June 30, 2015

Exemption No. 11949

Regulatory Docket No. FAA–2015–1416

Mr. Shaun Galang

Cedarmeade Studios, LLC

429 Beechcroft Road

Winchester, VA 22601

Dear Mr. Galang:

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 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Cedarmeade Studios, LLC (hereinafter petitioner or operator) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct real estate/ 

architecture, marketing, surveying/ mapping, industrial surveying, sporting events, and special 

events/ festivals operations.

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 is a 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, Cedarmeade Studios, LLC 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) 

 

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.
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and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

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

Conditions and Limitations

In this grant of exemption, Cedarmeade Studios, LLC 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 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 

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

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

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.
5

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 

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.
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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 

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

contained on the NTSB Web site: www.ntsb.gov.
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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.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Tuesday, April 21, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, DC 20590

by/for Cedarmeade Studios, LLC

429 Beechcroft Road 

Winchester, VA 22601 

 

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam, 

This petition is being submitted with no legal counsel or consulting services.

This document constitutes an exemption Request under Section 333 of the 

FAA Modernization and Reform Act of 2012 for Aviation Unmanned to 

perform Aerial Photography by/for Cedarmeade Studios, LLC. The main use 

of this UAS would be obtaining aerial video and still images for clients 

(categories listed below) and obtaining aerial still images for sale to the 

general public through online galleries. The UAS systems that I plan to use is 

a DJI Inspire 1 and will be referenced in this document and also in the 

attached user manual. 

The requested exemption would permit Cedarmeade Studios, LLC to pursue 

its commercial interests in providing services to clients using a small 

advanced UAS in the following areas: 

• Real Estate/Architecture 

• Marketing

• Surveying/Mapping 

• Industrial Surveying

• Sporting Events 

• Special Events/Festivals 

Page 1 of 8
Regulations from which exemption is requested: 

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.401 – 91.417

Unmanned Aircraft System

UAS are often seen as superior to helicopters as an aerial video gathering 

platform due to the smaller devices, more affordable equipment and 

personnel cost, reduced noise and as such, a much smaller environmental 

impact which promotes public safety.

Cedarmeade Studios, LLC is petitioning for an exemption to operate a DJI 

Inspire 1 with a built-in stabilized HD camera and the following GPS safety 

features: 

• Restricts the height above ground level (AGL) to a specified usergenerated height. 

• Restricts the radius of flight from the ground station to a user-generated 

radius. 

• Restricts operations within designated Class B, C and D airspace 

including a no-fly zone feature.

The DJI Inspire 1 also has a failsafe function that is triggered in the event 

communications are lost between the UAS and the main controller 

transmitter. In the unlikely event this occurs, the UAS will return to its point 

of takeoff and land safety. If communications are restored, the PIC can 

regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards (AC 

91-57) as set below:

1. The petitioner will only operate its UAS in line-of-sight of a pilot and/or 

observer and will operate at sites that are ‘sufficient distance’ from 

populated areas within the sterile area described in the FOPM. Such 

operations will ensure that the UAS will “not create a hazard to users of 

the national airspace system or the public.” The orientation of flights will 

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be such that the pilot in command (PIC) always has a visual on the rear 

mounted LED flight Indicator. Additional safety features on the DJI 

Inspire 1 include, return to home, low battery energy level, enhanced 

failsafe along with operating in the less populated 5.8 GHZ frequency 

range. 

2. When flying the UAS within three (3) miles of an airport, airport 

operators will be notified and the operator will give the right-of-way to 

avoid flying in the proximity of full-scale aircraft. 

3. Pre-flight inspection would be checking battery condition/level in both 

the transmitter and UAS, a visual/operational check of the propellers, a 

visual/operational check of the aircraft, a visual/operational check of the 

motors, a full compass and IMU calibration, a visual/operational check of 

the transmitting radio control unit, a visual/operational check of the 

camera and gimbal unit and a visual/operational check of the vision 

positioning system. A check for power-lines, antennas and other 

overhead objects would also be performed. Wind conditions would be 

monitored and be a factor for flying.

4. The radio frequency of the DJI Inspire 1 is in 5.725~5.825 GHz range 

the FC350 camera 2.400~2.483 GHz. Maximum take-off weight 

approximately 3000g. Max Ascent/decent speed 5 m/s. Maximum flight 

Velocity 22 m/s. The UAS operated by the petitioner weighs less than 

15 pounds, including all payload (i.e. camera, lens, and stabilized 

gimbal).

5. The PIC will be only myself and I have a minimum of 55 hours flying 

time with DJI equipment, approximately 10 of those hours with this 

specific model (DJI Inspire 1). I’m a freelance video producer and 

photographer with over 10 years of photography/videography 

experience. Testing, updating and programming the DJI Inspire 1 

firmware would be done on a monthly schedule. 

6. Flights will be terminated when battery energy levels reach 25%, 

allowing sufficient reserve flight time to safely land the UAS.

7. The UAS will be programmed so it will not be operated at an altitude 

that exceeds 400 feet AGL, and not more than 150 feet above a 

significantly elevated geographic position from which videography/

photography is planned. 

8. I’m in good medical health and sound mental health with no arrests or 

felonies. 

9. The intended use of this DJI Inspire 1 is to supplement my existing 

photography business with aerial photographs and video. The aerial 

vantage point/perspective would allow my studio to provide a service to 

local advertising clients that is different/unique and competitive. 

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10. All photo/video flights would have the date, time, GPS coordinates along 

with the camera metadata recorded in an in-app flight log on the mobile 

device serving as the in-flight monitor. This flight log records flight path, 

altitude, flight time, number of images shot, amount of video shot, date, 

time, and total flight distance. Each individual flight has the capability of 

playing back (in-app) in real time and is synced across devices via DJI’s 

in-app User Center. 

11. Given the small size of the UAS and the restricted sterile environment 

within which it will operate, Cedarmeade Studios, LLC’s operations will

adhere to the Reform Act’s safety requirements. 

12. The DJI Inspire 1 will never be flown in the flight path of manned 

aircraft. with the first condition listed, always keeping a visual line of 

sight, being of utmost importance to providing a significant level of 

public safety.

I respectfully request exemption under Section 333 to enable Cedarmeade 

Studios, LLC to operate efficient, limited, low-risk commercial UAS 

operations for the activities stated respecting at all times the space and 

privacy of citizens and property while keeping airspace safe. 

Respectfully,

Cedarmeade Studios, LLC

429 Beechcroft Road 

Winchester, VA 22601 

Home/Cell: (540)533-3775 

www.cedarmeadestudios.com

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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

Cedarmeade Studios, LLC requests an exemption from the following 

regulations as well as any additional regulations that may technically apply 

to the operation of the UAS System: 

14 CFR Part 21, Airworthiness Certificates 

This part establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop airworthiness 

standards for Unmanned Aerial Systems, we request an experimental 

certificate be issued for the DJI Inspire 1 under either, or both, of the 

following provisions: 

21.191 Experimental certificates. Experimental certificates are issued for the 

following purposes:

(a) Research and development. Testing new aircraft design concepts, 

new aircraft equipment, new aircraft installations, new aircraft operating 

techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness regulations 

including flights to show compliance for issuance of type and supplemental 

type certificates, flights to substantiate major design changes, and flights to 

show compliance with the function and reliability requirements of the 

regulations.

Since the experimental certificate can be used for commercial purposes such 

as market surveys, sales demonstrations, and customer crew training, we 

would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry 

fuel, and will only fly under strict operational requirements. Combined with 

the UA's light weight, being constructed primarily of carbon fiber and plastic, 

we propose that the UA will be at least as safe, if not safer, than a 

conventionally certificated aircraft performing the same mission. If an 

experimental airworthiness certificate is not appropriate for this application, 

then we request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent 

level of safety outlined in the previous paragraph. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks 

These regulations provide that each aircraft must display "N" and the 

aircraft's registration number in letters at least 3 inches high. Additionally, 

the aircraft must display the word "EXPERIMENTAL" in letters at least 2 

inches high near the entrance to the cabin, cockpit, or pilot station. The UAS 

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does not have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by the FAA. 

We propose to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" in a placard on the top of the aircraft where the PIC, VO 

and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous 

paragraph will provide the aircraft's registration information at the ground 

station. Finally, we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in 

letters adhering to the specifications of at least 2 inches and less than 6 

inches. Since the aircraft will operate in close proximity (not more than 1/2 

NM) to the ground station, the banner should be visible to anyone that 

observes the aircraft and chooses to investigate its point of origin. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an 

airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard 

requirements. 

This regulation provides that no person may operate an aircraft unless a 

current, approved flight manual is in the aircraft. We assume that the intent 

of this requirement is to ensure that flight manual information is available to 

the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation, 

the documentation would not be available to the crew during flight 

operations. To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that the manual be kept in a digital format on a mobile 

device at the ground station. A hard copy will also be kept inside the 

equipment carrying case (in the event the digital version is unavailable) and 

available to the crew at the ground station anytime the aircraft is in, or 

preparing for, flight. 

91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot 

be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Since the typical mission of the UAS would be photography or survey of 

persons, vessels, vehicles or structures it would, at times, be necessary to 

operate closer than 500 feet to the items listed. Operations will only be flown 

over property or persons where permission has been obtained and careful 

Page 6 of 8
pre-planning has been performed. The aircraft will be operated at a low 

altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. Therefore we maintain that 

due to the small size of the UAS, the hazard to persons, vehicles and 

structures is minimal compared to manned aircraft, which should be 

considered in granting the exemption. 

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by 

reference to an altimeter setting available within 100 NM of the aircraft. The 

UAS will always fly below 400 feet AGL and will not need to maintain cruising 

altitudes in order to prevent conflict with other aircraft. An Above Ground 

Level altimeter measurement above the takeoff point is transmitted via radio 

from the UAS on-board computer to the display screen held by the PIC, 

providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane 

under day-VFR conditions unless there is enough fuel to fly to the first point 

of intended landing and to fly after that for at least 30 minutes and nightVFR conditions an additional 45 minutes. We feel the intention of this 

paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UAS is battery operated and the maximum duration of flight 

from a single battery charge is approximately 15 minutes with an additional 

25% reserve. Since the aircraft will never fly more than 1/2 NM from the 

point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. The PIC has a 

visual reference to the remaining battery energy level and an estimated 

“return to home” energy requirement. We request an exemption to the word 

"fuel" and ask for an equivalent interpretation with the word "energy". 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. 

The regulation provides that an airworthiness certificate, with the 

registration number assigned to the aircraft and a registration certificate 

must be aboard the aircraft. Additionally, subparagraph (b) provides that the 

airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew." At a maximum gross weight of 5.3 

pounds, the UAS is too small to carry documentation, does not have an 

entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located 

with the crew at the ground control station and available for inspection upon 

request. In order to identify the aircraft, we propose that the information 

Page 7 of 8
found on airworthiness and registration certificates be permanently affixed to 

the aircraft containing such information plus the word "EXPERIMENTAL" to 

satisfy the requirement of 14 CFR 45.23. 

14 CFR Subpart E 91.401- 91.417 - Maintenance, Preventive 

Maintenance, Alterations

The regulation provides that the operator is primarily responsible for 

maintaining the aircraft in an airworthy condition, including compliance with 

part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC perform 

maintenance and inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed 

inspections after every two hours of flight. Maintenance performed by the 

PIC is limited to repairing small cracks, replacing a propeller, checking 

electrical connections and updating software and firmware for the on-board 

computer. All other maintenance will be performed by the manufacturer or a 

manufacturer-designated repair facility. The PIC will document work 

performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent 

level of safety. 

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