UAV Aerial Surveys 

US Department of Transportation Exemption Request Pursuant to Section 

333 of the FAA 

Reform Act and Part 11 of the Federal Aviation 

September 29th 2015 

Glenn G Smith Jr 

134 Boarland Road 

Ardmore Oklahoma 73401 

DBA: UAV Aerial Surveys 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

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

the Federal Aviation Regulations from: 

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 

14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 

14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) 

(1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

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

Act") and 14 CFR Part 11, Glenn G Smith Jr, operator of Unmanned Aircraft Systems 

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

("FARs") to allow commercial operation of designated UAS, provided such operations 

are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. 

Thank you in advance for your consideration 
Commercial operation of an UAS, as described herein, which are equipped 

with camera(s) and sensors, would provide professional services in the 

following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, 

public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/commercial structures under contract 

with the owners or local government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government has requested it by contract or donation. 

6. Training to persons individually or belonging to both private and/or public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS. 

As described fully below, the requested exemption would permit the operation of 

designated UAS as set forth in this document under controlled conditions in the NAS 

that would be (a) limited (b) controlled (c) predetermined and (d) safe. Approval of this 

exemption would increase public awareness of UAS operations and enhance safety to 

aid in fulfilling the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to "establish requirements for the safe operation of such aircraft systems 

in the national airspace system." 

The name and address of the applicant is: 

Glenn G Smith Jr 

Ph: 405-850-8984 

Email: ggsmithjr@gmail.com 

Address: 134 Boarland Road 

Ardmore, Oklahoma 73401 

DBA: UAV Aerial Surveys 
Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Glenn G Smith Jr will operate one or more of the following model UAS: 

3D Robotics Iris 

3D Robotics X8 

Walkera QR X350 
3 D Robotics Iris 

• 16-22 minutes flight time* 

• Payload capacity 400 g (.8 lbs) 

• Integrated LEDs on all arms for trouble-free directional awareness 

• Remote controller with on-screen telemetry for instant data as you fly 

• Follow Me - 3DR’s 3rd Person View (3PV) Follow Me technology 

• IRIS+ can be easily setup to follow any GPS-enabled Android device with OTG compatibility. 

• Automatic Mission Planning - Using the free DroidPlanner app, IRIS+ users can plan flights 

by simply drawing a flight plan on any Android tablet or phone. This allows for hands free 

flight control, your drone will go where you tell it to go, with virtually unlimited waypoints - 

even keep IRIS+ pointing to the same location via a Region of Interest (ROI) waypoint 

throughout the entire flight. 

• Flight Protection - The IRIS+ can land itself automatically, or return to a home point if it travels 

out of range or runs out of battery. 

Telemetry radio frequency: Telemetry radios allow your ground station computer to communicate 

with your aircraft wirelessly, providing unparalleled ease of use for viewing real-time flight data, 

changing missions on the fly, tuning, and using an Android tablet as a ground station. Select 915 

Mhz for the U.S. 
3D Robotics X8 

• Battery: 4S 14.8V 10,000 mAh 10C 

• Battery Dimensions: 6.6 in x 2.6 in x 1.4 in (16.7 cm x 6.5 cm x 3.5 cm) 

• Battery Weight: 803 g 

• Autopilot hardware: Pixhawk v2.4.5 

• Autopilot firmware: ArduCopter 3.2 

• GPS: 3DR u-blox GPS with Compass (LEA-6H module, 5 Hz update) 

• Ground Station Radio: 3DR Radio v2 (915 MHz or 433 MHz) 

• Motors: SunnySky V2216-12 KV800 II (The images above show conical nuts; 

X8+ ships with hex nuts.) 

• Controller: FlySky FS-TH9X with FrSky telemetry module 

• Frame Type: X 

• Propellers: APC Propeller 11x4.7 SF (4), APC Propeller 11x4.7 SFP (4) 

• Vehicle Dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 20 cm) 

• Payload Capacity: 800 g (1.7 lbs). Additional payload possible up to over 1kg 

with reduced flight time. 

• Vehicle Weight with Battery: 2.56 kg (5.6 lbs) 

• Maximum Estimated Flight Time: 15 min 
Walkera QR X350 
Gimbal 

Controllable Range-Pitch -90° tp +30° 

Stabilization-3-axis (pitch, roll, yaw) 

Vision Positioning 

Max Velocity-Less than 8 m/s (when 2 m above ground) 

Altitude Range-30 cm-300 em 

Operating Range-30 cm-300 em 

Operating Environment-Surface with clear pattern and adequate lighting (Lux> 15) 

Remote Controller 

Operating Frequency-2.400 GHz-2.483 GHz 

Max Distance-2000m (outdoors and unobstructed) 

Video Output Port-USB 

Operating Temperature-0°C- 40°C 

Battery-6000 mAh LiPo 2S 

Mobile Device Holder-For tablet or phone 

Receiver Sensitivity (1%PI:R)--101 dBm ±2 dBm 

Transmitter Power (EIRP) 

FCC: 20 dBm 

CE: 16 dBm 

Working Voltage-1.2 A @7.4 V 

Battery Charger 

Voltage-17.4 V 

Intelligent Flight Battery 

Capacity-4480 mAh 

Voltage-15.2 V 

Battery Type-LiPo 45 

Energy-68 Wh 

Net Weight-365 g 

Max Flight Time-Approximately 23 minutes 

Operating Temperature--10°( to 40°( 

Max Charging Power-100 W 

Given the small size of the UAS in scope and the controlled environment provided, the 

proposed operations will adhere to the Reform Act's safety requirements. The approval 

of this application presents no national security issues. Regarding the level of safety 

surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the 

requested exemption is in the public interest. Accordingly, the applicant graciously 

requests that the FAA grant the requested exemption. 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using 

conventional aircraft. These limitations and conditions to which the applicant agrees to 

adhere to when conducting commercial operations under the FAA issued exemption as 

set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with 

battery and camera. 

2. The UAS, depending on the model in operation, will have a maximum operating 

speed of no more than 50mph. 

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or 

Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model in 

operation, but will not exceed 30 minutes. Flights will be terminated at 25% battery 

power reserve or 30 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual 

Observer (VO), and may include a third, but separate, Camera Operator (CO). 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged 

a minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day's flights consisting of all the days' 

production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a Smile radius of the 

geographic center/ Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/ Airport. 
13. The operator will file FAA Form 77111, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) 

no more than 72 hours but no less than 48 hours from planned operation. 

14. The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 100 

feet of the flight operation, and the radius may be reduced to 30 feet based upon an 

equivalent level of safety determination, as U.S. Department of Transportation required 

under the FOM. With the advanced permission of the FSDO, operations at closer 

range may be approved. 

15. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio at all times. 

17. Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies as appropriate to flight operations. 

18. If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a predetermined location within a designated 

location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with an 

automated "Return Home and Land" function. 

20. The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 

FAR §91.203 (a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by the Applicant, 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. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully 
loaded, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application 

of these same criteria demonstrates that there is no credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external 

load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 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. Even though the UAS will have no 

airworthiness certificate, an exemption may be needed as the UAS will have no 

entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

placed. Given the size of the UAS, two inch 

lettering will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with §45.29 (f). US Department of Transportation February 20, 2015 The 

equivalent level of safety will be provided by having the UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAS will 

see the identification of the UAS as "Experimental." 

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: 

Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private 

pilot certificate may act as a pilot in command of an aircraft that is carrying passengers 

or property for compensation or hire. The proposed UAS operations may achieve an 

equivalent level of safety as achieved by current regulations because the applicant's 

UAS do not carry any pilots or passengers nor property. The risks attendant to the 

operation of UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR 61. The PIC of the UAS will be, or be under the direct 

supervision of, a FAA Certificated Private Pilot with current Third Class or higher 

medical certificate. It is believed that the operation and limitations set forth in the FOM 

will equate to the safe operation of the UAS. 
14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance and use of safety checklists 

prior to each flight, an equivalent level of safety will be provided. 

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

Section 91.9 (b) {2) provides: No person may operate a U.S.registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 

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. The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where 

the pilot flying the UAS will have immediate access to it. 

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

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided 

for the aircraft an exemption will be needed. The PIC will take all actions as stated in the 

FOM in Section 4 under Normal Procedures including but not limited to reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 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 

functioning dual controls. UAS and remotely piloted aircraft, by their design do not have 

fully functional dual controls. Flight control is accomplished through the use of a control 

box that communicates with the aircraft via radio communications. 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 equivalent level of safety 

is provided by the fact that neither a pilot nor passengers will be carried in the aircraft 

and by the size and speed of the aircraft. 
14 C.F.R. §91.119: Minimum Safe Altitudes. 

 Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 

200 above an elevated platform from which filming is planned, an exemption may 

be needed to allow such operations. As set forth herein, the UAS will never operate at 

higher than 400 AGL with the exception that in circumstances where the UAS is used to 

survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not 

be operated more than 200 feet above the highest point on the structure. It will however 

be operated in a restricted area with security perimeter, where buildings and people will 

not be exposed to operations without their pre obtained consent. The 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. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner 

and participants in the filming activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum ssibs proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented 

with conventional aircraft operating at or below 500 AGL. In addition, the low altitude 

operations of the UAS will ensure separation between these UAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

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

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set " ... to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an U.S. exemption may be 

needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

safety check list and live flight data monitoring, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight. 

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

Section 91.151 (a) prohibits an individual from beginning "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." The applicant believes that an exemption from 14 
CFR §91.151(a) falls within the scope of prior exemptions. Operating the UAS in a 

tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed does not engender the type of risks that 

Section 91.151(a) was intended to alleviate given the size and speed of the small 

UAS. The applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power- whichever happens first. This 

restriction would be more than adequate to return the UAS to its planned landing zone 

from anywhere in its limited operating area. 

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

The regulation provides in pertinent part: (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. The UAS fully loaded weighs well under the 

proposed 55 lb limit and is operated without an on board pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on the 

UAS. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the UAS will have immediate access to them, 

to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections. 

These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter ... ," and others shall inspect or maintain the aircraft 

in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft 

with an airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because the UAS is 

very limited in size and will carry a small payload and operate only in restricted areas for 

a limited period of time. If mechanical issues arise the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep 

a log of any maintenance performed. Moreover, the operator is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with the UAS 

Manufacturer's User Manual. As provided in the FOM, the operator will ensure that the 

UAS is in working order prior to initiating flight and perform required maintenance 

needed. 
Additional Information. 

The applicant, Glenn G Smith Jr, believes this exemption request and associated 

safety considerations adequately satisfy criteria provided in Section 333 of the Reform 

Act of 2012, providing sufficient justification for the granting of commercial operations of 

the applicant's UAS. 

The applicant, Glenn G Smith Jr requests your respective approval of this Section 

333 exemption petition request. 

Thank you for your attention in this matter. Please notify Glenn G Smith Jr of your 

actions, and or approvals. 

Thank You for your interest in this request. 

Sincerely, 

Glenn G Smith Jr 

134 Boarland Road 

Ardmore, Oklahoma 73401 

ggsmithjr@gmail.com 

405-850-8984 

DBA: UAV Aerial Surveys