Long Range RC

19733 State Route 278 S.W.

Nelsonville, Ohio 45764

740-270-2610

Jason@longrangerc.com

www.longrangerc.com

August 7, 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 C.F.R. 

Part 11

Dear Sir or Madam,

Long Range RC, (LRRC) 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. LRRC seeks and 

is asking for exemption in order to commercially operate small unmanned aerial vehicles (UAVs) / small 

unmanned aerial systems (UAS) weighing less than 55lbs for the purpose of: 

. Search and rescue

. Aerial photography

. Aerial videography

. Inspections

All of Long Range RC’s Pilots in Command (PICs) will have attended a sport pilot course or higher and all 

carry a Third Class Medical Certificate or possess a valid driver’s license. All of LRRC’s PIC’s and Visual 

Observers (VO’s) undergo rigorous training and continued education for the specific aircraft for which 

they will pilot/ operate/ or observe. Following LRRC policy, all PIC’s must maintain a detailed flight log 

and that flight log information will be on file with LRRC. All Information recorded by the PIC will be filed 

with Senior Management weekly for approval filing. Any incidents out of normal operation will also be 

immediately filed before the end of the day on which the incident took place.

The name and address of this petitioner is:

Long Range RC

Attn: Jason A. Gadrim

19733 State Route 278 S.W.

Nelsonville, Ohio 45764
 To preserve the safety of all manned aircraft operations, the NAS, and property, LRRC will maintain 

the following limitations and conditions during all flight operations:

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

pounds.

2. All UAVs operated by LRRC under the requested Section 333 exemption will have an on-board 

GPS positioning system, preprogrammed with an altitude ceiling of 385 feet and a maximum 

lateral distance of 2,600 feet and these parameters will be programed into each units flight 

computer prior to flight.

3. All flights will be conducted within visual line of sight by the pilot in command and the VO.

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 into each aircraft, allowing first for a visual 

warning to the PIC and VO, and a second for the autonomous landing of the aircraft.

b. If the aircraft is autonomously traveling home at its’ return home altitude and a hazard 

appears the PIC can flip a switch and avoid such hazard and land the aircraft without 

incident.

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; LRRC has a strict “No Night Flight” policy for all aircraft.

LRRC 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 Flights 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. LRRC 

requests exemption from this Subpart to operate small UAVs (less than 55 pounds) 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, LRRC 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 a cockpit of cabin, LRRC requests that in order 

to identify the aircraft as an experimental type, the word “EXPERIMENTAL” will be displayed in 1⁄2 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

LRRC requests exemption from 14 C.F.R. / 61.113(a) and (b) to allow LRRC to commercially operate small 

UAVs with operators holding a private pilot certificate. Section 61.113(a) and (b) limit private pilots to 

non-commercial operations. However, provided recent documentation, it has been determined that 

private pilot and commercial pilot certificates 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 small UAV. Applying manned commercial pilot certification requirements does not 

significantly add to the safety of UAS operations. LRRC’s operating procedures will ensure our Pilots 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

LRRC request exemption from the minimum safe altitude requirements of 14 C.F.R. / 91.119 that states 

the minimum safe altitudes under which aircraft may operate:

1. 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.

2. 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 385 feet. Additionally the 

small UAVs will maintain a maximum lateral distance of 150 feet from inhabited structures, buildings 

and vehicles, and will remain within visual line of site from 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 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.”

LRRC requests exemption from this section because our small UAVs do not have barometric altimeters 

on-board, but rather a GPS-based altitude readout system. All aircraft will be programmed to remain 

below 385 feet regardless of the input of the PIC, thus ensuring operation at safe altitudes.

14 C.F.R. / 91.203(a)(1) and (2): Civil aircraft: Certification Required

Under the requested exemption, LRRC 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 

LRRC would not be able to display the airworthiness certificate in accordance with 14 C.F.R. / 

91.203(a)(1) and (2).

14 C.F.R. / 91.405; 91.407; 91.409; 91.417: Maintenance / Operation / Inspections / Records

These regulations specify maintenance and inspections 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”).

LRRC 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 manufacturers Guidelines and equipment manuals and all maintenance and 

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

The PIC will use a check list prior to each flight session and range test the unit as per the control units 

owner’s manual to ensure safe link is established from the control unit to the UAV. If the UAS fails the 

Range Test the unit will be taken out of service and checked. Any repairs and observation as to the link 

failure will be logged in the PICs flight logged.

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

By granting this exemption request, LRRC will be able to safely commercially operate our small UAVs in 

the NAS allowing for aerial photography, aerial videography, inspections, and most importantly help to 

possible help find a lost person looking for help. The safe and utilization of this new technology allows us 

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

and human resources to be used to further help others.

LRRC feels these exemptions play a huge part of the early adoption of small UAS into the NAS. It is the 

review processes like these that allow those of us operating responsibly and safely to use this 

technology to protect people, protect property, and help to improve countless industries and lives.