Brian J. Kelso 

31152 Wakefield Drive 

Spanish Fort, AL 36527 

June 15, 2015 

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); 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) 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Brian J. Kelso, operator of small Unmanned Aerial Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations to allow commercial operation of a 

small UAS, so long as such operations are conducted within and under the conditions outlined 

herein or as my be established by the FAA as required by Section 333. 

Commercial operation small UAS, as described herein, which are equipped with cameras and 

sensors, would operate in the following manner: 

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

architecture, agriculture, land surveying, engineering and other related professional 

activities. 

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

public events, and cinematography. 

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

with the owners or local government authority. 

4. 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. 

1 

Kelso- FAR Section 333 Exemption Request 
As described fully below, the requested exemption would permit the operation of small UAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined 

and d) will provide safety enhancements to the already safe operations in the industry 

presently using conventional aircraft. Approval of this exemption would thereby enhance safety 

and fulfill 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, phone, email and address of the applicant: 

Name: Brian J. Kelso 

Phone: (251) 767-5182 

Email: kelgun04@yahoo.com 

Address: 31152 Wakefield Drive, Spanish Fort, AL 36527 USA 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113(a) 

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) 

The small UAS's I will be using are multi-rotor craft weighing no more than 551bs. including 

payload. Under normal conditions they operate at speeds of no more than 45 Mph or 39 Knots 

and have the ability to hover and move along a vertical and horizontal plane simultaneously. 

They will operate in line of sight only and by the exempted person only obeying all other local 

and federal laws. 

Given the small size of the small UAS 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 

2 

Kelso- FAR Section 333 Exemption Request 
interest. Accordingly the applicant requests that the FAA grant the requested exemption with 

minimum delay. 

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 small UAS will weigh less than 55 lbs. 

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

3. Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve or 30 minutes of flight time whichever occurs 

first. 

4. 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. 

5. Minimum crew for each operation will consist of the small UAS Pilot in Command 

(PIC}, the Visual Observer (VO} when needed and may include but not limited to a 

Camera Operator. 

6. The small UAS pilot will be Brian J. Kelso ONLY not allowing any other person to 

operate the small UAS in a commercial capacity. 

7. A briefing will be performed regarding the planned small UAS operations prior to each 

day's flight consisting of all the days' production activities. 

8. The PIC 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 required under the FOM. With the advanced 

permission or direction of the FSDO, operations at closer range may be approved. 

9. The PIC and VO will have been trained in operation of small UAS and receive up-todate information for the particular small UAS to be operated and will be able to show 

upon request their competent ability to operate the small UAS and/or Camera. 

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

11. 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 when needed. 

12. If the small UAS loses communications or loses GPS signal, the small UAS will have 

the capability to return to a pre-determined location within a designated location and 

land autonomously. 

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

obstacles, weather, or emergencies. 

Kelso- FAR Section 333 Exemption Request 

3 
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 small UAS. In all cases, an 

analysis of these criteria demonstrates that the small 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 small 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 small 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 small UAS will have no airworthiness certificate, an exemption may be needed 

as the small UAS will have no entrance to the cabin1 cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the small UAS, two-inch lettering will be 

impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 

(f). The equivalent level of safety will be provided by having the small UAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the small 

UAS will see the identification of the small UAS as "Experimental." 

4 

Kelso- FAR Section 333 Exemption Request 
14 C.F.R. § 61.113(a): Private Pilot Privileges and limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (aL 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. 

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

achieve the equivalent level of safety of current operations by requiring the Pilot operating the 

aircraft to be an experienced aviator with a detailed knowledge of the National Airspace 

System. The FAA has acknowledged in prior grants of exemption under Section 333 that a 

commercial pilot's certificate was not necessary to operate a small UAS, and deemed that a 

Sport Pilot or Recreational Pilot certificate was adequate to address the FAA's requirement that 

the Pilot In Command have the requisite training and understanding of the National Airspace 

System, to ensure that the Pilot is registered with the FAA, and that the flight operation will not 

pose a risk to national security. 

A person holding an FAA Aircraft Dispatchers certificate is just as, or more, qualified to operate 

a small UAS commercially in the National Airspace System than one holding a Sport or 

Recreational pilot certificate. A small UAS operator with an FAA Aircraft Dispatchers certificate 

meets or exceeds the required experience, knowledge, and security levels of the Sport or 

Recreational Pilot certificate. Per 14 CFR 61.97, those applying for the Recreational Pilot 

certificate are required to exhibit knowledge of FAA regulations, accident reporting, VFR 

navigation using aeronautical charts, basic weather, and other topics (See Appendix A, 14 CFR 

61.97). By comparison, a far deeper knowledge and understanding of similar topics is required 

by 14 C.F.R. 65.55 to obtain the Aircraft Dispatchers certificate, often to the same depth 

required by those operating with the Airline Transport Pilot certificate (See Appendix B, 14 

C.F.R. 65.55). In addition, those seeking the Aircraft Dispatchers certificate are required to be 

experienced in the aviation industry, demonstrate skill by passing a practical examination given 

by an FAA designated examiner, and pass an FAA approved dispatcher course consisting of at 

least 200 hours of instruction (See Appendix C, 14 C.F.R. 65.57, 65.59, and 65.61). Given the fact 

that the Aircraft Dispatchers certificate meets, or in most cases exceeds, the desired levels of 

aviation experience and knowledge of the Sport or Recreational pilot certificates, the applicant, 

Brian J. Kelso, requests that an exemption be granted to allow the Aircraft Dispatchers 

certificate be deemed acceptable in order to operate small UAS in a commercial manner. 

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. 

Kelso- FAR Section 333 Exemption Request 

5 
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 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. The small 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 small 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 OPERATOR will take all actions including 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. Small 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 small 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 small UAS will never operate at higher than 400 AGL with the exception 

that in circumstances where the small UAS is used to survey or photograph a structure whose 

height exceeds 400 feet AGL, the small UAS will not be operated more than 100' above the 

highest point on the structure. It will however be operated in a restricted area with security 

6 

Kelso- FAR Section 333 Exemption Request 
perimeter, where buildings and people will not be exposed to operations without their preobtained consent. The equivalent level of safety will be achieved given the size, weight, speed 

of the small 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 551bs. 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 small UAS will ensure separation between these small 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 small UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an 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 battery powering the small UAS provides approximately 30 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, small UAS flights would be limited 

to approximately 10 minutes in length. Given the limitations on the small UAS's proposed flight 

area and the location of its proposed operations within a predetermined area, a longer time 

frame for flight in daylight or twilight VFR conditions is reasonable. Applicant believes that an 

exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. Operating the 

small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, 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. Additionally, limiting small UAS flights to 10 minutes would 

greatly reduce the utility for which the exemption will be granted. 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 

small UAS to its planned landing zone from anywhere in its limited operating area. 

7 

Kelso- FAR Section 333 Exemption Request 
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 small UAS fully loaded weighs no more than 55 lbs. 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 small UAS. 

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

control point where the pilot flying the small UAS will have immediate access to them; to the 

extent they are applicable to the small 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 section 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 these small UASs are very limited in size and will carry a small payload 

and operate only in restricted areas for limited periods of time. If mechanical issues arise the 

small UAS can land immediately and will be operating from no higher than 400 feet AGL. The 

operator will ensure that the small 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 small UAS Manufacturer's Manual, as referenced in the 

Aircraft Operations Manual (AOM). As provided in the FOM1 the operator will ensure that the 

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

needed. 

Kelso- FAR Section 333 Exemption Request 

8 
Small UAS Information 

Small UAS's to be used are as follows but not limited to providing they are within the scope of 

the exemption granted by the FAA: 

1. Walkera QR X350 Pro 

• Weight (Battery Included): 2.17 lbs 

• Takeoff Weight: <2.98 lbs 

• Main Rotor Diameter: 22.91 inches 

• Main Rotor Blade Length: 9.13 inches 

• Length: 11.38 inches 

• Width: 11.38 inches 

• Height: 8.07 inches 

• Brushless Motor Spec: WK-WS-28-008C 

• Brushless ESC Spec: WST-15A(G/R) 

• Receiver: Devo RX703A 

• Walkera QR X350 Pro Battery 

o 11.1 volt 5200mAH LiPo Battery 

• G-2D Brushless Gimbal 

o Maximum Angular Rate: 2000 deg/sec 

o Maximum Acceleration: 16g 

o Control Frequency: 1000Hz 

o Accuracy:0.1° 

o Control Range: Roll: -45° to 45° 

Pitch: -135° to 90° 

• Devo 10 Transmitter 

o Encoder: 10 Channel Micro Computer System 

o Frequency: 2.4 GHz Direct Sequence Spread Spectrum 

o Output Power: ::;10mW 

o Current Drain: 200mA 

o Transmitter Power Supply: 12V 1600mAh NiMH Battery 

o Output Noise: 1000-2000ms 

2. DJI Flame Wheel F550 

• Takeoff Weight: <5.29 lbs 

• Brush less Motor Type: DJI E300 2212 920kv 

• Brush less ESC Type: DJI E300 15 amp 

• Receiver: NAZA-M V2 with GPS Module 

• Battery 

o 11.1 volt 3S LiPo Battery 

• Zenmuse H3-3D Gimbal 

o Operating Current: Static: 400mA, Dynamic: 600mA 

o Controllable Range: Tilt: -130deg to +45deg 

o Max Controllable Speed: Tilt+/- 130deg/sec 

Kelso- FAR Section 333 Exemption Request 

9 
3. DJIInspire 

Conclusion 

• Weight (Battery Included) 6.4 7 lbs. 

• Hovering Accuracy {GPS Mode) Vertical1.5 ft, Horizontal 7.5 ft 

• Max Angular Velocity Pitch: 300deg/s; Yaw ISOdeg/s 

• Max Tilt Angle 30deg/s 

• Max Ascent Speed 15 ft/s 

• Max Decent Speed 12 ft/s 

• Max Speed 66 ft/s 

• Diagonal Distance 22.0 in. (Landing gear lowered), 22.9 in. (Landing gear raised) 

• DJI Inspire Battery 

o Model (Standard) TB4 7 

o Voltage 22.2v 

o Capacity 4500mAh 

o Energy 99.9Wh 

o Net Weight 1.26 lbs. 

• DJI Inspire Gimbal 

o Operating Current: Station: 750mA, Motion: 900mA 

o Controllable Range: Pitch: -90deg to +30deg 

o Max Controllable Speed: Pitch: 120deg/s, Pan: 180deg/s 

• DJI Inspire Remote Controller 

o Frequency 

• 5.725GHr5.850GHz (Remote Controller to Remote Controller) 

• 2.400GHr2.483GHz (Remote Controller to Aircraft) 

o Battery Capacity 6000mAh 

o Working Current/Voltage 1.2A@7.4V 

Thank you for the consideration of these exemptions. 

Sincerely, 

Brian J. l<elso 

Kelso- FAR Section 333 Exemption Request 

10 
Appendix A 

14 C.F.R. § 61.97 Recreational Pilots. Aeronautical knowledge. 

(a) General. A person who applies for a recreational pilot certificate must receive and 

log ground training from an authorized instructor or complete a home-study course on the 

aeronautical knowledge areas of paragraph (b) of this section that apply to the aircraft 

category and class rating sought. 

(b) Aeronautical knowledge areas. (1) Applicable Federal Aviation Regulations of this 

chapter that relate to recreational pilot privileges, limitations, and flight operations; 

(2) Accident reporting requirements of the National Transportation Safety Board; 

{3} Use of the applicable portions of the "Aeronautical Information Manual" and FAA 

advisory circulars; 

(4) Use of aeronautical charts for VFR navigation using pilotage with the aid of a 

magnetic compass; 

(5) Recognition of critical weather situations from the ground and in flight, windshear 

avoidance, and the procurement and use of aeronautical weather reports and forecasts; 

{6) Safe and efficient operation of aircraft, including collision avoidance, and 

recognition and avoidance of wake turbulence; 

(7) Effects of density altitude on takeoff and climb performance; 

(8) Weight and balance computations; 

{9) Principles of aerodynamics, powerplants, and aircraft systems; 

(10) Stall awareness, spin entry, spins, and spin recovery techniques, if applying for an 

airplane single-engine rating; 

(11} Aeronautical decision making and judgment; and 

(12) Preflight action that includes-

(i) How to obtain information on runway lengths at airports of intended use, data on 

takeoff and landing distances, weather reports and forecasts, and fuel requirements; and 

(ii) How to plan for alternatives if the planned flight cannot be completed or delays 

are encountered. 

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Kelso- FAR Section 333 Exemption Request 
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Appendix B 

14 C.F.R. § 65.55 Aircraft Dispatchers. Knowledge requirements. 

(a) A person who applies for an aircraft dispatcher certificate must pass a knowledge 

test on the following aeronautical knowledge areas: 

(1) Applicable Federal Aviation Regulations of this chapter that relate to airline 

transport pilot privileges, limitations, and flight operations; 

(2) Meteorology, including knowledge of and effects of fronts, frontal characteristics, 

cloud formations, icing, and upper-air data; 

(3) General system of weather and NOT AM collection, dissemination, interpretation, 

and use; 

(4) Interpretation and use of weather charts, maps, forecasts, sequence reports, 

abbreviations, and symbols; 

(5) National Weather Service functions as they pertain to operations in the National 

Airspace System; 

(6) Windshear and microburst awareness, identification, and avoidance; 

(7) Principles of air navigation under instrument meteorological conditions in the 

National Airspace System; 

(8) Air traffic control procedures and pilot responsibilities as they relate to en route 

operations, terminal area and radar operations, and instrument departure and approach 

procedures; 

(9) Aircraft loading, weight and balance, use of charts, graphs, tables, formulas, and 

computations, and their effect on aircraft performance; 

(10) Aerodynamics relating to an aircraft's flight characteristics and performance in 

normal and abnormal flight regimes; 

(11) Human factors; 

(12) Aeronautical decision making and judgment; and 

(13) Crew resource management, including crew communication and coordination. 

(b) The applicant must present documentary evidence satisfactory to the 

administrator of having passed an aircraft dispatcher knowledge test within the preceding 

24 calendar months. 

12 

Kelso- FAR Section 333 Exemption Request 
Appendix C 

14 C.F.R. § 65.57 Aircraft Dispatchers. Experience or training requirements. 

An applicant for an aircraft dispatcher certificate must present documentary evidence 

satisfactory to the Administrator that he or she has the experience prescribed in paragraph 

(a) of this section or has accomplished the training described in paragraph (b) of this 

section as follows: 

(a) A total of at least 2 years experience in the 3 years before the date of application, 

in any one or in any combination of the following areas: 

(1) In military aircraft operations as a-

(i) Pilot; 

(ii) Flight navigator; or 

(iii) Meteorologist. 

(2) In aircraft operations conducted under part 121 of this chapter as-

(i) An assistant in dispatching air carrier aircraft, under the direct supervision of a 

dispatcher certificated under this subpart; 

(ii) A pilot; 

(iii) A flight engineer; or 

(iv) A meteorologist. 

(3) In aircraft operations as-

(i) An Air Traffic Controller; or 

(ii) A Flight Service Specialist. 

(4) In aircraft operations, performing other duties that the Administrator finds 

provide equivalent experience. 

(b) A statement of graduation issued or revalidated in accordance with §65. 70(b) of 

this part, showing that the person has successfully completed an approved aircraft 

dispatcher course. 

14 C.F.R. § 65.59 Skill requirements. 

An applicant for an aircraft dispatcher certificate must pass a practical test given by 

the Administrator, with respect to any one type of large aircraft used in air carrier 

operations. The practical test must be based on the aircraft dispatcher practical test 

standards, as published by the FAA, on the items outlined in appendix A of this part. 

14 C.F.R. § 65.61 Aircraft dispatcher certification courses: Content and minimum hours. 

(a) An approved aircraft dispatcher certification course must: 

(1) Provide instruction in the areas of knowledge and topics listed in appendix A of 

this part; 

(2) Include a minimum of 200 hours of instruction. 

(b) An applicant for approval of an aircraft dispatcher course must submit an outline 

that describes the major topics and subtopics to be covered and the number of hours 

proposed for each. 

(c) Additional subject headings for an aircraft dispatcher certification course may also 

be included, however the hours proposed for any subjects not listed in appendix A of this 

part must be in addition to the minimum 200 course hours required in paragraph (a) of 

this section. 

13 

Kelso- FAR Section 333 Exemption Request 
(d) For the purpose of completing an approved course, a student may substitute 

previous experience or training for a portion of the minimum 200 hours of training. The 

course operator determines the number of hours of credit based on an evaluation of the 

experience or training to determine if it is comparable to portions of the approved course 

curriculum. The credit allowed, including the total hours and the basis for it, must be 

placed in the student's record required by §65. 70(a) of this part. 

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Kelso- FAR Section 333 Exemption Request 

14