June 30, 2015

Exemption No. 11964

Regulatory Docket No. FAA–2015–0945

Mr. Brandon Blackburn

Cheif Executive Officer

Mr. Brian Behling

Director, Business Development

Waypoint Global Strategies, Inc.

146 Orange Place

Maitland, FL 32751

Dear Messrs. Blackburn and Behling:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 4, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Waypoint Global Strategies, Inc. (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial surveying, inspection, patrolling, monitoring, and public entity support.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the SenseFly eBee, C-Atral Bramor RTK, and DJI 

Inspire 1.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Waypoint Global Strategies, Inc. is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

Conditions and Limitations

In this grant of exemption, Waypoint Global Strategies, Inc. is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the the SenseFly eBee, 

C-Atral Bramor RTK, and DJI Inspire 1 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 
4

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
6

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 
7

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
U.S. Department of Transportation 

April 3, 2015

Page 1

ALEX MIROT PRESIDENT

386.866.0471 Alex.Mirot@UnmannedSafetyInstitute.Org

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

April 3, 2015

Re: Petition of WAYPOINT GLOBAL STRATEGIES, INC for Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Sir and/or Madam: 

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

Act") and 14 C.F.R. Part 11, WAYPOINT GLOBAL STRATEGIES, INC 

(“WAYPOINT”), hereby applies for an exemption from Federal Aviation Regulations ("F 

ARs") identified below, to allow commercial operations of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "sUAS"). 

This exemption is made based on the information in this petition, as well as the 

accompanying UAS Operations Manual (''Operations Manual") and Emergency 

Response Plan. Petitioner submits the Operations Manual and Emergency Response 

Plan, and as Confidential documents under 14 C.F.R. § 11.35(b), as the entire 

Operations Manual and Emergency Response Plan contain confidential commercial and 

proprietary information that the Petitioner has not and will not share with others. The 

documents contain operating conditions and procedures that are not available to the 

public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 

552 et seq., and any other requirements established by the FAA pursuant to Section 

333 of the FAA Reform Act. 

For your convenience, the petition is organized as follows: 

I. Description of Petitioner 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

a. 14 C.F.R. Part 21, Subpart H-Airworthiness Certificates and 14 C.F.R. 

§ 91.203 
U.S. Department of Transportation 

April 3, 2015

Page 2

b. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and 

Limitations: Pilot in Command. Commercial Pilot Privileges and 

Limitations.

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

Requirements 

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

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

Registration 

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness F. 14 C.F.R. § 91.103: 

Preflight Action 

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

g. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

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

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

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

Maintenance Inspections 

VI. Advanced UAS Flight Safety Training 

VII. Drug and Alcohol Program 

VIII. Public Interest

IX. Privacy 

X. Federal Registry Summary 

XI. Conclusion 

I. DESCRIPTION OF PETITIONER 

WAYPOINT is a strategy and technology consulting firm providing remote sensing, ondemand UAS flight service and advanced analytics solutions to customers in the civil 

and commercial markets worldwide. WAYPOINT provides digital satellite services and 

contract flight operations with sUAS to customers around the world. WAYPOINT is an 

affiliate of the Unmanned Safety Institute, a professional organization dedicated to UAS 

flight safety. WAYPOINT has been recognized by some of the world’s leading 

insurance brokerage firms and underwriting companies as a leader in UAS operations, 

risk mitigation, and flight safety.

WAYPOINT is the sole provider of UAS flight safety training to Global Aerospace’s 

industry-leading SM4 Safety Program and the exclusive provider of flight safety 

education to individuals and proponent organizations seeking to safely operate sUAS

around the world. Global Aerospace, a leading provider of insurance and risk 

management solutions for the aviation and aerospace industries, recognizes 

WAYPOINT as a highly competent proponent organization dedicated to aviation safety

and the highest standards of excellence. Global Aerospace, with more than 90 years of 

experience, and over 14 offices around the world, has placed trust and confidence into 

WAYPOINT as the sole provider of flight safety training and education to its worldwide 
U.S. Department of Transportation 

April 3, 2015

Page 3

portfolio of clients seeking to responsibly integrate sUAS into their businesses and 

operate safely.

As an affiliate to the Unmanned Safety Institute, WAYPOINT staff have provided a 

variety of flight safety training programs to both individuals and proponent organizations 

around the world, as part of its role in the SM4 Safety Program, as well as through other 

independent channels. These include:

• A workshop on unmanned aviation safety to a major Part 135 operator 

providing unique air services to government and private industry, including 

international air ambulance services and transportation of unique cargo such 

as explosives. The local FSDO participated in this training workshop.

• UAS safety training to one of the largest multinational oil and gas corporations 

in the world.

• UAS operator training, flight safety training, and scenario-based training to 

one of the largest electric utilities companies in the world, and a leading 

utilities company in the United States.

• UAS flight safety education and curriculum development for Embry-Riddle 

Aeronautical University, one of the world’s most prestigious aviation 

universities. 

WAYPOINT seeks the requested exemptions and a Certificate of Authorization to permit 

it to offer on-demand commercial UAS operations for the following industries and 

applications:

• Precision agriculture

WAYPOINT has adopted a philosophy that recognizes that UAS operations are a part of 

complex, interconnected systems that make up the NAS. As a result, WAYPOINT, in 

partnership with the Unmanned Safety Institute, has instituted for its UAS operations in 

the NAS, a strict policy on flight safety. These include FAA-credentialed private pilots 

cross trained by the Unmanned Safety Institute to rigorous flight safety standards to 

serve as Pilot in Command (PIC), the designation of a Safety Manager and 

implementation of a robust Safety Management System (SMS), and participating in 

routine Safety Audits by the Unmanned Safety Institute.

As set forth in more detail in the attached Confidential documents, WAYPOINT will 

provide a mission capable UAS, FAA-credentialed PIC who is trained and endorsed by 

the Unmanned Safety Institute, observer, sensor operator (if needed), and any 

additional flight crew members needed for the specific flight operation. WAYPOINT will 

retain operational control of all UASs, and each operation will be performed pursuant to 

a set of general procedures applicable to all flights, as well as additional flight 

procedures developed as suitable for each defined area of work.
U.S. Department of Transportation 

April 3, 2015

Page 4

The contact information for Petitioner is as follows: 

WAYPOINT GLOBAL STRATEGIES, INC.

Attn: Aaron L. Greenwald

146 Orange Place, Maitland Florida 32751

Phone: (202) 505-0862 

Toll-Free: 1-844-200-0155 Ext. 2

E-mail: Aaron.Greenwald@WaypointGS.com

II. RELEVANT STATUTORY AUTHORITY 

This petition for exemption is submitted in accordance with the Section 333(a) through 

(c) of the FAA Modernization and Reform Act of 2012. Congress has directed the FAA 

"to safely accelerate the integration of civil unmanned aircraft systems into the national 

airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is 

to permit unmanned aircraft systems to operate in the National Airspace System 

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

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

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

• Operation of the UAS within the visual line of sight of the operator.1

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 44701(±) (permitting exemptions 

from§§ 44701(a), (b) and§§ 44702-44716, et seq.). A party requesting an exemption 

must explain the reasons why the exemption: (1) would benefit the public as a whole, 

and (2) would not adversely affect safety (or how it would provide a level of safety at 

least equal to the existing rules). See 14 C.F .R. § 11.81 (petitions for exemption). 

III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM 

ACT 

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive UAS 

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) 

controlled as to access; and that (4) provides an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose. 

																																																												 1 Id. at § 333(b)(1).
U.S. Department of Transportation 

April 3, 2015

Page 5

Given the small size of the sUASs involved and the restricted environment within which 

they will operate, this petition exemption falls within the zone of safety, i.e., an 

equivalent level of safety, in which Congress desired the FAA to permit commercial 

UAS operations by exemption pending completion of formal rulemaking. Also, due to 

the size of the sUASs, their sole intended use in remote sensing for agriculture, and the 

restricted area in which the sUASs will operate, approval of the application presents no 

national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest. 

Accordingly, Petitioner respectfully requests the FAA grant the requested exemption 

without delay. 

IV. DESCRIPTION OF PROPOSED OPERATIONS 

A. Scope of Operations.

As an affiliate to the Unmanned Safety Institute, WAYPOINT will draw upon its vast 

aviation and flight safety experience to provide UAS services to a highly regarded 

agriculture customer in pre-defined areas. Detailed, industry specific procedures have 

been created and are set forth in the accompanying Confidential documents to ensure 

safe operation for the potential UAS application. To assist the FAA in its safety 

assessment of Petitioner's proposed sUAS operations, below is a summary of 

operational limitations and conditions, which will ensure an equivalent or higher level of 

safety to operations conducted under current regulatory guidelines: 

1. The UAS will weigh less than 55 pounds. 

2. Flights will be operated within visual line-of-sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be limited to the 

amount of time the UAS can be flown and still maintain a reserve battery 

power of no less than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet above ground

level ("AGL"). As a result, the UAS flight will not be conducted within 

navigable airspace. 
U.S. Department of Transportation 

April 3, 2015

Page 6

5. Flights will be operated at a lateral distance of least 100 feet from any 

inhabited structures, buildings, vehicles, vessels, or people not associated 

with the operation or who have not signed a waiver in advance of the 

operation. 

6. The petitioner will file a Notice to Airman ("NOTAM") with an appropriate air 

traffic control ("ATC") facility between 72 and 48 hours before the flight.

7. A Certificate of Authorization ("COA'') will be obtained prior to flight.

8. The petitioner will coordinate operations with the appropriate Flight Standards 

District Office ("FSDO").

9. Minimum crew for each operation will consist of the UAS Pilot, one or more 

Visual Observers as necessary to safely conduct the mission, and a Sensor 

Operator if required. 

10.The UAS Pilot will hold an FAA private pilot's license with class III medical 

certificate.

11.The observer designated for any operation will have at least a class II medical 

certificate. 

12.The UAS Pilot will be Pilot in Command ("PIC"). If a pilot certificate holder 

other than the UAS Pilot, who possesses the necessary PIC qualifications, is 

also present, that person can be designated as PIC. 

13.The UAS will operate in accordance with the safety and operational 

requirements of the Operations Manual. 

14.Prior to the operation, a Safety Risk Analysis Plan (SRAP) will be created 

which includes all safety and operational information necessary to safely carry 

out the flight. 

15.A briefing will be conducted in regard to the planned sUAS operations prior to 

each day's missions. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for 

this briefing. 

16.Pilot, Visual Observer and Sensor Operator will at all times be able to 

communicate by voice. 
U.S. Department of Transportation 

April 3, 2015

Page 7

17.The UAS PIC will be trained and certified by the Unmanned Safety Institute to 

the Professional System Operator© (“PSO©”) level. To obtain the PSO 

credential, the UAS PIC must possess an FAA Private Pilots License, obtain 

a aircraft-specific training on the specific air vehicle, and attend an Small 

Unmanned Aircraft Safety workshop presented by the Unmanned Safety 

Institute. The PSO© credential, outlined further below, will address critical 

components of safe flight for UAS operators.

18.All required permissions and permits will be obtained from territorial, state, 

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

appropriate governmental agencies. 

19.The operator will file a FAA Form 7711-1, or its equivalent, as modified in light 

of the requested exemption, with the local Flight Standards District Office 

("FSDO"). 

20.If the sUAS loses communications or loses its GPS signal, the sUAS will have 

the capability to return to a pre-determined location within the operational 

area and land. 

21.An Emergency Response Plan will be developed to safely terminate flight if

there is a loss of communication between the pilot and the observer. 

22.The UAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

23.The petitioner will enroll in the Unmanned Safety Institute’s Safety Audit 

Program that will independently assess petitioner’s safety management 

practices. Petitioner will designate a Safety Manager and also implement 

Safety Management Systems (SMS) to ensure UAS flight safety best 

practices. .

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

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

This statutory authority, by its terms, includes exempting civil aircraft, as the term is 

defined under§ 40101 of the Act, including sUASs, from its safety regulations and 
U.S. Department of Transportation 

April 3, 2015

Page 8

minimum standards when the Administrator decides a requested exemption is in the 

public interest.2

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. 

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

and (2) the operating procedures and safeguards that Petitioner has established which 

will ensure a level of safety better than or equal to the rules from which exemption is 

sought.3

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

Petitioner 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). 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. 

All UAS operated by WAYPOINT will meet the requirements of a small UAS, i.e., have a 

gross take-off weight of less than 55 pounds. Given the size and limited operating area 

associated with the UAS operations, 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. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without 

an airworthiness certificate, in the restricted environment and under the conditions 

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

an airworthiness certificate without the restrictions and conditions of the proposed sUAS

operations. 

Equivalent Level of Safety 

The sUASs to be operated hereunder weigh less than 55 pounds with payload, carry 

neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and 

operate exclusively within a secured and sterile area. Unlike other civil aircraft, the 

proposed operations will be controlled and monitored by the operator, as well as an 

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

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716) 3 See 14 C.F .R. § 11.81 (e), which requires a petition for exemption to include: The reasons why granting 

the exemption would not adversely affect safety, or how the exemption would provide a level of safety at 

least equal to that provided by the rule from which you seek exemption.
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Page 9

observer and sensor operator, pursuant to the Manual's requirements. Moreover, the 

FAA will have advance notice of all operations conducted under this exemption. 

These safety enhancements, which already apply to civil aircraft operated in connection 

with existing inspection operations, provide a greater degree of safety to the Petitioner's 

employees, members of 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 sUAS, due to its size, speed of operation, lack of 

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

load. 

B. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: 

Pilot in Command. Commercial Pilot Privileges and Limitations.

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire.

WAYPOINT’s proposed operations meet the requirements of 8900.227 para 16(c)(2)(c) 

"Operations without a pilot certificate" in which the PIC is required to complete "FAA 

private pilot ground instruction" and pass "the FAA Private Pilot written examination." 

Since there are currently no means available for the pilot of a UAS to gain the 

experience in an equivalent category and class in order to apply for a commercial pilot's 

license, WAYPOINT’s proposed operations can achieve the equivalent level of safety by 

having their pilots to complete an advanced flight safety training program as outlined in 

Section VI of this petition whereby all pilots employed by WAYPOINT will undergo 

advanced UAS training by the Unmanned Safety Institute and each be certified as a 

Professional System Operator©. 

Equivalent Level of Safety 

Because the UAS will not carry a pilot or passengers, the proposed operations can 

achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate this small UAS, as well as an advanced UAS flight safety training as 

documented in Section VI of this petition. Unlike a conventional aircraft that carries the 

pilot and passengers, the sUAS is remotely controlled with no person on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated 

in advance as set forth in the Operations Manual. The level of safety provided by the 

requirements included in the Operations Manual exceeds that provided by a single 

individual holding a commercial pilot’s certificate operating a conventional aircraft. The 
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risks associated with the operation of the sUAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a private pilot who holds advanced 

UAS flight safety training exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b).

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

Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. § § 91.9(c), and 45.23(b).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that: 

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

is identified in accordance with Part 45 of this chapter. 

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport, "experimental," or "provisional," 

as applicable. 

Exemption from 14 C.F.R. § 45.23(b) is warranted because the sUAS has no entrance 

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

Moreover, given the size of the sUAS, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with 14 C.F.R. § 45.29(f). 

Equivalent Level of Safety 

The equivalent level of safety for exemptions to the aircraft marking and identification 

requirements of§§ 91.9(c) and 45.23(b) and will be provided by having the sUAS 

marked on its fuselage as required by § 45.29(f). 

The FAA has previously issued the following exemptions to the aircraft marking 

requirements of§ 45.23(b): Exemption Nos. 10700, 10167 and 10167A. 
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D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

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

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

this chapter, unless there is available in the aircraft a current approved airplane 

or Rotorcraft Flight Manual, approved manual material, markings and placards, 

or any combination thereof. 

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

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it 

has within it the following: 

(1) An appropriate and current airworthiness certificate... 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

WAYPOINT does not request an exemption from this section but instead notifies the 

FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 

2014, the UAS flight manual, registration certificate and other documentation will be 

kept at the control station with the PIC during flight. The Chief Counsel's Office has held 

that for all UAS operations, this alternate method constitutes full compliance with the 

regulations. 

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

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness 

certificate issued for the sUAS, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. 

Equivalent Level of Safety 

The UASs will be fully maintained and operated in accordance with all specifications 

and requirements identified by the manufacturer. WAYPOINT will only operate sUAS

that have a proven track record of reliability and safety. Further, given that no UAS will 
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be operated by WAYPOINT with a weight of over 55 pounds, and no UAS will be flown 

unless it has been maintained and prepared for flight in accordance with the 

manufacturer's requirements, an equivalent level of safety will be provided. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

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

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

familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with 

all information necessary to safely conduct the flight, an exemption is requested to the 

extent that an FAA -approved Flight manual is required. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Aircraft Operations Manual 

and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including reviewing weather, flight battery requirements, landing and takeoff 

distance, and aircraft performance data - before initiation of flight. The Aircraft 

Operations Manual and manufacturer's flight manual will be kept at the ground station 

with the operator at all times. 

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

Petitioner 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 functioning dual controls." sUASs and 

remotely piloted aircraft, by their design, do not have functional dual controls. Instead, 

flight control is accomplished through the use of a box that communicates with the 

aircraft via radio communications. 

Equivalent Level of Safety 

Given the size and speed of the sUAS, an equivalent level of safety can still be 

achieved without dual controls because no pilot or passengers are aboard the sUAS, 

and all persons will be a safe distance away in the event that the sUAS experiences any 

difficulties during flight instruction. 
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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. 

Exemptions include: Nos. 5778K and 9862A.

H. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F .R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any 

person, vessel, vehicle, or structure in non-congested areas; See 14 C.F .R. § 

91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on 

the surface," provided that "each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended services, the sUAS is normally operated below 400 feet AGL. 

Additionally, the sUAS will maintain a lateral distance of at least 100 feet from inhabited 

structures, buildings, vehicles, and vessels, and from people not associated with the 

operation. 

Equivalent Level of Safety 

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

sUAS weight proposed herein, and given the lack of flammable fuel, any risk associated 

with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the 'size, weight, and speed 

of the UAS, as well as the location where it is operated. As set forth in the Manual, the 

sUAS will be operated in a restricted area. Furthermore, by operating at such lower 

altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum 

safe altitude regulations. 

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

This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required to the extent that the sUAS does not have a barometric altimeter, 

but rather a GPS altitude read out. 

Equivalent Level of Safety 

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

Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch 
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site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the 

GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation 

at safe altitudes. 

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

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on sUAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30-minute reserve. 

WAYPOINT proposes that all flights comply with this requirement by mandating that the 

aircraft be safely landed with no less than 25% of battery life remaining. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted 

on-site without significant transit time by the sUAS. All flights will be planned to be 

terminated with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to the ground and its planned 

landing zone from anywhere in its limited operating area even in the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve 

fuel does not include the type of risks that Section 91.151 (a) was intended to alleviate 

given the size and speed of the small UAS, and the proximity of the flight operation to 

the landing zone. Moreover, operation will be limited to controlled areas where only 

people and property owners, or official representatives who have signed waivers, will be 

allowed.

This request for exemption falls within the scope of prior exemptions, including 

Exemption Nos. 10673, 2689F, 5745, 10673, and 10808. 
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K. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

Petitioner also seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.F.R. 

Part 43. See, e.g., 14 C.F.R.§ 91.405(a) (stating that each owner or operator of an 

aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ... have discrepancies repaired as prescribed in part 

43 of this chapter"). An exemption to these regulations is needed because Part 43 and 

these sections only apply to aircraft with an airworthiness certificate, which the sUAS 

will not have. 

Equivalent Level of Safety 

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

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Aircraft Operations Manual. As provided in the Operations Manual, the operator will 

ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. 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. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during 

daylight hours, creates less risk than that associated with conventional aircraft

performing the same operation. 

VI. ADVANCED UAS FLIGHT SAFETY TRAINING

WAYPOINT recognizes that UAS present a significant and complex flight safety 

challenge within the NAS. WAYPOINT is committed to the highest standards of 

excellence in flight safety and safety risk management. As a result, any PIC employed 

by WAYPOINT will not only possess a Private Pilot’s License provided by the FAA but 

will also be trained and certified as a Professional System Operator© (PSO©) by the 

Unmanned Safety Institute. 

To become certified as a PSO©, the student must have a valid Private Pilot’s License 

issued by the FAA. After presenting this credential the candidate must attend and pass 

the Small Unmanned Aircraft System Safety workshop at the Unmanned Safety 

Institute. This workshop focuses on eight specific flight safety modules.
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Area one: Unmanned Aircraft Systems 

1. Small unmanned aircraft system loading and performance

2. Basic unmanned aircraft systems

3. Dealing with common UAS Emergencies 

Area two: Operations Planning 

1. Field site survey and preparation

2. Safety zones and sterile area concept

3. Energy planning 

Area three: Weather

1. Official sources of weather and effects of weather on performance

2. Field weather measurements

Area four: Airspace

1. Rules and Regulations

2. Airspace classification, control authority, and operating requirements 

3. Procedures for safely operating near airports

Area five: Crew Resource Management 

1. Human factors and Crew resource management

2. Physiological effects of drugs and alcohol

3. Six core Crew Resource Management concepts

4. The crew concept

Area six: Hazard Identification and Mitigation 

1. Four hazard domains

2. Risk mitigation strategies 

Area seven: Aeronautical Decision Making 

1. Decision processes 

2. Limitations and external pressures 

Area eight: Safety Management Systems

1. Safety Procedures and Policy

2. Assessing risks

3. Safety Assurance practices

4. Safety promotion
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Upon completion of the Small UAS Safety Workshop, the candidate must participate in 

Unmanned Aircraft (“UA”) specific training and demonstrate proficiency in UAS type. 

This UA training must include all areas listed below per Unmanned Safety Institute 

guidelines;

Area 1: Syllabus and Instruction Administration

1. Clearly defined objectives for each block of training

2. Training plan defining the number and sequence of events

3. Each training event has a completion standard and has identified items that must 

be covered in order to be considered complete

4. Training may include a combination of CBT, classroom, simulation, and live fly 

however, the program must include the greater of 5 hours or 10 flight training 

cycles

5. The training plan has standardized grade sheets for each block of training and is 

“signed off” by both the trainee and the instructor

6. The training record is kept for one year after training (digital versions okay)

7. The training operator has an instructor upgrade and qualification program

8. All trainees are required to pass a standardized practical and written test 

administered by an impartial party (check airman, chief of training, evaluator, 

etc.)

9. Trainees participate in operations as part of a team conducting full scale 

operations, not just part tasks as individual crew positions

10.Safety program and records of data

Area 2: Vehicle Specification

1. Is capable of waypoint navigation

2. Has stabilization and stability augmented by automation

3. Has a human machine interface other than just a controller

Area 3: Unmanned Aircraft Vehicle Specific Module

1. Systems components and functions

2. Flight controls, aerodynamics and modes of control

3. Telemetry and displays

4. Payloads and use

5. Data link equipment, operational bands, and limitations

6. Mission/operation planning software

7. Performance and limitations

8. UAS flight manual and documents review

Area 4: Pre-flight Procedures Module

1. Certificates, logs and documents

2. Preflight inspection

3. Control station and antenna equipment setup (if applicable)
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4. Launch and recovery equipment, operational use, service limits, setup and 

teardown

5. Engine/motor starting

6. Before takeoff check

7. Radio/communications with ATC or CTAF

Area 5: Launch and Recovery Procedures Module

1. Normal and crosswind launch and recovery

2. Normal and crosswind approach

3. Confined area operations (if applicable to UAS)

4. Go-around

5. Controlling rate of descent (if applicable to UAS)

Area 6: Hover/Orbit Maneuvers Module

1. GPS fixed position hold

2. Hover 

3. Station keeping to maintain a fixed orbit around a point

Area 7: Operational Maneuvers Module

1. Departure climb outs

2. Level off/routine checks

3. Establishing and maintaining alt.

4. Straight and level flight

5. Airspeed change, straight-and-level

6. Clearing turns with aircraft or payload (if applicable)

7. Climbs

8. Systems monitoring during turns

9. Inflight change of waypoints or flight path

10.Descends or arrival profiles

11.Edge of visual range operations

12.In-flight checks of the system

13.Proper checklist usage (if applicable)

Area 8: Navigation Module

1. Use of local area map for orientation

2. Map reading (aeronautical charts)

3. Correlation of aircraft position with map

4. Maneuvering within assigned airspace

5. Using visual landmarks in flight

6. Waypoint placement and selection(if applicable)

7. Switching autopilot modes of control (if applicable)

8. Data link management

9. Use of fail safes or “geo fences” to limit UAS operations (if applicable)

10.Calculation of actual fuel/energy consumption
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11.In-flight navigation or flight path planning

12.Calculation/compensation for in flight winds

13.Calculation of estimated time of arrival (eta)

Area 9: Airmanship Module

1. GCS and flight line safety procedures

2. Flight line and air discipline

3. Airmanship, judgment, & decision making and situation awareness

Area 10: Abnormal and Emergency Module

1. Loss of data link

2. Systems and equipment malfunction

3. Aircraft runaway

4. Flight termination

5. Uncontrolled flight into an obstacle

6. Airspace violation

7. Stalls or abnormal flight recovery procedures

Area 11: Crew Interaction Module

1. Collision awareness using a visual observer

2. Crew communication and coordination

3. Briefing and debriefing

4. Recovering from loss of situation awareness

5. Identifying lapses in flight safety

Area 13: Post-Flight Module

1. After landing checks

2. Post landing procedures

3. Engine shutdown checks

4. Equipment tear down (if applicable)

5. Servicing or minor repairs to the systems

6. Completion of flight time logs

7. Completion of maintenance logs

8. Safety procedures for securing UAS components

This course of study and practice comprise the advanced flight safety training provided 

by the Unmanned Safety Institute and is widely recognized by the world’s leading 

aviation insurance underwriting organizations and brokers. This training, in conjunction 

with the additional requirements for UAS PIC noted above, will ensure the operator 

conducts flight safety practices of the highest standards as certified and endorsed by 

the Unmanned Safety Institute.
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VII. DRUG AND ALCOHOL PROGRAM 

As set forth in the Manual, WAYPOINT is committed to a drug-free work place and the 

right of the flying public it serves to safe and efficient flight service. All employees of 

WAYPOINT who perform safety sensitive and/or security related functions are 

prohibited from performing work if they have alcohol or a prohibited drug in their system. 

VIII. PUBLIC INTEREST 

Granting WAYPOINT's exemption request furthers the public interest. National policy 

set by Congress favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this petition. In addition, maintaining industrial 

safety has been a priority of state and local governments for decades. By its nature, the 

proposed use of sUAS offers superior safety to performing the same tasks with 

conventional aircraft or rotorcraft. 

In addition, granting the exemption will help advance the knowledge base for conducting 

commercial UAS operations. WAYPOINT is committed to working with the local FSDO 

to share data from its operations. 

This additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the 

hazards and emissions associated with alternate use of conventional aircraft to conduct 

similar operations. The UAS in question is very light weight and does not carry any 

flammable fuel, further reducing the risk from any potential accident. 

IX. PRIVACY 

All flights will occur in accordance with any state or local laws regarding privacy. 

X. FEDERAL REGISTRY SUMMARY 

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

Federal Register, should it be determined that publication is needed: 

WAYPOINT seeks an exemption from the following rules: 

• 14 CFR Part 21, Subpart H

• 14 CFR 45.23(b)

• 14 CFR 61.113 (a) & (b)

• 14 CFR Part 61.133 (a)

• 14 CFR 91.7(a)
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• 14 CFR 91.9(b)(2)

• 14 CFR 91.103

• 14 CFR 91.109(a)

• 14 CFR 91.119

• 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)

Approval of these exemptions will allow WAYPOINT to offer on-demand commercial 

UAS operations for applications in precision agriculture. The exemptions will enhance 

safety by reducing risk to the general public and property owners from the hazards 

associated with performing equivalent work with conventional aircraft and rotorcraft. 

XI. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, 

weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within visual line of sight, and national security-provides more than adequate 

justification for the grant of the requested exemptions to permit WAYPOINT to operate 

sUASs and provide on-demand UAS services to private entities. 

Granting the requested exemption will benefit the public interest as a whole in many 

ways, including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating 

costs compared with conventional flight operations. 

If you have any questions or require any additional information, please do not hesitate 

to call. 

UNMANNED SAFETY INSTITUTE, LLC

________________________________

Alex Mirot, President

(386) 866-0471

Attachments: Operations Manual and Emergency Response Plan (submitted as a 

Confidential Documents under 14 C.F.R. § 11.35(b) and exempt from disclosure under 
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the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements 

established by the FAA pursuant to Section 333 of the Reform Act).