 

Much of our company expertise is in aviation, with a workforce consisting primarily of retired 

military aviators, maintainers, Airframe and Powerplant (A & P) mechanics, A & P with 

Inspection Authorization (IA), instructor pilots, maintenance test pilots, and technicians that 

support airworthiness standards. Avion has expertise in developing and conducting aviation 

related training in both the classroom and field environments. Avion Solutions will rely heavily 

on this experience and technical knowledge to operate commercial UAS in the NAS, develop 

unique product solutions, standardize UAS operating procedures, and train UAS Operators and 

support elements in this highly technical field. Avion is focused on providing solutions for 

utilizing unmanned aircraft to safely and efficiently collect actionable data for the customer.

Avion Solutions seeks exemption in order to commercially operate UAS in an actively managed

environment, for the purposes of training, conducting R&D, and aerial data collection. Avion

proposes to use small, lightweight UAS for all of the requested operations. Aircraft to be 

utilized are electric powered rotorcraft, equipped with four to eight electric motors. The 

weight of these aircraft will not exceed 55 lbs., and they will be operated at all times by an 

FAA and exemption compliant UAS Operator. Additional information about the aircraft to be 

utilized and key personnel can be found in this petition for exemption, and in the Avion SOP. 
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Basis for Petition

Avion Solutions Inc. requests exemptions from several provisions of the FARs in accordance 

with Section 333 of the FAA Modernization and Reform Act of 2012. Avion Solutions seeks 

exemption in order to commercially operate small Unmanned Aircraft Systems (sUAS) in a 

sterile environment clear of people and objects for the purposes of training and educating UAS 

Operators, Visual Observers, and Maintainers. In addition to training, Avion intends to 

conduct research and development and data collection to include but not limited to, aerial 

survey, agricultural inspections, building/infrastructure inspections, aerial imagery for real 

estate purposes, and any other approved FAA UAS operations not associated with closed set 

cinematography. 

Avion may update or revise its operating documents. Avion will track such revisions and 

present updated and revised documents to the Administrator or any law enforcement official 

upon request. Avion will track all changes to documents approved in this Exemption Request 

in accordance with the Avion SOP. Avion will also present updated and revised documents if it 

petitions for extension or amendment to this grant of exemption. 

Avion requests the included exemptions and offers the following documents located in the 

appendices for supporting information:

 Avion Solutions Inc. Unmanned Aircraft Systems (UAS) Standard Operating Procedures

 DJI Phantom 2

o DJI Phantom 2 User Manual

o Phantom 2 Quick Start Guide

o Zenmuse H4-3D Gimbal Quick Start Guide

o Smart Flight Battery Safety guidelines

o Phantom 2 FPV Hub Kit Instructions v1.0

o Naza-M(v2) Quick Start Guide v1.22

o 2.4G Bluetooth Datalink and iPad Ground Station User Guide v1.12

o DJI New Pilot Experience 2015

o Avion Solutions Phantom 2 Checklist

 DJI Phantom 3

o DJI Phantom 3 Professional User Manual v1.0

o DJI Phantom 3 Safety Guidelines and Disclaimer

o DJI Phantom 3 Professional Quick Start Guide

o DJI Phantom 3 Intelligent Flight Battery Safety Guidelines

o Avion Solutions Phantom 3 Checklist

 DJI Inspire 1

o DJI Inspire 1 User Manual v1.2

o DJI Inspire 1 Quick Start Guide v1.2

o DJI Intelligent Flight Battery Safety Guidelines

o DJI Inspire 1 Safety Guidelines
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

o DJI Inspire 1 Maintenance Manual v1.0

o DJI Disclaimer & Warning

o DJI 1345s Quick Release Propellers for the Inspire 1 Quick Start Guide

o Avion Solutions Inspire 1 Checklist

 DJI Spreading Wings S1000

o DJI Spreading Wings S1000+ User Manual v1.2

o Avion Solutions S1000 Checklist
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Name and Address of Avion

The name and address of Avion is:

Avion Solutions Inc.

4905 Research Drive Northwest

Huntsville, Alabama 35805-5905

The Signature Authority for this petition is:

Evan Wagner

Vice President, Chief Operating Officer

Huntsville, Alabama 35805

Office: (256)-327-7109, Fax: (256)-721-7007

E-mail: ewagner@avioninc.com

The point of contact (POC) for this Petition is:

Craig “Taylor” Abington Jr.

Project Lead, Commercial UAS 

4905 Research Drive Northwest

Huntsville, Alabama 35805-5905

Tel: (256) 327-7182 Fax: (256) 721-7007

Cell: (615) 604-1428

E-mail: taylor.abington@avioninc.com

UAS@avioninc.com

Daniel Michael Carbone

Assistant Project Lead, Commercial UAS 

4905 Research Drive Northwest

Huntsville, Alabama 35805-5905

Tel: (256) 327-7182 Fax: (256) 721-7007

Cell: (931) 302-2633

E-mail: daniel.carbone@avioninc.com

UAS@avioninc.com
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

14 CFR Sections for Requested Exemption

The Federal Aviation Act expressly grants the FAA Administrator the authority to issue 

exemptions. By its terms, this statutory authority includes exempting civil aircraft, as the term 

is defined under § 40101 of the Act, including sUAS, from its safety regulations and minimum 

standards when the Administrator decides a requested exemption is in the public interest. 

Avion asks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 

91 for purposes of conducting aerial data collection, R&D, inspections and training utilizing 

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

The extent of relief Avion seeks exemption; (3) the operating procedures and safeguards that 

Avion has established which will ensure a level of safety equal to or higher than the rules from 

which exemption is sought. The full Code of Federal Regulations (Including the specific Title 

14 requested exemptions) is available on eCFR.com, excerpts or recaps of these regulations 

included in this document are for reference only.

Specific sections of 14 C.F.R. for which exemption is sought:

Title 14 – Aeronautics and Space

PART 21 – CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

Subpart h - airworthiness certificates

PART 45 – IDENTIFICATION AND REGISTRATION MARKING

§ 45.23 (b) – display of marks; general.

§ 45.27 – Location of marks; nonfixed-wing aircraft.

§ 45.29 – size of marks

PART 61 – CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

§ 61.101 (e) (4) and (5) – recreational pilot privileges and limitations. 

§ 61.113 (a) and (b) – private pilot privileges and limitations: pilot in command.

§ 61.315 (a) and (c) – what are the privileges and limits of my sport pilot certificate?

PART 91 – GENERAL OPERATING AND FLIGHT RULES

§ 91.7 (a) – civil aircraft airworthiness.

§ 91.9 (b) (2) and (c) – civil aircraft flight manual, marking, and placard requirements. 

§ 91.103 – preflight action.

§ 91.109 – flight instruction: simulated instrument flight and certain flight tests. 

§ 91.119 – minimum safe altitudes: general.
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PART 91 – GENERAL OPERATING AND FLIGHT RULES (cont.)

§ 91.121 (a) (1) – altimeter settings.

§ 91.151 (a) (1) – fuel requirements for flight in VFR conditions. 

§ 91.203 – civil aircraft: certifications required. 

§ 91.405 (a) – maintenance required.

§ 91.407 (a) (1) – operation after maintenance, preventive maintenance, rebuilding, or 

alteration. 

§ 91.409 (a) (1) and (2) – inspections.

§ 91.417 (a) (1) and (2) – maintenance records.

PART 21 – CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS

Subpart h - airworthiness certificates

The Extent Of Relief Avion Seeks Exemption:

Avion seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 C.F.R § 

91.203(a)(1). Given the size and limited operating area associated with the UAS to be utilized 

by Avion, an exemption from Part 21, Subpart H meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act.5

The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

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

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations.

Equivalent Level of Safety:

An equivalent level of safety for an exemption to the airworthiness requirements stated within 

Part 21, Subpart H – airworthiness certificates, will be achieved by operating a UAS that is 

under 55 lbs, carries neither a pilot nor passengers, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a known secured area as set out by the 

issuance of this exemption request and a Certificate of Authorization or Waiver (COA). 

Additionally, Avion will ensure compliance with any guidance regarding UAS airworthiness 

made by the FAA.

The FAA has issued the following exemptions to 14 CFR, Part 21, Subpart H – Airworthiness 

requirements: Exemptions Nos. 10700, 8738, 10167 and 10167A.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

PART 45 – IDENTIFICATION AND REGISTRATION MARKING

§ 45.23(b) – display of marks; general.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.23 which identifies the registration number marking 

requirements for aircraft. This regulation requires aircraft to be marked with not less than nor 

more than 6 inch Roman lettering identifying the aircrafts registered N-number. This 

regulation also requires the words “limited,” “restricted,” “light-sport,” “experimental,” or 

“provisional,” as applicable, to be placed near the cockpit of the aircraft. 

Given the size of the UAS to be operated, two inch lettering is not possible. Official marking 

systems for small UAS have not yet been established by the FAA for operations inside the NAS. 

The aircraft utilized by Avion are not configured with a cockpit and are not currently identified 

by one of the five classifications listed above. 

Equivalent Level of Safety

Avion Solutions will meet an equivalent level of safety by placing the registered N-Number on 

the aircraft as large as practical, utilizing Roman capital lettering. The ground control Station 

(GCS) will also be marked with the N-number of the aircraft it is operating. The GCS will be 

marked in a manner similar to the aircraft, using Roman Capital lettering and as large as 

practical. These internal requirements for marking aircraft and GCS are identified in the Avion 

SOP. Additionally, Avion will ensure compliance with any guidance regarding UAS marking by 

the FAA.

Given the nature of the specific relief sought by this exemption request, Avion requires relief 

from the associated marking and identification requirements of § 45.27 and § 91.9, which 

would require compliance with§ 45.23(b).

The FAA has issued the following exemptions to 14 CFR, § 45.23 – display of marks; general: 

Exemptions Nos. 10700, 8738, 10167 and 10167A.

§ 45.27 – Location of marks; nonfixed-wing aircraft.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.27 which identifies the location of marks for non-fixed 

wing aircraft. This regulation states that the Operators of a rotorcraft must display the marks 

as required by §45.23 horizontally on both sides of the aircraft. Because this regulation 

specifically references compliance with §45.23, a regulation identified for exemption by Avion, 

an exemption will be required.

Equivalent Level of Safety

Avion will meet an equivalent level of safety by placing the registered N-number on both sides 

of the aircraft in a location that allows for the largest possible lettering. The GCS will also be 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

marked with the N-number of the aircraft it is operating. The GCS will be marked in a manner 

similar to the aircraft as identified in the Avion SOP. The locations of all aircraft and 

equipment markings are identified in the Avion SOP. Additionally, Avion will ensure 

compliance with any guidance regarding UAS marking/location by the FAA.

The FAA has issued the following exemptions to 14 CFR, § 45.27 – Location of marks; nonfixedwing aircraft: 

Exemptions No. 11188

§ 45.29 – size of marks

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 45.29 which establishes the size requirements for markings 

on aircraft. This regulation specifically identifies height, width, thickness and spacing of marks. 

It also calls out a 12 inch height requirement for marks on rotorcraft. 

Avion has requested exemption from § 45.23 and § 45.27, which cover the display and 

location of marks on aircraft. Due to the size of the UAS to be operated, twelve inch lettering 

is not possible, and a standard for UAS marking has not yet been identified by the FAA. 

Equivalent Level of Safety

Avion will meet an equivalent level of safety by placing the registered N-number on both sides 

of the aircraft in a location that allows for the largest possible lettering. The GCS will also be 

marked with the N-number of the aircraft it is operating. The GCS will be marked in a manner 

similar to the aircraft as identified in the Avion SOP. The locations of all aircraft and 

equipment markings are identified in the Avion SOP. Additionally, Avion will ensure 

compliance with any guidance regarding UAS marking/location by the FAA.

The FAA has issued the following exemptions to 14 CFR, §45.29 – size of marks: 

Exemptions Nos. 11136, 11157, 11170, 11185, 11193

PART 61 – CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND GROUND INSTRUCTORS

§ 61.101 (e) (4) and (5) – recreational pilot privileges and limitations.

§ 61.113 (a) and (b) – private pilot privileges and limitations: pilot in command.

§ 61.315(a) and (c) – what are the privileges and limits of my sport pilot certificate?

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 61.101 (e) (4) and (5), § 61.113 (a) and (b), and § 61.315(a) 

and (c). These parts establish that a person who holds a Recreational, Private, or Sport pilot 

certificate may not act as pilot in command of an aircraft for compensation or hire, or, in 

furtherance of a business. Regulations identifying the requirements for a UAS pilot have not 

yet been established by the FAA. The FAA has however approved exemptions requiring the 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Operator of an UAS to hold at a minimum a Sport Pilot certificate. Additionally, Avion will 

ensure compliance with any guidance regarding UAS pilot certifications by the FAA.

Equivalent Level of Safety

Pilots operating a UAS for Avion will hold at a minimum, a Sport Pilot certificate. Each pilot 

will maintain currency requirements for the rating they hold as required by the appropriate 

FARs. Avion will maintain flight and currency records for all pilots operating Avion UAS. The 

minimum training standards will be met prior to the operation of any aircraft for commercial 

use. Training will be conducted during specific training flights and recorded per the Avion 

SOP.

The FAA has issued the following exemptions to § 61.101 (e) (4) and (5) – recreational pilot 

privileges and limitations. § 61.113 (a) and (b) – private pilot privileges and limitations: pilot in 

command.

Exemptions Nos. 11371, 11370, 11388

PART 91 – GENERAL OPERATING AND FLIGHT RULES

§ 91.7(a) – civil aircraft airworthiness.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.7(a), which requires that a civil aircraft be in an airworthy 

condition to be operated. There are currently no airworthiness certificates for the UAS 

identified in the Exemption Request. Because there are no airworthiness certificates for these 

UAS, there is no standard on which to base an airworthy condition. Additionally, Avion will 

ensure compliance with any guidance regarding UAS airworthiness by the FAA.

Equivalent Level of Safety

All Avion Operators will receive training to accurately pre- and post-flight any UAS in which the 

Operator is rated. Given the size of the UAS, the requirements contained in the 

manufacturer’s user manual, and the use of safety checklists prior to each flight, an equivalent 

level of safety will be provided. Avion will maintain a maintenance log book and record any/all 

deficiencies noted during pre-flight, flight and post-flight inspections. The corrective actions 

required/taken to return the aircraft to service will be logged in accordance with the 

appropriate manufacturer’s manual and the Avion SOP. 

The FAA has issued the following exemptions to § 91.7(a) – civil aircraft airworthiness: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

§ 91.9 (b) (2) and (c) – civil aircraft flight manual, marking, and placard requirements.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.9 (b) (2) and (c) which provide that no person may 

operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 

45 of this chapter and has a current approved rotorcraft flight manual available in the aircraft. 

Compliance with § 91.9 is impossible given the exemptions requested from specific portions of 

part 45 earlier in this document, and the lack of space on the aircraft for rotorcraft manual 

placement. Additionally, Avion will ensure compliance with any guidance regarding UAS 

marking/placarding requirements by the FAA.

Equivalent Level of Safety

Avion has requested an exemption from § 45.23 – display of marks; general, § 45.27 –

Location of marks; non fixed-wing aircraft, and § 45.29 – size of marks. Due to the request for 

exemption from these regulations, Avion will not be able to comply with § 91.9. As previously 

stated Avion will maintain an equivalent level of safety by marking the aircraft in the most 

practicable manner. Avion will maintain all of the required documentation for flight, to 

include a manufacturer’s rotorcraft flight manual (or equivalent) accessible to the Operator of 

the UAS at all times of operation. The documentation to be maintained and its location are

outlined in the Avion SOP.

The FAA has issued the following exemptions to § 91.9(b)(2) – civil aircraft flight manual, 

marking, and placard requirements: Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 

11161, 11166, 11167, 11170, 11171, 11172, 11174, 11177, 11178, 11184, 11185, 11188, 

11189, 11191, 11192, 11193, 11195, 11204.

The FAA has issued the following exemptions to § 91.9(c) – civil aircraft flight manual, marking, 

and placard requirements: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 

11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11111, 11112, 11114, 11136, 11138, 11150, 11153, 

11156, 11157, 11174, 11177, 11178, 11184, 11185, 11189, 11192, 11193, 11195.

§ 91.103(b) (2) – Preflight action. 

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from§ 91.103 (b) (2), 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. Because an FAA approved flight manual will not be 

provided for the aircraft, an exemption is requested. Additionally, Avion will ensure 

compliance with any guidance regarding UAS preflight actions by the FAA.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Avion Solutions Inc. aircraft

comprehensive checklists. The Operator will take all actions, including reviewing weather, 

flight battery requirements, landing and takeoff clearance, and aircraft performance data, 

before initiation of flight.

The FAA has issued the following exemptions to § 91.103(b) (2) – Preflight action: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11138, 11150, 

11153, 11156, 11158, 11160, 11161, 11166, 11167, 11171, 11172, 11176,11177, 11178, 11184, 

11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195, 11204

§ 91.109 (a) – flight instruction: simulated instrument flight and certain flight tests

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from 14 C.F.R. § 91.109(a), which provides that "no person may 

operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functional dual controls.” Remotely piloted aircraft and UAS, by 

their design, do not have fully functional dual controls. Aircraft control surface manipulation is 

accomplished through the use of an electronic controller, communicating with the UAS via FCC 

approved radio communications. Additionally, Avion will ensure compliance with any 

guidance regarding UAS flight instruction by the FAA.

Equivalent Level of Safety

Given the size and speed of the UAS, an equivalent level of safe training can still be performed 

without dual controls because no pilot or passengers are aboard the UAS. All personnel 

unrelated to the training event will be a safe distance away in the event that the UAS Operator 

experiences any difficulties during flight instruction. All flight training will be conducted during 

dedicated training sessions, in a dedicated training area. The FAA has approved exemptions 

for flight training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft.

The FAA has issued the following exemptions to § 91.109 (a) – flight instruction: simulated 

instrument flight and certain flight tests: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11166, 11167, 11170, 11171, 11174, 11177, 

11184, 11185, 11189, 11191, 11192, 11193, 11194, 11195, 11206, 11208
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

§ 91.119 – minimum safe altitudes: general.

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. 

This Section 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. Section § 91.119(d) (l) 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.

During certain types of operations, to include but not limited to aerial inspections, the UAS will 

be required to maintain a distance of approximately 50 feet or less in order to collect the 

necessary data. Because of these operation requirements an exemption from this regulation 

is required. Additionally, Avion will ensure compliance with any guidance regarding UAS 

minimum safe altitudes by the FAA.

Equivalent Level of Safety

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

weight proposed herein, and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight and speed of the UAS as well as the 

location where it is operated. Personnel associated with flight operations will be briefed of the 

expected route of flight and the associated risks to persons and property on the ground prior 

to conducting flight operations. 

The FAA has issued the following exemptions to § 91.119 – minimum safe altitudes: general : 

Exemptions Nos. 11162, 11163, 11164, 11165, 11166, 11108, 11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 

11172, 11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

§ 91.121 (a) (1): Altimeter Settings

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.121 (a) (1), a regulation which requires an aircraft 

operator 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 

because the UAS does not have a barometric altimeter, but rather a GPS altitude shown in an 

on-screen display. 

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the 

aircraft checklists. Prior to lifting off the Operator will confirm a zero altitude reading, and 
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monitor this reading as the aircraft climbs to a hover following take off. The Operator will use 

the GPS altitude indicator to constantly monitor the UAS height, thus ensuring operation at 

safe altitudes (Below 400 Ft AGL). Select aircraft, to include the Inspire 1 and Phantom 3 

employ the use of a Vision Positioning Sensor (VPS) to maintain stable flight at low altitudes. 

All of the aircraft to be utilized by Avion have the ability to program maximum allowable 

altitude. This maximum altitude limit will be confirmed at 400 Ft AGL prior to flight. 

The FAA has issued the following exemptions to § 91.121: Altimeter Settings: 

Exemptions Nos. 11162, 11163, 11164, 11165, 11166, 111080, 111109, 11136, 11138, 11150, 

11153, 11156, 11160 11161, 11166, 11167, 11170, 11171, 11174, 11176, 11178, 11185, 11188, 

11189, 11190, 11193

§ 91.151 (a) (1) – fuel requirements for flight in VFR conditions. 

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.151 (a) (1) which identifies the Fuel requirements for 

flight in VFR conditions. A “fuel requirement” to reach the first point of intended landing is 

achievable by all of the aircraft in which Avion will operate. A “fuel reserve” of at least thirty 

minutes is not achievable. The aircraft that Avion intends to operate have a maximum flight 

time of approximately 25 minutes. Additionally, Avion will ensure compliance with any 

guidance regarding UAS fuel requirements by the FAA.

Equivalent Level of Safety

Avion Solutions has developed an extensive series of checklists, mission briefs and safety/risk 

matrices. All Avion Operators and Visual Observers will actively monitor the battery status to 

ensure safe levels of operation, and at no time will the aircraft be operated at a distance 

where it cannot, under its own power return to the origination point. The UAS are set for low 

battery warning at thirty percent (30%) and automatic “Return to home” at ten percent (10%) 

battery power. These internal standards can be reviewed in the Avion SOP. 

The FAA has issued the following exemptions to 14 CFR, § 45.27 – Location of marks; nonfixedwing aircraft: 

Exemptions Nos. 10700, 10167, 10167A, 11110, 11153, 11156, 11161; 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11160, 11161, 11166, 11167, 11170, 11171, 11172, 

11174, 11176, 11178, 11185, 11188, 11189, 11190, 11193

§ 91.203(a) (1) – civil aircraft: certifications required. 

The Extent of Relief Avion Seeks Exemption

Avion seeks an exemption from § 91.203(a) (1) which identifies that no pilot may operate any 

aircraft unless it has an appropriate and current airworthiness certificate. Currently, none of 

the aircraft to be utilized by Avion hold an airworthiness certificate. Avion will maintain each 
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aircraft to a level equivalent to the aircraft’s original condition as determined by the aircraft 

manufacturer. Aircraft will be inspected routinely in accordance with the manufacture 

manuals and the Avion SOP. Additionally, Avion will ensure compliance with any guidance 

regarding airworthiness requirements by the FAA.

Equivalent Level of Safety

Avion Solutions will maintain strict adherence to its SOP and maintenance standards. 

Operators and Maintainers will ensure that all aircraft are maintained to the aircraft 

manufacturer specifications, and that all maintenance is properly logged in accordance with 

the SOP. In the event that specific maintenance techniques are not outlined in the 

manufacturer manuals, maintenance will be performed utilizing standard aviation 

maintenance practices as identified in AC 43.13-1B - Acceptable Methods, Techniques, and 

Practices - Aircraft Inspection and Repair. Maintenance records for each aircraft will be 

available for inspection at the Avion Solutions Inc. building.

The FAA has issued the following exemptions to 91.203(a) (1) – civil aircraft: certifications 

required: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 

11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 11185, 11188, 11188, 11189, 11191, 11192, 11193, 11195

§ 91.405 (a) – maintenance required.

§ 91.407 (a) (1) – operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

§ 91.409 (a) (1) and (2) – inspections.

§ 91.417 (a) (1) and (2) – maintenance records.

The Extent of Relief Avion Seeks Exemption

Avion seeks exemption from § 91.405 (a), § 91.407 (a) (1), § 91.409 (a) (1) and (2), and §

91.417 (a) (1) and (2). These regulations address maintenance activities and require that an

aircraft operator or owner, “shall have that aircraft inspected as prescribed in paragraph (c) of 

this section, have discrepancies repaired as prescribed in part 43 of this chapter...” and others 

shall inspect or maintain the aircraft in compliance with Part 43. 

The four UAS airframes identified in this exemption request do not hold an airworthiness 

certificate; therefore they may not be maintained in accordance with the above regulations. 

Equivalent Level of Safety

Because Avion Solutions is an aviation centric, company we understand the absolute 

requirement for safety during flight operations, and the equivalent requirement during 

maintenance performed on the aircraft and its systems while on the ground. An equivalent 

level of safety will be achieved by maintaining the UAS in accordance with the manufacturer’s

guidelines. When no manufacturer reference is available, standard aviation maintenance 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

practices will be utilized. An aircraft logbook will be maintained for each airframe and all 

maintenance performed, to include functional test flights, will be logged. Additional 

information in regard to maintenance can be found in this Petition and the Avion SOP. 

The FAA has issued the following exemptions to § 91.405 (a) – maintenance required, § 91.407 

(a) (1) – operation after maintenance, preventive maintenance, rebuilding, or alteration, § 

91.409 (a) (1) and (2) – inspections, and § 91.417 (a) (1) and (2) – maintenance records: 

Exemptions Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11111, 

11112, 11114, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11160, 11161, 11166, 

11167, 11170, 11171, 11172, 11174, 11176, 11177, 11178, 11184, 11185, 11188, 11188, 

11189, 11191, 11192, 11193, 11195, 11204
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Reasons Why Requested Exemption Would Be In Public Interest

By granting this exemption request, Avion Solutions will be able to promote the fundamentals 

of safe UAS operations to students who participate in our training programs. Our training 

methods were developed to help new operators identify the risks associated with these 

operations and to prepare for and mitigate them. By cultivating a growing industry of UAS 

professionals, Avion is acting in the public interest, as this ensures that future operators are 

sufficiently trained with an added level of awareness and safety when conducting UAS 

operations.

Avion’s existing relationships within the aerospace community promote awareness of UAS 

operations and the inherent benefits of their use. Granting this petition allows Avion to share 

valuable experience obtained through operations and training, and promote the UAS research 

efforts of policymakers including the FAA, NASA, and DoD. This would provide significant

benefits to the public interest.

Avion Solutions is an active member of the Huntsville community. Our participation in local 

events gives us an opportunity to address the safe and responsible use of unmanned aircraft 

during public awareness campaigns, local technology events, school job fairs, law enforcement 

demonstrations, and hobby/RC events. Public education is critical for two reasons; 1) If the 

public has a better understanding of the UA and how it can be used safely, they will be less 

likely to fear or dismiss the technology, and 2) Hobbyists and private owners of UA learn the 

repercussions of not adhering to FAA requirements from both a legal and a safety standpoint. 

For these reasons, granting this exemption request would provide a benefit to the public 

interest that would continue to grow over time.

The efficiency of utility operations is heavily dependent upon constant monitoring of assets 

and facilities, right-of-way, vegetation encroachment, and infrastructure inspection. There are 

a wide variety of factors that can affect operating conditions and cause problems for 

infrastructure. Avion’s UAS services would provide the capability to identify and report 

infrastructure damage. This would greatly reduce downtime and improve the cost, speed, and 

efficiency of repair efforts resulting in a measurable benefit to the public interest.

Avion Solutions currently works closely with the Alliance for System Safety of UAS through 

Research Excellence (ASSURE) which includes twenty-one of the world’s leading research 

universities and a hundred leading industry and government partners. Through ASSURE, Avion 

supports UAS research and development efforts associated with Air Traffic Control 

Interoperability, Airport Ground Operations, Control and Communication, Detect and Avoid 

(DAA), Human Factors, Low Altitude Operations Safety, Noise Reduction, UAS Traffic 

Management (UTM), and a number of additional research topics of interest to the FAA and the 

NAS. Avion will leverage our aviation experience and provide valuable input to these 

programs, proving our commitment to safe integration of UAS into the NAS. 

Given the clear direction in Public Law 112–95 § 333, the equivalent level of safety 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

surrounding the proposed operations, and the significant public benefit including reduced 

noise levels and lower operating costs through more efficient equipment, granting this 

petition is deemed to be in the public interest.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Reasons Granting Exemption Would Not Adversely Affect Safety

The enhanced safety achieved using an unmanned aircraft (UA) with the specifications 

described within this petition and carrying no passengers or crew, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, would 

provide the FAA good cause to find that the UAS operation enabled by this exemption would 

not adversely affect safety.

Prior to conducting any UAS operations, Avion will conduct a mission brief as identified in the 

Avion SOP. Aircrews will also conduct a risk assessment and discuss any additional safety 

issues identified by the client before conducting UAS operations. All Avion UAS aircrew 

members will comply with qualification, currency, and training requirements as outlined in the 

Avion SOP prior to conducting flight operations. Safety to the public and property will be of 

the highest priority when conducting flight operations. Avion will only employ well trained and 

competent Operators and VOs. Operations will be conducted through the use of checklists to 

ensure safe, predictable, and consistent outcomes.

All current and future UAS operated by Avion will employ the use of automated safety 

features to provide an additional level of safety in the event of a lost communications link 

between the Operator and aircraft. The automated safety features will direct the UA to a predetermined “home” point if the control signal is interrupted. This same feature will safely land

the aircraft in the event of a low battery condition. Avion will continue to pursue technology 

which employs the use of sensors on future platforms. These safety features are designed to 

improve the level of safety and not adversely affect it.

Avion will conduct annual safety training and document this training in accordance with the 

Avion SOP. Training will include current practices, lessons learned from prior operations, FAA 

guidance and policy, and industry-specific safety measures. Flight data, inspection results, 

recorded observations and lessons learned from UAS operations will be periodically compiled 

and reviewed to further enhance Avion’s current safety program.

Based on Avion Solutions’ extensive manned and unmanned aviation experience, granting an 

exemption would not adversely affect safety. Avion employees already adhere to exacting 

military aviation safety standards, and our industry partnerships with like-minded 

organizations prove Avion’s commitment to safety. Avion will also abide by local safety laws 

and ordinances and communicate with the proper authorities if discrepancies or 

inconsistencies exist that might adversely affect safe operation. 

Avion’s proposed operations to perform training, R&D, and aerial data collection will reduce

the unnecessary exposure of personnel and property to dangerous activities by decreasing the 

requirement for personnel to climb structures and/or operate costly manned aircraft. This 

would not adversely affect safety, but instead greatly reduce the level of risk associated with 

performing these operations. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

The limitations provided by the FARs, this exemption request, and any additional guidance 

provided for commercial UAS operations by the FAA Administrator, will ensure a level of 

safety previously unattainable by manned aircraft. Based on the size and the limited area of 

operations of the aircraft, approval of this request presents no threat to National Security.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Key Personnel

General

All Avion Solutions employees participating in UAS activities will receive formal UAS training in 

the area of their assigned responsibility. This training will be outlined and tracked in 

accordance with the SOP. 

Operator

Requirements

 Must hold at a minimum a sport pilot certificate.

 The PIC must also hold a current FAA airman medical certificate as required for the 

type of certificate held.

 Must meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the Operator is rated as identified on the pilot certificate.

 Must meet UAS flight hour minimums as outline in the SOP.

 Must meet all training requirements of the assigned responsibility in accordance with 

the SOP. 

Training

 5 flight hour minimum, per airframe prior to operating commercially.

 10 flight hour minimum, per aircraft type prior to operating commercially.

 25 flight hour minimum total UAS time prior to operating commercially.

 Completion of UAS Operator Training IAW the SOP.

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operator Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP. 

Visual Observer

Requirements

 Must meet all training requirements of the assigned responsibility in accordance with 

the SOP. 

Training

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operator Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Maintainer

Requirements

 Must exhibit familiarity with the aircraft systems being operated.

 Must comply with all maintenance guidelines for aircraft in accordance with 

manufacturer manuals, safety bulletins, guidelines and warnings.

 Must comply with all guidelines for performing aircraft maintenance in accordance 

with the SOP.

 Must comply with all guidelines for documentation of aircraft maintenance in 

accordance with the SOP

 Must meet all training requirements of the assigned responsibility in accordance with 

the SOP. 

Training

 Completion of Visual Observer Training IAW the SOP.

 Completion of Payload Operator Training IAW the SOP.

 Completion of Annual Aviation Safety Training IAW the SOP. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Operations

Maintenance

Avion will perform all maintenance activities, to include inspections, preventive maintenance, 

and condition based maintenance in accordance with the manufacturer’s manuals. When the 

manufacturer documentation does not identify specific maintenance procedures, best 

maintenance practices will be utilized and recorded in the aircraft logbook. All maintenance 

activities will be recorded in the aircraft logbook and will include the following items:

 Date of work performed

 Aircraft total time in service

 Description of the work accomplished

 Signature of the individual who performed the work

 Certificate number and type being exercised

A squawk sheet will be available for aircraft Operators to denote faults identified during preand post-flight inspections. The squawk sheet may be inserted into the aircraft logbook, or 

entries may be transposed directly into the logbook by the original entry maker. The Squawk 

sheet is identified in the Avion SOP. 

Functional test flights will be performed following maintenance/modifications that affect flight 

characteristics, and/or the replacement of flight critical components. Functional test flights 

will be conducted in accordance with the Avion SOP and will be annotated in the aircraft 

logbook. 

When modifications to an aircraft are made for research and development, or when mission 

equipment is installed/removed, an entry will be made in the aircraft logbook. In addition to a 

logbook entry and a functional test flight, the performing activity will complete an aircraft 

basic weight and configuration form in order to ensure aircraft maximum operating weight 

compliance. This form is identified in the Avion SOP. 

The most current firmware available from the manufacturer will be installed and verified in 

the aircraft, GCS and any additional equipment as required, prior to flight. Avion will adhere 

to any safety or flight critical related bulletins for the aircraft being operated. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Training

Training will be conducted for all personnel involved in the pre-flight, mission, and post-flight 

activities associated with commercial UAS operations. Training will be conducted in 

accordance with the Avion SOP by assigned responsibility. All training will be conducted in a 

sterile training environment. Training flights will be conducted during dedicated sessions only, 

and will include a Visual Observer at all times. 

Training requirements and standards for each key personnel is outlined above and in the 

Avion SOP. Key personnel include Operators, Visual Observers/Payload Operators and 

Maintainers. Each of these key personnel will maintain proficiency in their respective areas by 

adhering to the Avion SOP currency/training requirements. Training and currency will be 

logged in individual logbooks and will be available for review. Training reviews will be 

conducted annually to ensure that the most recent and effective training 

procedures/standards are being utilized. 

Flight

No flight operations will be conducted with less than the Avion SOP approved minimum 

personnel, which includes an aircraft Operator and a Visual Observer. All missions will be 

briefed in accordance with the Avion Air Mission Brief prior to flight. The property owner will 

be briefed on the operation and a Risk Assessment will be performed prior to flight. Safety 

procedures are addressed in the Avion SOP. The aircraft Operator will perform all of the 

required preflight inspections and document as necessary. 

All operations will include a VO, and the VO may be used to satisfy the Visual Line of Sight 

(VLOS) requirement. The VO and aircraft Operator must maintain positive communication and 

have the ability to monitor Common Traffic Advisory Frequency (CTAF) frequencies to ensure 

manned aircraft avoidance. 

At no time will the Visual Observer perform VO duties for more than one aircraft at a time. 

At no time will the Operator of an Avion UAS manipulate an aircraft from a moving vehicle. 

The UAS shall not be flown at a ground speed exceeding 30 mph. 

All flights will be documented on the Flight Log and all flight time will be accounted for on the 

Flight Log, including the reason for the flight (purpose of the mission).

All flight operations will be conducted at least 500 feet from nonparticipating personnel, 

unless blockades or physical barriers are present, providing a protective layer between 

operations and bystanders. If at any time nonparticipating persons encroach on the 500 foot 

safety zone, flight operations will be aborted immediately. 
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Operations of an Avion UAS may be conducted at distances less than 500 feet from 

unoccupied vessels, vehicles or structures owned by the land owner/controller when the land 

owner/controller grants such permission, and the Operator makes a safety assessment of the 

risk from operations and determines that it does not present an undue hazard to persons or 

property. Personnel participating in flight training, or required for operations during flight are 

permitted within the 500 foot safety zone. These required personnel are to maintain a safe 

distance from both critical flight crew personnel and the UAS to ensure an appropriate level of 

safety at all times. 

At no time will Avion operate a UAS above 400 FT above ground level (AGL). All operations 

will be conducted under Visual Meteorological Conditions (VMC). Avion UAS will not be 

operated less than 500 feet below, or 2000 feet horizontally from a cloud, or if visibility is less

than the identified 3 statute mile requirement. 

UAS flights will not be operated in Class A, B, C, or D airspace but may be operated in class E 

and G airspace, provided the UASs Operator/Observer maintains visual line of sight with the 

UASs and safe separation from actual certificated aircraft in the airspace.

The aircraft documentation required by 14 CFR, § 91.9 and § 91.203 shall be available to the 

Operator at the GCS of the UAS anytime the aircraft is operating. This documentation shall be 

available to the Administrator or any law enforcement official upon 

request. 

UAS Operator shall not begin an operation unless there is enough battery power for the 

aircraft, in a normal flight attitude, to land at the Home Point with at least 25% power 

remaining. 

Aircraft Operator must abort the flight in the event the aircraft strikes an object, or an 

emergency is identified by any of the flight crew personnel. If the UAS loses positive control 

link from the Operator, the aircraft must automatically return to the briefed Home Point. 

All aircraft operations will be conducted in accordance with this exemption, the Avion SOP, 

and any additional guidelines provided by the FAA. 

Avion Solutions will request a Notice to Airman (NOTAM) between 48 and 72 hours prior to 

each mission. 

UAS accidents, incidents or flights that transgress the boundaries of the operational area as 

defined by the applicable certificate of authorization (COA) shall be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the National 

Transportation Safety Board (NTSB) In accordance with the NTSB Web site: www.ntsb.gov. 

UAS Operator shall remain clear of and yield right of way to all manned aircraft. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

UAs will be identified by N-number, with markings as large as practicable.

Avion Solutions shall hold an Air Traffic Organization (ATO) issued COA before operating under 

this exemption request. 

Unless otherwise specified by the Administrator, the PIC, and Operator must comply with all 

applicable parts of 14 C.F.R. including, but not limited to, parts 45, 47, 61, and 91.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Privacy

Respect for civil rights and civil liberties is a core tenet of our democracy. As with all data 

collection methods, UAS must be operated consistent with the U.S. Constitution. The Fourth 

Amendment protects individuals from unreasonable searches and seizures and generally 

requires law enforcement to seek a warrant in circumstances in which a person has a 

reasonable expectation of privacy. Despite the proven effectiveness of UAS technology, 

concerns about privacy threaten to overshadow the benefits it promises to bring to public 

safety.

Avion's proposed operations will create no privacy issues. The UAS will be operating in rural 

and populated areas within the vertical boundaries of the designated property. When 

possible, UAS will utilize Geofencing software to ensure airspace compliance and restrict 

operations in areas that may affect the privacy of adjacent landowners. All operations will be 

conducted with the property owner’s written consent provided on the Avion Solutions UAS 

Operations Release Form; this form is available for reference in the Avion SOP. Avion 

Solutions Inc. will also obtain any permits or authorizations from local authorities, facility 

managers, or event managers when necessary, and the approval of any/all parties 

participating in the aerial data collection/training operation. 

Documentation related to aerial data collection operations will be available to local authorities 

on site and at Avion Headquarters. Mission related data will be kept on file for a minimum of 

one year and will then be destroyed IAW Avion Privacy Policy. All missions will be evaluated to 

ensure that data that is unrelated to the specified use will be minimized.

Avion will not infringe on any individual or landowner privacy rights. If a non-participating 

individual poses a safety risk prior to or during an operation, the mission commander will 

abort the mission and re-evaluate the mission scenario. 

Avion will take steps to protect against unauthorized disclosure of any information or data 

through the use of encrypted video downlink signals, positive control of removable media, and 

proper destruction of data that is not required or relevant to the operation.

Avion personnel will be trained to understand and abide by all relevant federal legal privacy 

standards applicable to the use of UAS, and to seek advice from legal counsel as necessary. 

Avion will make every attempt to avoid use of UAS in a manner that could be considered 

intrusive relative to individuals' privacy and civil liberties.

Prior to using UAS, Avion will assess the relative intrusiveness of the proposed use of UAS, and 

balance it against the particular need. This is both a logical process and an exercise in 

judgment, but the overall principle remains: in deciding whether to use UAS, Avion personnel 

must consider and, if reasonable based on the facts and circumstances of the mission, use the 

least intrusive means to accomplish an operational need.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Avion will only collect, use and disseminate information obtained from UAS for an authorized 

purpose. Data collected by UAS that is retained must be safeguarded in accordance with 

applicable Federal laws, Executive Orders, directives, policies, regulations, standards, and 

guidance. These authorities ensure that Avion personnel with access to such data follow 

practices that are consistent with the protection of privacy and civil liberties. 

Avion will conduct annual privacy reviews of the organization’s use of UAS to ensure 

compliance with existing laws, regulations, and company policy, and to identify potential 

privacy risks. Avion will also, where appropriate, make recommendations to ensure that UAS 

will continue to be used in a manner consistent with the U.S. Constitution and all applicable 

laws, regulations, and policies, including those protecting privacy and civil liberties.
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Aircraft 

DJI Innovations Phantom 2

Figure 1

Aircraft Specifications:

Aircraft

Operating Environment Temperature -10° C to 50°C

Power Consumption 5.6 W

Supported Battery DJI Intelligent Battery

Weight(including the Battery) 1000g

Take-off Weight ≤1300g

Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s

Max Tilt Angle 35°

Max Ascent/Descent Speed Ascent: 6m/s; Descent: 2m/s

Max flight speed 15m/s (Not Recommended)

Wheelbase 350 mm

2.4GHz Remote Controller

Operating Frequency 2.4 GHz ISM

Communication Distance (open Areas) 1000m

Receiver Sensitivity (1%PER) -97dBm

Working Current/Voltage 120 mA@3.7V

Built-in LiPo Battery Working 3.7V, 2000mAh
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Current/Capacity

DJI Intelligent Battery

Type 3S LiPo Battery

Capacity 5200mAh, 11.1V

Charging Environment Range 0°C to 40°C

Discharging Environment Range -20°C to 50°C

Previous FAA approvals for commercial operation of the Phantom 2 aircraft: 

Exemption Nos. 11442, 11388, 11351
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

DJI Innovations Phantom 3

Figure 2

Aircraft Specifications:

Aircraft

Weight (Battery and Propellers included) 1280 g

Max. Ascent Speed 5 m/s

Max. Descent Speed 3m/s

Max. Speed 16 m/s (ATTI mode, no wind)

Max. Flight Altitude 6000 m

Max Flight time Approximately 23 Minutes

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

Gimbal

Controllable Range Pitch: - 90° to +30°

Vison Positioning System

Velocity range < 8 m/s (2 m above ground)

Altitude range 30 cm - 300 cm

Operating range 30 cm - 300 cm

Operating environment Brightly lit (Lux > 15) patterned surfaces

Camera

Sensor Sony EXMOR 1/2.3” Effective Pixels 12.4M 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

(Total Pixels: 12.76M)

Lens FOV 94° 20mm(35mm format equivalent) f/2.8

ISO Range 100-3200(video) 100-1600(photo)

Electronic shutter speed 8s – 1/8000s

Image Max. size 4000 x 3000

Still photography modes Single shot

Burst shooting:3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7 EV bias

Time-lapse

Supported SD card types Micro SD

Max Capacity: 64 GB. 

Class 10 or UHS-1 Rating Required

Video recording modes UHD: 4096 x 2160p 24/25, 3840 x 2160p 24/25/30

FHD: 1920 x 1080p 24/25/30/48/50/60

HD: 1280 x 720p 24/25/30/48/50/60

Max. Bitrate of video 

storage

60 Mbps

Supported file formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Operating temperature 

range

0°C to 40°C

Remote Controller

Operating Frequency 2.4 GHz – 2.483 GHz

Communication Distance (Open Areas) 2000 m (Outdoor and Unobstructed)

Video Output Port USB

Operating Temperature Range 0°C to 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and Smartphone

Transmitter Power(EIRP) FCC: 20 dbm; CE: 16 dbm

Working Voltage 1.2 A @ 7.4 V

Charger

Voltage 17.4 V

Rated Power 100 W

Intelligent Flight Battery (PH3-4480 mAh – 15.2 V)

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Energy 68 Wh

Net Weight 365 g

Operating Temperature -10°C to -40°C

Max. Charging Power 100 W

App / Live View

Mobile App DJI Pilot

EIRP 100 mW

Live View Working Frequency 2.4 GHz ISM

Liew View Quality 720P @ 30fps (Depending on conditions 

and mobile device)

Mobile Device System Requirements iOS 7.1 or later; Android version 4.1.2 or 

later

Supported Mobile Devices iPhone 6 Plus, iPhone 6, iPhone 5S, iPad 

Air2, iPad mini 3, iPad Air, iPad Mini2, 

iPad , Samsung Note 3, Samsung S5, 

Sony Z3 EXPERIA. Note: It is 

recommended that you use a tablet for 

the best experience. 

Previous FAA approvals for commercial operation of the Phantom 3 aircraft: 

Exemption Nos. 11872, 11802, 11801
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

DJI Innovations Inspire

Figure 3

Aircraft Specifications:

Aircraft

Model T600

Weight (Battery include) 2935 g

Hovering Accuracy(P mode) Vertical: 0.5 m

Horizontal: 2.5 m

Max. Angular velocity Pitch: 300°/s

Yaw: 150°/s

Max. Tilt Angle 35°

Max. Ascent Speed 5 m/s

Max. Descent Speed 4 m/s

Max. Speed 22 m/s (ATTI mode, no wind)

Max. Flight Altitude 4500 m

Max. Wind Speed Resistance 10 m/s

Max Flight time Approximately 18 Minutes

Motor Model DJI 3510

Propeller Model DJI 1345

Indoor hovering Enabled by Default

Operating Temperature 

Range

-10°C to 40°C

Diagonal Distance 559 to 581 mm

Dimensions 438 x 451 x 301 mm
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Gimbal

Model ZENMUSE X3

Output Power (With Camera) Static: 9 W; In Motion: 11 W

Operating Current Station: 750 mA; Motion: 900 mA

Angular Vibration range ± 0.03°

Mounting Detachable

Controllable Range Pitch: -90° to +30°

Pan: ± 320°

Mechanical Range Pitch: -125° to +45°

Pan: ± 330°

Max. Controllable Speed Pitch: 120°/s

Pan: 180°/s

Camera

Name X3

Model FC350

Total Pixels 12.76M

Effective Pixels 12.4M

Image Max. Size 4000 x 3000

ISO Range 100-3200(video) 100-1600(photo)

FOV (Field of View) 94°

CMOS Sony EXMOR 1/2.3”

Lens 20mm (35mm format equivalent) f/2.8 focus at ∞

9 elements in 9 groups

Anti-distortion

Still photography modes Single shot

Burst shooting:3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 Bracketed 

Frames at 0.7 EV bias

Time-lapse

Video recording modes UHD (4K): 4096 x 2160p 24/25, 3840 x 2160p 

24/25/30

FHD: 1920 x 1080p 24/25/30/48/50/60

HD: 1280 x 720p 24/25/30/48/50/60

Max. Bitrate of video storage 60 Mbps

Supported file formats FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD card types Micro SD

Max Capacity: 64 GB. 

Class 10 or UHS-1 Rating Required
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Operating temperature 

range

0°C to 40°C

Remote Controller

Model C1

Operating Frequency 5.725 ≈ 5.825 GHz: 2.400 ≈ 2.483 GHz

Transmitting Distance 2 km (Outdoor and Unobstructed)

EIRP 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port USB

Power Supply Built-in Battery

Charging DJI Charger

Dual User Capability Host-and-Slave Connection

Mobile Device Holder Tablets and Smartphone

Operating Temperature 

Range

0°C to 40°C

Storage Temperature Range Less than 3 months: -20° to 45°C

More than 3 months: 22° to 28°C

Charging Temperature Range 0 – 40°C

Battery 6000 mAh LiPo 2S

Charger

Model A14 – 100P1A

Voltage 26.3 V

Rated Power 100 W

Battery (Standard)

Name Intelligent Flight Battery

Model TB47

Capacity 4500 mAh

Voltage 22.2 V

Battery Type LiPo 6S High Voltage Battery

Energy 99.9 Wh

Net Weight 570 g

Operating Temperature -10°C to 40°C

Storage Temperature Range Less than 3 months: -20° to 45°C

More than 3 months: 22° to 28°C

Charging Temperature Range 0 – 40°C

Max. Charging Power 180 W

Battery (Optional)

Name Intelligent Flight Battery
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Model TB48

Capacity 5700 mAh

Voltage 22.8 V

Battery Type LiPo 6S High Voltage Battery

Energy 129.96 Wh

Net Weight 670 g

Operating Temperature -10°C to 40°C

Storage Temperature Range Less than 3 months: -20° to 45°C

More than 3 months: 22° to 28°C

Charging Temperature Range 0 – 40°C

Max. Charging Power 180 W

Vison Positioning System

Velocity range Below 8 m/s (2 m above ground)

Altitude range 5 – 500 cm

Operating environment Brightly lit (Lux > 15) patterned surfaces

Operating range 0 – 250 cm

DJI Pilot App

Mobile Device System 

Requirements

iOS 7.1 or later; Android version 4.1.2 or later

Supported Mobile Devices iPhone 6 Plus, iPhone 6, iPhone 5S, iPad Air2, iPad 

mini 3, iPad Air, iPad Mini2, iPad , Samsung Note 3, 

Samsung S5, Sony Z3 EXPERIA. Note: It is 

recommended that you use a tablet for the best 

experience. 

Previous FAA approvals for commercial operation of the Inspire 1 aircraft: 

Exemption Nos. 11416, 11384, 11426
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

DJI Innovations Spreading Wings S1000

Figure 4

Aircraft Specifications:

Frame

Diagonal Wheelbase 1045 mm

Frame Arm Length 386 mm

Frame Arm Weight

(with motor, ESC, Propeller)

325 g

Center Frame Diameter 337 mm

Center Frame Weight

(With Landing Gear 

Mounting Base, Servos)

1520 g

Landing Gear Size 460 mm (Length) x 511 mm (width) x 305 mm 

(Height)

Motor

Stator Size 41 x 14 mm

KV 400 rpm/V

Max Power 500 W

Weight(with cooling fans) 158 g

ESC

Working Current 40A

Working Voltage 6S LiPo

Signal Frequency 30 Hz ≈ 450 Hz
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Drive PWM Frequency 8 KHz

Weight 13 g

Foldable Propeller (1552/1552R)

Material High Strength Performance Engineered Plastics

Size 15 x 5.2 Inch

Weight 13 g

Flight Parameters

Takeoff Weight 6.0 Kg ≈ 11.0 Kg

Total Weight 4.4 Kg

Power Battery LiPo (6S, 1000mAh ≈ 20000 mAh, 15C(Min))

Max. Power Consumption 4000 W

Hovering Time 15 min (@15000mAh & 9.5 Kg Takeoff Weight)

Working Environment 

Temperature

-10°C to 40°C

Previous FAA approvals for commercial operation of the Spreading Wings S1000 aircraft: 

Exemption Nos. 11442, 11439, 11416
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Summary That Can Be Published In the Federal Register

Department of Transportation 

Federal Aviation Administration 

Avion: Avion Solutions Inc. 

Avion Solutions Inc. seeks exemption from the requirements of 14 CFR Title 14 – Aeronautics 

and Space: Subpart h, § 45.23 (b), § 45.27, § 45.29, § 61.101 (e) (4) and (5), § 61.113 (a) and 

(b)§ 61.315 (a) and (c), § 91.7 (a), § 91.9 (b) (2) and (c), § 91.103, § 91.109 , § 91.119, § 91.121 

(a) (1), § 91.151 (a) (1), § 91.203, § 91.405 (a), § 91.407 (a) (1), § 91.409 (a) (1) and (2), § 

91.417 (a) (1) and (2).

Description of relief sought; 

Avion Solutions Inc. seeks an exemption for commercial operation of small unmanned aircraft 

pursuant to 14 CFR §11.61 and Section 333 of the FAA Modernization and Reform Act of 2012. 

Approval of said exemption will permit safe operation of the DJI Innovations Phantom 2, 

Phantom 3, Inspire 1, and Spreading Wings S1000. These aircraft will be operated 

commercially for the purpose of conducting of UAS flight training, research and development, 

and aerial data collection. By granting this petition, the FAA will provide Avion Solutions with 

a means to provide safe, effective and efficient aerial data collection to consumers. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Conclusion

As discussed in detail above, Avion Solutions Inc. will operate the proposed UAS safely in the 

NAS, without creating a hazard to other users of the NAS, the public, or otherwise pose a 

threat to national security. Avion Solutions will comply with all federal aviation regulations 

that are applicable to its UAS operations. Additional regulatory requirements imposed by the 

FAA through the approval of this exemption will be adhered to. All other mandates, state and 

local will be observed to ensure maximum safety during any data collection or training events. 
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

Appendices

A. Avion Solutions Inc. Unmanned Aircraft Systems (UAS) Standard 

Operating Procedures

Avion Solutions Inc. Unmanned Aircraft 

Systems (UAS) Standard Operating 

Procedures

Avion UAS Standard 

Operating Procedures SOP_07_08_2015.pdf
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

B. DJI Phantom 2 Documentation

DJI Phantom 2 User Manual

Phantom 2 

Supporting Documentation.pdf

DJI Phantom 2 Quick Start Guide

Zenmuse H4-3D Gimbal Quick Start Guide

DJI Smart Flight Battery Safety Guidelines

DJI Phantom 2 FPV Hub Kit Instructions v1.0

DJI Naza-M(v2) Quick Start Guide v1.22

DJI 2.4G Bluetooth Datalink and iPad Ground Station User 

Guide v1.12

DJI New Pilot Experience 2015

Avion Solutions Phantom 2 Checklist
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

C. DJI Phantom 3 Documentation

DJI Phantom 3 Professional User Manual v1.0

1.0 

Phantom_3_Professional_User_Manual_v1.0_en.p

DJI Phantom 3 Safety Guidelines and Disclaimer

2.0 

Safety_Guidelines_Disclaimer_en.pdf

DJI Phantom 3 Professional Quick Start Guide

3.0 

Phantom_3_Professional_Quick_Start_Guide_en.p

DJI Phantom 3 Intelligent Flight Battery Safety Guidelines

4.0 

Intelligent_Flight_Battery_Safety_Guidelines_en.p

Avion Solutions Phantom 3 Checklist

5.0 Avion Solutions 

Phantom 3 Checklist.pdf
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

D. DJI Inspire 1 Documentation

DJI Inspire 1 User Manual v1.2

1.0 

Inspire_1_User_Manual_v1.2_en.pdf

DJI Inspire 1 Quick Start Guide 

2.0 

Inspire_1_Quick_Start_Guide_en.pdf

DJI Intelligent Flight Battery Safety Guidelines

3.0 

Intelligent_Flight_Battery_Safety_Guidelines_en.p

DJI Inspire 1 Safety Guidelines

4.0 

Inspire_1_Safety_Guidelines_en.pdf

DJI Inspire 1 Maintenance Manual v1.0

5.0 

Inspire_1_Maintenance_ManualV1.0_en.pdf

DJI Disclaimer & Warning

6.0 

Inspire_1_Disclaimer_and_Warning_en.pdf

DJI 1345s Quick Release Propellers for the Inspire 1 Quick Start 

Guide

7.0 

1345s_Quick_Release_Propellers_Quick_Start_Gui

Avion Solutions Inspire 1 Checklist

8.0 Avion Solutions 

Inspire 1 Checklist.pdf
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4905 Research Drive NW, Huntsville, AL 35805 ● 256.721.7006 ● www.avionsolutions.com

E. DJI Spreading Wings S1000 Documentation

DJI Spreading Wings S1000+ User Manual v1.2

1.0 

S1000_Plus_User_Manual_v1.2_en.pdf

Avion Solutions S1000 Checklist

Avion Solution S1000 

Checklist.pdf
4905 Research Drive NW

Huntsville, AL 35805

(256) 721-7006