APRIL 15, 2015

US Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

RE: 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,

Unmanned Vehicle Technologies, LLC (UVT) requests exemption from several provisions of the Federal Aviation Regulations 

(FAR) in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. UVT seeks exemption in order to 

commercially operate small unmanned aerial vehicles (UAVs)/ small unmanned aerial systems (UAS) weighing less than 55lbs 

for the purposes of:

 Aerial photography

 Aerial videography

 Inspection

All of UVT’s Pilots in Command (PICs) hold active sport pilot certifications or higher and all either carry a Third Class Medical 

Certificate or possess a valid driver’s license. All of UVT’s PICs and Visual Observers (VOs) undergo rigorous training and 

continued education for the specific aircraft which they pilot/operate/observe. Following UVT policy, all PICs and VOs must 

maintain detailed flight logs, which are submitted to UVT Senior Management monthly for review, approval and filing.

The name and address of the petitioner is:

Unmanned Vehicle Technologies, LLC

Attn: Christopher D. Fink / President

151 N Maitland Avenue

No. 948595

Maitland, FL 32751

(407) 218-6355

Unmanned Vehicle Technologies, LLC

151 N Maitland Avenue

No. 948595

Maitland, FL 32751

407.218.6355

Info@uvt.email

www.uvt.us
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Description of Flight Operations

To preserve the safety of manned aircraft operations, the NAS, and property, UVT will maintain the following limitations and 

conditions during all operations:

1. All UAVs operated by UVT under the requested Section 333 exemption will weigh less than 55 pounds.

a. In most cases, the UAVs will weigh less than four (4) pounds.

2. All UAVs operated by UVT under the requested Section 333 exemption will have on-board GPS systems, 

preprogrammed with an altitude ceiling of 400 feet; additionally, a maximum lateral distance of 500 feet will be 

programmed into each aircraft’s flight controller.

3. All flights will be conducted within visual line of sight by the Pilot in Command and Visual Observer.

4. All flights will be conducted with a limitation on the minimum voltage allowed in the primary flight battery.

a. Preprogrammed voltage limitations are built-in to each aircraft, allowing first for a visual warning to the PIC 

and VO, and second for the autonomous descent and landing of the aircraft.

5. At all times during the flight, the active PIC and VO will be able to communicate verbally.

6. All flights will be conducted in visual flight rules (VFR) conditions.

7. All flights will be conducted in daylight; UVT has a strict “No Night Flight” policy for all aircraft.

UVT requests the following exemptions under Section 333:

Part 21 Subpart H Airworthiness certification

14 C.F.R. § 45.23(b) Markings

14 C.F.R. § 61.113(a) and (b) Private pilot privileges

14 C.F.R. § 61.133(a) Commercial pilot privileges

14 C.F.R. § 91.7(a) and (b) Civil aircraft airworthiness

14 C.F.R. § 91.119 Minimum safe altitudes

14 C.F.R. § 91.121 Altimeter settings

14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR conditions

14 C.F.R. § 91.203(a)(1) and(2) Civil aircraft certifications

14 C.F.R. § 91.405; 407; 409; 417 Maintenance inspections

Part 21 Subpart H: Airworthiness certification

Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness certificates. UVT requests exemption 

from this subpart to operate small UAVs (less than 55lbs) without the requirement for an airworthiness certificate. Based on 

the proposed small UAVs being limited in size, weight, speed, operating capabilities, and operating within visual line of sight, 

UVT believes that an airworthiness certificate is not necessary to ensure an equivalent level of safety to manned aircraft 

operations.

14 C.F.R. § 45.23(b): Display of marks; general

As the proposed small UAVs do not have any entrances to the cockpit or cabin, UVT requests that in order to identify the 

aircraft as an experimental type, the word “EXPERIMENTAL” will be displayed in two (2) inch lettering on the fuselage of each 

aircraft.

14 C.F.R. § 61.113(a) and (b): Private pilot privileges and limitations: Pilot in command

UVT requests exemption from 14 C.F.R. § 61.113(a) and (b) to allow UVT to commercially operate small UAVs with operators 

holding private pilot certificates. Sections 61.113(a) and (b) limit private pilots to non-commercial operations. However, 

provided in recent documentation, it has been determined that private pilot and commercial pilot certifications meet the same 

basic knowledge of airspace through ground school and not flight training (See Regulatory Docket No. FAA-2014-0352, pages 

16-17). A commercial pilot’s certification ensures that a pilot is able to safely commercially operate a manned aircraft, not a 
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small UAV. Applying manned commercial pilot certification requirements does not significantly add to the safety of UAS 

operations. UVT’s operating procedures will ensure our Pilots in Command and VOs are trained to conduct operations with an 

equivalent level of safety to the training advantages obtained by a commercial pilot certification for manned aircraft.

14 C.F.R. § 91.7(a) and (b): 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 certificates issued for small UAVs, should this exemption be granted, no FAA regulatory standard will exist for 

airworthiness. Given the small size of our aircraft (weighing less than 55 pounds) and the aforementioned description of flight 

operations, an equivalent level of safety will be provided.

14 C.F.R. § 91.119: Minimum safe altitudes

UVT requests exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119 that prescribes the minimum safe 

altitudes under which aircraft may operate:

 Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 

feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

 Over other than congested areas at an altitude of 500 feet above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or 

structure.

To provide the intended operations, our small UAVs will be operated below 400 feet. Additionally, the small UAVs will maintain 

a maximum lateral distance of 500 feet from inhabited structures, buildings and vehicles, and will remain within visual line of

sight of the PIC and VO at all times.

14 C.F.R. § 91.121: Altimeter settings

This regulation requires that each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to “the current reported altimeter settings of a station along the route within 100 

nautical miles of the aircraft.”

UVT requests exemption from this section because our small UAVs do not have barometric altimeters on-board, but rather GPSbased altitude readouts. All aircraft will be programmed to remain below 400 feet regardless of the input of the PIC, thus 

ensuring operation at safe altitudes.

14 C.F.R. § 91.151(a): Fuel requirements for flight in VFR conditions

UVT requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states:

 No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather 

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

o During the day, to fly after that for at least 25 minutes;

o At night, to fly after that for at least 45 minutes.

The batteries powering our small UAVs provide approximately 10-18 minutes of flight time. All flight operations will be limited 

to a minimum voltage to ensure appropriate reserve battery to maintain an equivalent level of safety at all times. Should the 

PIC fail to land the aircraft prior to the minimum voltage warning, the aircraft will autonomously return to its home point and 

land.

14 C.F.R. § 91.203(a)(1) and (2): Civil aircraft: Certifications required

Under the requested exemption, UVT would not be operating aircraft with an airworthiness certificate as requested under the 

exemption for Part 21 Subpart H. The exemption for this section is required as UVT would not be able to display the 

airworthiness certificate in accordance with 14 C.F.R. § 91.203(a)(1) and (2).
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14 C.F.R. § 91.405; 91.407; 91.409; 91.417: Maintenance/Operations/Inspections/Records

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. 14 C.F.R. 91.405(a) (stating 

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

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

UVT requests exemption from these sections as these sections require the aircraft be inspected in accordance with Part 43 and 

is needed as these sections apply only to aircraft with an airworthiness certificate. An equivalent level of safety will be achieved 

by the PIC following standard maintenance procedures, per the aircraft manufacturer’s User Manual and all maintenance and 

repairs are logged for each aircraft, with those logs being submitted to UVT Senior Management following each maintenance 

and repair. Additionally, the PIC will ensure the aircraft is in working order prior to each flight.

Why is this exemption request in the public’s best interest?

By granting this exemption request, UVT will be able to safely commercially operate our small UAVs in the NAS allowing for 

aerial photography, aerial videography and perhaps most importantly, inspection. The safe and responsible utilization of this 

technology allows us to minimize the risk placed on the human life, not only potentially saving a life, but freeing up valuable 

human resources to be used to further innovate and create.

UVT feels these exemptions play an integral part of the early adoption of small UAS into the NAS. It is review processes like 

these that allow those of us operating responsibly and safely to use this technology to protect our people, protect our property 

and help improve countless industries and lives, worldwide.