425 E. Hollywood Boulevard, Suite A

Mary Esther, Florida 32569

(850)-243-4411, (850)-243-5279 Fax

www.unconventional-inc.com

Unconventional ConceptsTM, Inc. `

U. S. Department of Transportation

Docket Operations

West Building Ground Floor

Room w12-140

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Petition of Unconventional Concepts, Inc. for an Exemption pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (PL 112-95) and 14 C.F.R. Part 11, the 

Petitioner, Unconventional Concepts, Inc. (UCI), a developer and operator of Small Unmanned Aircraft Systems (sUAS), 

hereby applies for exemption from the Federal Aviation Regulations (FARs) listed below to allow UCI to conduct 

commercial operation of sUAS under the conditions and limitations outlined within this document for the purposes of, but 

not limited to, photography, video collection, data collection, industrial inspection, search and rescue, demonstration, and 

system development.

For your convenience, this request is organized as follows:

I. Introduction of Petitioner 

II. Description of Proposed Operation

a. Summary

b. Description of sUAS models

III. Specific Sections of 14 C.F.R. from which UCI seeks relief

IV. Extent of relief sought

V. Why granting the exemption will not adversely affect safety

VI. Why granting this relief would be in the public interest

VII. Summary to be published in the Federal Register

VIII. List of attached supporting documents

IX. Conclusion
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I. Introduction to the Petitioner:

Name: Unconventional Concepts, Inc.

Headquarters: 425 East Hollywood Blvd., Ste A

Mary Esther, FL 52569

Phone: 850-243-4411 

Fax: 850-243-5279

Company President: Michael Hopmeier

850-243-4411

Primary Point of Contact: Barry Skidmore

Project Manager, UAV Systems

Phone: 703-870-7211

Email: bskidmore@unconventional-inc.com

Unconventional Concepts, Inc. (UCI) is a professional engineering and technical consulting firm specializing in issues 

related to preparedness response operations, homeland security, and national security. UCI is currently developing 

specialized small Unmanned Aircraft Systems (sUAS) in an effort to provide cheap, affordable, and rapidly-deployable 

aerial observation capabilities for a wide range of clients. It is also investigating measures to mitigate the potential threat 

to public safety and national security presented by the increasing number of sUAS in the National Air Space.

II. Description of Proposed Operation:

a. Summary

UCI seeks this exemption under Section 333 of the FAA Modernization and Reform Act of 2012 (PL 112-95) to legally 

and safely operate sUAS in the National Airspace System for the purposes of, but not limited to: photography, video 

collection, data collection, industrial inspection, search and rescue, demonstration, and system development.

All sUAS operations conducted by UCI will adhere to strict operational safety protocols established in the attached UCI 

UA Flight Safety Manual and to requirements established by a Certificate of Waiver or Authorization (COA). At a 

minimum, all sUAS operations will occur:

• on private land with pre-approval from the owner or their representative,

• in areas with controlled-access, 

• during daylight hours, 

• below 400 feet above ground level (AGL), 

• within visual line-of-sight (VLOS) of the sUAS Pilot in Command (PIC) and designated Visual Observer (VO), 

and

• outside controlled airspace unless prior notice has been given and relevant authorization has been granted.

The requested exemption would permit the operation of sUAS under controlled conditions in airspace that 1) is limited 2)

is predetermined 3) is access controlled and 4) provides safety enhancements to the collection of data as listed above. 

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 proposed operations in this petition for exemption are substantially similar to those contained in prior FAA grant 

exemptions, including:

Exemption No. Regulatory Docket No.

11062 FAA-2014-0352

11109 FAA-2014-0507

11112 FAA-2014-0382

11213 FAA-2014-0642
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b. Description of sUAS models

At this time, UCI intends to utilize the following sUAV models: DJI Phantom, DJI Phantom 2 Vision, 3D Robotics Iris+,

Blade 350QX, and seven custom-built small Unmanned Aircraft (UA) of proprietary design with model numbers TUAV 

Mk 1.0, TUAV Mk 1.1, TUAV Mk 1.2, TUAV Mk 1.3, TUAV Mk 1.4, TUAV Mk 2.0, and TUAV Mk 2.1. 

In previous exemption grants, the Secretary of Transportation has determined the Blade 350QX, 3D Robotics Iris+, DJI 

Flame Wheel F550, DJI Phantom, DJI Phantom 2 Vision, and DJI Phantom 3 each meets the conditions of Section 333. A 

brief list of examples below:

sUAV Model Exemption No. Regulatory Docket No.

Blade 350QX 11138 FAA-2014-0481

3D Robotics Iris+

11741 FAA-2015-0892

11778 FAA-2015-0591

11861 FAA-2015-1118

DJI Phantom 11138 FAA-2014-0481

DJI Phantom 2 Vision 11731 FAA-2015-0061

11811 FAA-2015-1083

All of the proprietary small UA in this request are unique in that, while their flight performance characteristics are very 

similar to standard sUAS, they are not powered by an on-board battery. Instead they are powered from the ground via a 

Kevlar and fiberglass-wrapped wire cable. This design creates three distinct safety benefits:

1. The remote power source reduces the overall weight of the UA.

2. The wire cable will have a maximum length of 400 feet, physically limiting the altitude of the UA.

3. The wire cable negates the potential threat of “fly-offs.” In the event that the cable is severed or radio control is 

lost, the UA will automatically switch over to a small on-board emergency backup battery. It will also trigger the

UA’s on-board flight controller safety protocols to quickly land the vehicle in a safe and stable manner.

Beyond the shared feature of a ground-based power supply, the proprietary sUAS can be divided into three groups:

TUAV Mk 1.0 and TUAV Mk 1.1

Basic design summary: The TUAV Mk 1.0 and TUAV Mk 1.1 are hexacopters built on the frame of a DJI Flame Wheel 

F550. Due to the inclusion of added circuitry and a belly compartment attached to the bottom of the F550 frame, the Mk 

1.0 and Mk 1.1 have slightly heavier maximum take-off weights than the F550 (3050g vs 2400g). However the UAs both 

retain performance profiles nearly identical to the F550.

TUAV Mk 1.0 TUAV Mk 1.1

Maximum Width: 610mm 610mm

Height: 210mm 210mm

Prop Size: 250mm 250mm

Max. take-off weight (incl. payload): 3050 grams 3050 grams

Max. payload weight: 850 grams 1050 grams

Max Altitude: 400 Ft. AGL 400 Ft. AGL

Max Travel Distance: 400 Ft. 400 Ft.

Max Ascent Speed: 5m/s 5m/s

Flight Control System: DJI Naza M V2 DJI Naza M V2

Radio Controller: Spektrum DX9 Spektrum DX9

Radio Frequencies: 2.4GHz 2.4GHz/ 5.8GHz

Standard Payloads:

Mk 1.0: GoPro camera on stationary mount

Mk 1.1: GoPro camera on Zenmuse H3-2D gimbal, 5.8GHz HD video transmitter
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TUAV Mk 1.2, TUAV Mk 1.3, TUAV Mk 1.4

Basic design summary: The TUAV Mk 1.2, TUAV Mk 1.3, and TUAV Mk 1.4 are hexacopters designed around a 

carbon fiber and polycarbonate frame. They are lighter, more responsive, and can carry heavier payloads than the Mk 1.0 

and Mk 1.1. However, their basic flight capabilities remain the same.

TUAV Mk 1.2 TUAV Mk 1.3 TUAV Mk 1.4

Maximum Width: 600mm 600mm 600mm

Height: 180mm 180mm 180mm

Prop Size: 250mm 250mm 250mm

Max. take-off weight (incl. payload): 3050 grams 3650 grams 3650 grams

Max. payload weight: 1250 grams 2350 grams 2350 grams

Max Altitude: 400 Ft. AGL 400 Ft. AGL 400 Ft. AGL

Max Travel Distance: 400 Ft. 400 Ft. 400 Ft.

Max Climbing Speed: 5m/s 5m/s 5m/s

Flight Control System: DJI Naza M V2 DJI Naza M V2 3DR Pixhawk

Radio Controller: Spektrum DX9 Spektrum DX9 Futaba T10CHG

Radio Frequencies: 2.4Ghz 2.4Ghz/ 5.8Ghz 2.4Ghz/ 5.8Ghz

Standard Payloads:

TUAV Mk 1.2: GoPro camera on Zenmuse H3-3D gimbal, 2.4GHz Control and video transmitter

TUAV Mk 1.3: GoPro camera on Zenmuse H3-3D gimbal, 5.8GHz video transmitter

TUAV Mk 1.4: GoPro camera on Tarot T-2D Gimbal, 5.8GHz video transmitter

TUAV Mk 2.0, TUAV Mk 2.1

Basic design summary: The TUAV Mk 2.0 and TUAV Mk 2.1 are quadcopters designed around a carbon fiber and 

polycarbonate frame. They are lighter still than any of the hexacopters, but otherwise retain the same capabilities.

TUAV Mk 2.0 TUAV Mk 2.1

Maximum Width: 510mm 510mm

Height: 195mm 195mm

Prop Size: 250mm 250mm

Max. take-off weight (incl. payload): 2250 grams 2250 grams

Max. payload weight: 750 grams 1250 grams

Max Altitude: 400 Ft. AGL 400 Ft. AGL

Max Travel Distance: 400 Ft. 400 Ft.

Max Climbing Speed: 5m/s 5m/s

Flight Control System: DJI Naza M V2 DJI Naza M V2

Radio Controller: Spektrum DX9 Spektrum DX9

Radio Frequencies: 2.4Ghz/ 5.8Ghz 2.4Ghz/ 5.8Ghz

Standard Payloads:

TUAV Mk 2.0: GoPro camera on Zenmuse H3-3D gimbal, 5.8GHz video transmitter

TUAV Mk 2.1: GoPro camera on Zenmuse H3-3D gimbal, 5.8GHz video transmitter

All of the proprietary designs listed in this petition for exemption are substantially similar to other custom-built sUAS 

determined to have met the conditions of Section 333 by the Secretary of Transportation in prior FAA grant exemptions. 

Specifically, all of the proprietary designs listed here are smaller, lighter, and have stronger built-in safety protocols, while 

retaining similar operational capabilities to those of the custom-built UA listed in the request for exemption granted to 

RKG Media (Exemption No. 11332, Regulatory Docket No. FAA-2015-0010).
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III. Specific sections of 14 C.F.R. from which UCI seeks relief.

• 14 CFR 21, Subpart H – Certification procedures for products and parts

• 14 CFR 45.23 – Display of marks; general

• 14 CFR 61.23(a) and (c) – Medical certificates: Requirement and duration.

• 14 CFR 61.101(e)(4) and (5) – Recreational pilot privileges and limitations.

• 14 CFR 61.113 – Private pilot privileges and limitations: Pilot in command

• 14 CFR 61.315(a) and (c) – What are the privileges and limits of my sport pilot certificate?

• 14 CFR 91.7 – Civil aircraft airworthiness

• 14 CFR 91.119 – Minimum safe altitudes: General

• 14 CFR 91.121 – Altimeter settings

• 14 CFR 91.151(a)(1) – Fuel requirements for flights in Visual Flight Rules (VFR) conditions

• 14 CFR 91.405(a) – Maintenance required

• 14 CFR 91.407(a)(1) – Operation after maintenance, preventative maintenance, rebuilding, and alteration

• 14 CFR 91.409(a)(1) and (2) – Inspections

• 14 CFR 91.417(a) and (b) – Maintenance records

IV. Extent of relief sought

14 CFR 21, Subpart H- Certification procedures for products and parts

Extent of relief sought: Unnecessary if Secretary of Transportation determines that the aircraft listed in this request meet 

the conditions of Section 333. 

14 CFR 45.23 – Display of marks; general

Extent of relief sought: In accordance with previous decisions, UCI requests that the FAA grants an exemption from this

regulation requiring aircraft to bear N-number markings that are as large as practicable in accordance with 14 C.F.R. Par 

45, Subpart C. N-number markings size and placements as required in the regulation are impractical.

14 CFR 61.23(a) and (c) – Medical certificates: Requirement and duration.

Extent of relief sought: In accordance with previous decisions, UCI requests that the FAA grants an exemption from this

regulation requiring an sUAS PIC maintain a medical certificate. UCI’s PIC does not have a medical certificate but does 

have a valid driver’s license.

14 CFR 61.101(e)(4) and (5); 14 CFR 61.113 – Recreational and Private pilot privileges and limitations

Extent of relief sought: In accordance with previous decisions, we request that the FAA grants an exemption to UCI from 

these regulations requiring an sUAS PIC maintain a commercial pilot’s license. UCI’s PIC has a private pilot’s license.

14 CFR 61.315(a) and (c) – What are the privileges and limits of my sport pilot certificate?

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from this 

regulation forbidding individuals with a sport pilot’s certificate from serving as PIC for the purpose of commercially 

operating sUAS. UCI anticipates future need for an individual with a sport pilot certificate to serve as PIC.

14 CFR 91.7 – Civil aircraft airworthiness

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from this

regulation requiring an airworthiness certificate for sUAS civil aircraft. Considering the size, weight, and limited use of 

the sUAS listed in this request, airworthiness certificates as defined in this regulation are unnecessary.

14 CFR 91.119(c) – Minimum safe altitudes over other than congested areas.

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from this 

regulation requiring minimum altitude for flight of sUAS in “other than congested areas.” Per previous decision, 

commercial sUAS operations are forbidden above 400 ft AGL, which is below the minimum altitudes defined in this 

regulation, rendering it moot.
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14 CFR 91.119(b) – Minimum safe altitudes over congested areas

Extent of relief sought: we ask that the FAA grants an exemption to UCI from this regulation requiring minimum altitude 

for flight of sUAS in “congested areas” specifically for our proprietary TUAV models. The TUAV models are uniquely 

designed to maintain a steady, near-motionless hover over a fixed point collecting data. Due to the power cable tethering 

the UA to the ground, these devices cannot fly from point-to-point as traditional sUAS are designed to. Furthermore, UCI 

has established numerous safeguards and protocols to facilitate the safe operation of the TUAV models in congested 

areas. UCI believes these limitations and safeguards will offset any potential danger presented by operating the TUAV 

models in the congested or urban environments.

14 CFR 91.121 – Altimeter settings

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from this 

regulation. All UA operated by UCI have on-board autopilots which will maintain altitude through a combination of GPS 

triangulation and use of an onboard inertial measurement unit. Furthermore, barometric sensors will provide the PIC with 

accurate altitude telemetry readings to facilitate manual adjustments where necessary.

14 CFR 91.151(a)(1) – Fuel requirements for flights in Visual Flight Rules (VFR) conditions

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from this

regulation as the specified minimum fuel requirements exceed the capacity of most commercially available small UA. 

Instead, as part of our standard safety protocol and pre-flight procedures, the onboard auto pilot of all small UA operated 

by UCI will have a failsafe protocol which will automatically land the UA in a safe manner should power levels drop 

below a pre-determined point. Furthermore, the PIC will confirm before every flight that the primary power supply for the 

UA in question is fully charged to cover the anticipated operational duration. 

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) – Maintenance and inspection

Extent of relief sought: In accordance with previous decisions, we ask that the FAA grants an exemption to UCI from 

these regulations covering maintenance and inspection requirements. Due to the small size and nature of sUAS, the 

detailed maintenance and inspection requirements outlined in the above regulation would be unnecessary. Furthermore, 

the UCI UA Flight Safety Manual lays out a standard, periodic maintenance plan that will be sufficient to comply with 

safety requirements established by the FAA.

V. Why granting the exemption will not adversely affect safety

Granting the requested exemptions to UCI for commercial operation of sUAS will not adversely impact public safety for a 

number of reasons. 

General Safety Considerations

The FAA has recognized in previous grants of exemption the inherent increase in safety the use of sUAS provide to both

the operator and the general public. The use of sUAS by UCI will improve safety because our UA:

• are smaller and lighter than any conventional manned aircraft,

• contain far less (if any) combustible fuel and produce fewer emissions,

• have no on-board crew or passengers who may be put at risk in the event of a catastrophic system failure,

• can be brought to and launched at the operation site, negating the need for flights to and from airports or similar 

launch facilities.

National Security Considerations

In the FAA’s decision regarding the exemption request made by Douglas Trudeau (Docket #: FAA-2014-0481/ 

Exemption #: 11138) the FAA stated it requires operators of commercial sUAS to maintain pilot certificates in order to (1)

meet the statutory requirements established under 49 USC § 44711 and (2) to ensure sUAS operators undergo a security 

screening by the Department of Homeland Security required for all certificated airmen.

Regarding the first point, UCI’s Chief Pilot, James Remenick, holds a Private Pilot license issued in February 2010 and a 

current driver’s license from the District of Columbia. Additionally, Mr. Remenick holds a Restricted Radiotelephone 
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Operator’s license. Regarding the second point, all UCI employees are required to pass a government background check 

as a matter of company policy. 

Operational Safety Considerations

Maintaining a safe working environment – whether in the office, in the lab, or out in the field – is UCI’s highest priority 

and this emphasis on safety extends to our operation of sUAS. UCI has established a rigorous set of safety protocols 

covering all aspects of our sUAS projects: pre-flight, active flight operations, post-flight, maintenance, and training. These 

protocols are outlined in the attached Flight Safety Manual. 

UCI has also incorporated or utilized existing safety features on the sUAS we operate. These include: limiting all UCIoperated UA to a maximum allowed distance from point of take-off no more than 300 meters; limiting the TUAV models 

to a maximum allowed distance from point of take-off no more than 3 meters; utilizing the power cable on the TUAV 

models as a tether, further limiting their operational range; setting all UCI-operated UA to be flown exclusively in “GPS 

mode;” and establishing reserve power thresholds on all UCI-operated UA that will trigger an automatic, and immediate 

safe landing should that threshold be reached.

Finally in order to further ensure safe sUAS operations, UCI proposes to adopt the following conditions and limitations:

1. Any UCI-operated UA will weigh less than 55 pounds, including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA will not be operated at a speed exceeding 50 knots or the maximum operating airspeed recommended by 

the manufacturer, whichever is lower. 

4. The UA will 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 FAAissued 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. The UCI Flight Manual, Flight Log, Safety Checklist, and a copy of the grant of exemption will be accessible to 

the PIC during UAS operations and made available to the Administrator upon request.

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

will 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. UCI will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components.
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12. Each UAS operated under this exemption will comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC will 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 

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 will 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 will 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 will 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 will return to a pre-determined location within 

the private or controlled-access property.

19. The PIC will 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. All operations shall be conducted in accordance with an ATO-issued COA. The 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 will 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 will 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 conducted closer to nonparticipating persons (persons other than the PIC or VO), vessels, 

vehicles, and structures, than the minimum distance requirements of § 91.119 (b) and (c), must be conducted 
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using a tether. The operator must ensure that nonparticipating persons remain at least 20 feet away from the 

maximum distance the UAS can travel. If a situation arises where nonparticipating persons comes with 20 feet 

from the maximum distance the UAS can travel, flight operations must cease immediately.6 The PIC must make a 

safety assessment of the risk of operating closer to those objects and determine that it does not present an undue 

hazard. 

27. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this 

exemption.

28. 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.

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

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

VI. Why granting this relief would be in the public interest

The public interest will be served by granting the requested exemptions to UCI for commercial operation of sUAS.

Congress has established a national policy that favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this request. Granting this Petition for Exemption helps fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's assessment of whether certain UAS may 

operate safely in the NAS before completion of the statutorily required rulemaking. 

Additionally, as established in the previous section, the use of sUAS in place of traditional aircraft will greatly increase 

public safety by decreasing the risks associated with traditional aircraft. Further, replacing traditional aircraft will benefit 

public health by reducing exposure to potentially toxic fumes from engine exhaust and significantly reducing the noise 

level associated with these operations.

Another benefit to the public would be the reduced cost associated with sUAS operations when compared to traditional 

aircraft. By almost every measure, it is far cheaper to operate an sUAS than a traditional aircraft. Many of UCI’s clients 

are government agencies including the Coast Guard, the Department of Homeland Security, and the Department of 

Defense. Thus, the potential reduction in use of traditional aircraft by these and other agencies will save taxpayer dollars.

Finally, all UCI UAS operations will be conducted in accordance with applicable federal, state, or local laws regarding 

privacy. All operations will be conducted over private, controlled-access property with permission from the land owner or 

authorized representative. 

VII. Summary to be published in the Federal Register

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:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:

21, Subpart H; 45.23; 61.23(a) and (c); 61.101(e)(4) and (5); 61.113; 61.315(a) and (c); 91.7; 91.119; 91.121;

91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b)

The exemption will enhance safety by reducing risk to the general public and property owners from the 

substantial hazards associated with using conventional fixed-wing aircraft or, rotorcraft for aerial data collection.
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VIII. List of attached supporting documents

• UCI UA Systems Manual

• UCI UA Flight Safety Manual

o UCI UAV Safety Checklist

o UCI UAV Flight Checklist

o UCI UA Flight Log Template

o UCI UA Maintenance Log Template

o UCI UA Training for PIC

o AMA Aircraft Safety Code

• Photocopies of James Remenick’s private pilot’s license, driver’s license, and restricted radiotelephone operator’s

license

UCI submits these supporting materials as confidential documents pursuant to 14 C.F.R. § 11.35(b), as the materials 

contain confidential commercial and/or proprietary information that UCI has not and will not share with others. 

Additionally, these documents contain operating conditions and procedures that are not generally available to the public 

and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

IX. Conclusion

UCI hereby submits a Petition for Exemption from the regulations stated above for the purpose of safely and lawfully 

operating sUAS for commercial purposes, in accordance with Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. § 11.61. The characteristics and capabilities of the sUAS UCI intends to use, and the manner and 

purpose for which we intend to operate them, fulfills all requirements established by Section 333 as determined by the 

Secretary of Transportation. By granting this petition, the FAA Administrator will be fulfilling the Congressional mandate 

to “safely accelerate the integration of civil unmanned aircraft systems into the national airspace system.” We thank you 

for your prompt consideration of this request, and should you have any questions or require any additional materials, 

please do not hesitate to contact us.