November 6, 2015 

U.S. Department of Transportation 

Document Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam: 

SUMMARY

MEADORS INC. (“Petitioner”), through the instant petition (the “Petition”), seeks 

exemption from the regulations listed below, to operate Unmanned Aircraft Systems, pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 (the “FMRA”). This 

exemption will permit Petitioner to operate a UAS for the commercial purpose of conducting 

aerial photography, videography, surveying, and data collection in compliance with the 

conditions outlined below or as established by the Federal Aviation Administration (“FAA”). 

BACKGROUND 

The specific exemptions below are being requested because: (1) existing regulations will 

burden Petitioner, (2) Petitioner can provide a level of safety that is equal or greater than those 

provided by the existing rules, and (3) the request is in the public interest. 

A. Contact Information of Petitioner 

The name and address of Petitioner is: 

MEADORS INC.

c/o James Webb, Director of Estate Management & Maintenance 

P.O. Box 21758 

Charleston, South Carolina 29413 

(843) 708-7153 

jim@meadorsinc.com 

B. Description of Petitioner 

Petitioner offers architectural design, construction, millwork and cabinetry, conservation 

and maintenance services. Petitioner will use a UAS to take photographs, video, surveys and 

collect data relating to its business operations. Generally, Petitioner will use said video, 

photographs, surveys, and data to document the progress of the projects it is working on for the 
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purpose of keeping detailed records and enhancing its ability to evaluate the quality and safe 

completion of the project. Petitioner will also use some of the images and video captured of 

completed projects to market its services. The use of a UA will enhance Petitioner’s services to 

its clients and the public by providing a more efficient, safer method as further described in this 

Petition. 

C. Summary Process 

Petitioner makes this request under the “summary grant” process that the FAA 

announced in April 2015.1This request is similar to a number of recent grants of exemption, 

including: Exemption No. 12995 to Dragonfly Live, LLC (FAA-2015-2788) and Exemption 

No. 12965 to Lee Lewis Construction, Inc. (FAA-2015-2737). 

D. Specific Regulations From Which Exemption is Sought2

Regulations from which the exemption is requested: 

• 14 C.F.R. part 21, Subpart H 

• 14 C.F.R. § 45.23 (b) 

• 14 C.F.R. §§ 61.101(e)(4) and (5) 

• 14 C.F.R. §§ 61.113 (a) & (b) 

• 14 C.F.R. § 61.23(a) 

• 14 C.F.R. § 61.315(a) 

• 14 C.F.R. § 91.7 (a) 

• 14 C.F.R. § 91.9 (b) (2) 

• 14 C.F.R. § 91.103 

• 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. § 91.405 (a) 

• 14 C.F.R. § 407 (a) (1) 

• 14 C.F.R. § 409 (a) (2) 

• 14 C.F.R. §§ 417 (a) & (b) 

E. Pilot In Command Overview 

Any Pilot In Command (“PIC”) will be required to hold an airline transport, commercial, 

private, recreational or sport pilot certificate, and a current FAA airmen medical certificate or a 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

 

1 See FAA Summary Grants Speed UAS Exemptions, https://www.faa.gov/news/updates/?newsId=82485. 

2

The specific reasons the requested exemptions should be granted are addressed later in this Petition. 
Page 3 

possession or the Federal government. The PIC will also be required to meet certain flight-hour 

and currency requirements and demonstrate the ability to safely operate the UAS in a manner 

consistent with the operation specifications, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and structures. 

AUTHORITY FOR EXEMPTIONS

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the FMRA. The FMRA directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (the “NAS”) before completion of the rulemaking required under Section 332 of the 

FMRA. In making this determination, the Secretary is required to determine which types of 

UASs do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

 

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

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

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

(See FMRA, Section 333(a).) 

Lastly, if the Secretary determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system.” (See FMRA, Section 333(c).) 

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

This statutory authority by its terms includes exempting civil aircraft – including UASs – from 

the requirement that civil aircraft must have a current airworthiness certificate. 

Petitioner interprets this provision to place the duty on the Administrator not only to 

process applicants for exemptions under section 333, but to also craft conditions for the safe 

operation of the sUAS, if it should be determined that the conditions set forth herein do not fulfill 

the statutory requirements for approval. 

Given the small size of the UASs involved, and the restricted environment within which 

they will operate, Petitioner falls squarely within the zone of safety (an equivalent level of 

safety) in which Congress envisioned that the FAA should, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size of the UASs and the 

restricted areas in which the relevant UASs will operate, approval of the application presents no 

national security issue. 

Given (1) the clear direction in Section 333 of the FMRA; (2) the authority contained in 

the Federal Aviation Act; (3) the strong equivalent level of safety surrounding the proposed 

operations; and (4) the significant public benefit, including enhanced safety, reduction in 

environmental impacts (reduced emissions and chemical spills), and (5) previous exemptions 

granted allowing UASs for aerial photography, videography, surveying and data collection, the 
Page 4 

grant of the requested exemptions in this Petition is in the public interest and supported by the 

FMRA. Accordingly, the applicant respectfully requests that the FAA grant the exemptions as 

set forth in this Petition. 

AIRCRAFT DESCRIPTION, PERFORMANCE, AND MAINTENANCE 

Petitioner will operate a DJI Phantom 3 Advance, DJI Phantom Professional and DJI 

Inspire 1 (collectively, the “sUASs”), which are multirotor aircraft weighing less than 7 pounds. 

The DJI Phantom 3 Advance and Phantom 3 Professional (collectively, the “Phantoms”) weigh 

approximately 2.82 pounds, while the DJI Inspire 1 (the “Inspire”) weighs approximately 6.47 

pounds. The Phantoms have the ability to operate under normal conditions at a speed of no more 

than 16 m/s (approximately 31 knots), while the Inspire has the ability to operate under normal 

conditions at a speed of no more than 22 m/s (approximately 43 knots). The Phantoms and 

Inspire have the capability to hover and move in the vertical and horizontal plane 

simultaneously. The sUASs will operate only in the PIC’s or Visual Observer’s (“VO”) visual 

line of sight at all times, and includes automatic safety features as described in the User Manuals. 

The sUASs are equipped with a flight recorder that automatically records flight telemetry, 

aircraft status information and other parameters. 

The sUASs are also equipped with GPS, a Vision Positioning System, and a Return-toHome feature. Return-to-Home is an effective safety measure and has three forms: (1) Smart 

RTH, (2) Low Battery RTH, and (3) Failsafe RTH. 

1. Smart RTH allows the PIC to initiate said mode calling the sUAS back to the 

recorded home point. This could be used if the PIC, for whatever reason, deems that the 

operation cannot continue, or for any other reason the PIC would require the sUAS to 

return to the home point without the use of the remote controller. 

2. Low Battery RTH notifies the PIC when the battery is at depleted levels and 

further operation of the sUAS may affect the ability to safely complete the operation. If 

no action is taken by the PIC within 10-seconds, the sUAS will automatically return to 

the home point. 

3. Failsafe RTH automatically initiates after signal with the remote controller is lost 

for more than three seconds, at which time the sUAS will automatically return to the 

home point. 

Maintenance will be performed regularly as detailed in this Petition, the User Manuals, 

Safety Guidelines and as required by any grant of exemption by the FAA. Moreover, all 

maintenance will be recorded in the Maintenance Log attached and/or submitted with this 

Petition. 

A further and more in-depth description of the sUASs and related performance, operating 

procedures and maintenance can be found in the User Manuals and Safety Guidelines attached 

and/or submitted with this Petition.3

 

3

 The User Manual PDF file for the Inspire was too large to submit via the online docket. A copy can be found at: 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf. 
Page 5 

RULES FROM WHICH EXEMPTION IS SOUGHT AND 

REASONS EXEMPTIONS SHOULD BE GRANTED

A. 14 C.F.R. Part 21, Subpart H: Airworthiness certificates 

Subpart H establishes the procedural requirements for the issuance of airworthiness 

certificates. Given the size and limited operating area associated with the sUAS to be utilized by 

Petitioner, an exemption from 14 C.F.R. Part 21, Subpart H, meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the FMRA. 49 U.S.C. § 44701(f) and 

Section 333 of the FMRA 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 UASs. 

The sUASs to be used by Petitioner will not carry persons or property, will not carry 

combustible fuel, weigh less than 7 pounds, and will only fly under strict operational 

requirements set forth in this Petition and by any exemption granted by the FAA. 

An analysis of these criteria by the FAA has routinely found that UASs 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 manned aircraft operating with an airworthiness 

certificate. 

B. 14 C.F.R. § 45.23(b): Marking of the aircraft 

Section 45.23(b) requires that: “light-sport category aircraft or experimental or 

provisionally certified aircraft . . . 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.” 

The sUASs have no entrance, cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Moreover, given the size of the sUASs, the two inch lettering will 

be impossible. Petitioner proposes to achieve an equivalent level of safety by including the word 

“EXPERIMENTAL” in the largest practicable lettering on the sUASs, where the PIC, VO and 

any other person in the vicinity of the aircraft while preparing for launch will be able to see such 

designation. The sUASs will be identified by serial number, registered, and have N-Number 

markings in lettering as large as practicable. 

C. 14 C.F.R. §§ 61.101(e)(4) & (5): Recreational pilot privileges and limitations 

Sections 61.101(e)(4) & (5) prohibit persons with a recreational pilot certificate from 

acting as a PIC of an aircraft for compensation or hire and in furtherance of a business. An 

exemption is therefore required. The FAA has routinely found that PICs holding a minimum of a 

sport or recreational pilot certificate and a valid U.S. driver’s license are eligible to operate 

UASs for a commercial purpose. 
Page 6 

An equivalent level of safety will be achieved by requiring that the PIC meet minimum 

flight-hour and currency requirements, demonstrate the ability to safely operate the sUASs in a 

manner consistent with the User Manuals, Safety Guidelines, and any grant of exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles, and structures where necessary. 

D. 14 C.F.R. §§ 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command 

 

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. The 

proposed operations can achieve an equivalent level of safety because the sUASs will not carry a 

pilot or passengers, and PICs will be required to meet certain flight-hour and currency 

requirements and demonstrate the ability to safely operate the sUASs in a manner consistent with 

the User Manuals, Safety Guidelines, and operation specifications, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures. 

E. 14 C.F.R. § 61.23(a): Operations requiring a medical certificate: Requirements and 

duration 

 Section 61.23(a) requires PICs of any flight for compensation or hire to hold a 

comprehensive FAA issued medical certificate. In granting exemptions, the FAA has routinely 

found that a person holding a U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession or the Federal government, operating UASs will not 

adversely affect safety. Similarly, the grant of an exemption to Petitioner will not adversely 

affect safety because all PICs will have – at a minimum – a U.S. driver’s license, will exercise a 

level of care as described throughout this Petition, and will abide by any and all other conditions 

provided in any exemption granted by the FAA. 

F. 14 C.F.R. §§ 61.315(a) and (c): What are the privileges and limits of my sport pilot 

license? 

 Section 61.315(a) and (c) restrict sport pilots from acting as the PIC of any flight for 

compensation or hire, or in furtherance of any business. The FAA, however, has provided that 

PICs holding a sport or recreational pilot certificate and a valid U.S. driver’s license are eligible 

to operate UASs for a commercial purpose. All of Petitioner’s PICs will be required to have – at 

a minimum – a U.S. driver’s license, meet minimum flight-hour and currency requirements, 

demonstrate the ability to safely operate the sUAS in a manner consistent with the User Manuals, 

Safety Guidelines, and any grant of exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, and structures where necessary. 

G. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness 

Section § 91.7(a) requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Since there will be no airworthiness certificate issued for the aircraft should 
Page 7 

this request for exemption be granted, the PIC will ensure that the sUASs are in airworthy 

condition based upon its compliance with the User Manuals, Safety Guidelines and review of the 

Maintenance Log prior to every flight. The PIC will conduct a pre-flight inspection to determine 

that the sUAS being used is in condition for safe flight. During the pre-flight inspection the PIC 

will take into account any inoperable components, items, or equipment. If the PIC discovers a 

condition affecting the safe operation of the sUAS, the aircraft will not be operated until the 

necessary maintenance is performed and the sUAS is in safe flying condition. 

Given the size of the aircraft and the requirements contained in the User Manuals and 

Safety Guidelines for maintenance and use of safety checklists prior to each flight, an equivalent 

level of safety will be achieved. 

H. 14 C.F.R. § 91.9(b)(2): Civil aircraft flight manual, marking and placard 

requirements 

Due to the small size and configuration of the sUASs, and the fact that there is no pilot, 

crew, or passengers onboard, it is not possible to place or carry such a flight manual on the 

aircraft. The equivalent level of safety will be maintained by keeping the User Manuals, Safety 

Guidelines and any other operating documents at the Ground Control Station where the PIC, VO 

or any other person involved with the operation will have immediate access to said documents. 

I. 14 C.F.R. § 91.103: Preflight action 

Section 91.103 requires each PIC, prior to beginning a flight, to become familiar with all 

available information concerning that flight, including, runway lengths at airports of intended 

use, and the following takeoff and landing distance information. This is not applicable to the 

operations proposed since no airports, or runways will be necessary. 

To provide an equivalent level of safety, each individual operation will have a flight plan 

that will be thoroughly reviewed with the PIC and VO. The PIC and VO will review current and 

future weather forecasts for the vicinity that the operation is to take place, flight battery 

requirements, aircraft performance data, and any other relevant information to the operation. The 

PIC and VO will also review all site-specific conditions in preflight procedures and ensure that 

no obstacles or obstructions to the operation exist, or how such obstacles can be avoided without 

compromising the safe completion of the operation. No operation will take place unless the PIC 

determines the same can be completed safely. Lastly, the PIC and VO will ensure all required or 

suggested pre-flight actions are followed in the User Manuals, Safety Guidelines and any grant 

of exemption. 

J. 14 C.F.R. § 91.109: Flight instructions; Simulated instrument flight and certain 

flight tests 

Section 91.109 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. 
Page 8 

All subparagraphs of this section address civil manned aircraft in conjunction with 

training and flight tests. In addition to the sUASs being unmanned and having no combustible 

fuel, by design, the sUASs do not have fully functional dual controls. Flight control is 

accomplished through the use of a remote controller that communicates with the aircraft via 

radio communications. 

The equivalent level of safety is provided by the fact that neither a pilot nor passengers 

will be carried in the aircraft, the size and speed of the aircraft, and the ability to control the 

sUAS via radio signals from the controller. Moreover, any flight instruction taking place would 

be done at a minimum of 500 feet from other people. Flight instruction will only be conducted 

during dedicated training sessions, at which time the sUAS will only be operated an appropriate 

distance from all non-essential persons to the flight instruction. 

K. 14 C.F.R. § 91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of 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. 

The exemption requested herein is for sUASs that fly in a similar manner to a helicopter, 

with vertical takeoff and vertical landing. The sUASs will never operate at an altitude higher 

than 400 feet above ground level (“AGL”) and all operations will occur during daylight hours 

under visual meteorological conditions (“VMC”) only. The sUASs will also remain in the visual 

line of sight of the PIC and/or VO at all times. 

The equivalent level of safety will be achieved given the size, weight and speed of the 

sUASs, as well as the confined location where the sUASs will be 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 any onsite personnel, all affected individuals will be aware of 

the planned flight operations. Moreover, compared to the flight operations of aircraft or 

rotorcraft weighing far more than the less than max 7 pounds of the sUASs that are the subject of 

this Petition, and the lack of combustible fuel, any risk associated with these operations is far less

than similarly situated conventional aircraft. The PIC and VO will also survey the area of 

operation for any potential obstacles or dangers and notify all involved of the potential obstacles 

and how same will be avoided. If the PIC deems the operation cannot be completed safely due to 

any obstacles, the operation will be canceled or aborted. 

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

Section 91.121 requires each person operating the aircraft to maintain cruising altitude by 

reference to certain altimeter settings proscribed therein. 

DJI Phantom 3 and Inspire 1 UAs do not have a typical barometric altimeter onboard, 

however, altitude information will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the 

sUASs to the Ground Control Station for active monitoring of the altitude and flight path. This 
Page 9 

altitude information, combined with each of Petitioner’s PIC’s skilled operation of the sUASs 

within the visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

M. 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 for at least 45 minutes.” 

The battery powering the Phantoms provides approximately 23 minutes of powered 

flight, while the battery powering the Inspire provides approximately 18 minutes of powered 

flight. This would render the sUASs unable to meet the 30 minute reserve requirement. Given 

the confined location of the sUASs within a predetermined operating area and its ability to land 

immediately, an exemption is reasonable. 

An equivalent level of safety can be achieved by the PIC not beginning any operation 

unless (considering wind and forecast weather conditions) there is enough available power for 

the UA to conduct the intended operation and to operate after for at least five minutes or with the 

reserve power recommended by the manufacturer, if greater. In addition, the sUASs have a Low 

Battery Return-to-Home mode as described above. 

N. 14 C.F.R. §§ 91.203(a) & (b): Civil aircraft: Certifications required 

Sections 91.203(a) & (b) require that no person operate a civil aircraft unless it has within 

it an appropriate current airworthiness certificate and an effective U.S. registration certificate. 

The airworthiness certificate must also be displayed at the cabin or cockpit entrance so it is 

eligible to passengers and crew. An exemption is requested because no airworthiness certificate 

will be required if the requested exemption is granted and, furthermore, the sUASs have no 

cabin, cockpit or pilot station and are operated without an onboard pilot, crew or passengers. 

Therefore, there is no ability to place or carry certification and registration documents or to 

display them in the sUASs. 

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

Control Station where the PIC, VO or any other relevant person will have immediate access to 

them. 

O. 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(1) & (2); 417(a) &(b): Maintenance 

inspections 

Section 91.405(a) requires 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 . . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 

91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 
Page 10 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

An equivalent level of safety will be achieved because the sUASs are small in size, will 

operate solely in controlled and predetermined areas, and are not large, complex mechanical 

devices. Petitioner will perform all maintenance and inspections in accordance with the 

manufacturer’s User Manuals and any required manufacturer safety or service bulletins. In 

addition, the PIC will conduct a pre-flight inspection of the sUASs and all associated equipment 

to account for all discrepancies and/or inoperable components. Maintenance will be performed 

and verified to address any conditions potentially affecting safe operation of the sUASs and no 

flights will occur unless and until all flight critical components of the sUAS have been found to 

be in a condition for safe operation. All maintenance will be recorded in the Maintenance Log 

attached and/or submitted with this Petition. A functional flight test will be conducted following 

the replacement of any flight-critical components. Moreover, the operator is the person most 

familiar with the aircraft and therefore is best suited to maintain it in airworthy condition. 

PUBLIC INTEREST 

Granting this Petition will further the public interest by allowing Petitioner to safely, 

efficiently, and economically conduct the operations described in this Petition under certain 

conditions imposed under any grant of exemption. Moreover, the FAA has already approved 

exemptions allowing commercial operations of UASs for aerial photography, videography, 

surveying and data collection, finding that such commercial operations are in the public interest. 

Granting this Petition is in the public interest because: (1) the risk to the public is less 

than when using a manned aircraft for aerial photography, videography, surveying, and data 

collection, (2) congestion to the NAS will be reduced, (3) UASs are efficient and safe, and (4) it 

will benefit the economy. 

A. The Risk to the Public Is Less Than When Using Manned Aircraft 

Manned aircraft, performing these same essential functions, create a greater risk to the 

public because said craft are much larger, have combustible fuel, and carry a human pilot or 

other crew. In contrast, a UA weighing less than a maximum of 7 pounds, powered by batteries, 

and utilizing flight systems such as GPS, VPS, and Return-To-Home, eliminate virtually all of 

that risk given the reduced weight and lack of combustible fuel carried onboard. The sUASs will 

carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. The sUASs do not require an airport or runway to take-off and land, and 

therefore – unlike a manned aircraft – will not need to travel potentially long distances over 

populated areas to arrive at the operation location. 

B. Congestion of the NAS Will Be Reduced 

By reducing the amount of manned aircraft needed to perform aerial photography, 

videography, surveying, and data collection, congestion of the NAS will be reduced. This will 

reduce noise and air pollution, as well as increasing the safety of persons and property in the air 
Page 11 

and on the ground. Furthermore, congestion around airports caused by departing and arriving 

aircrafts will be reduced, as well as air traffic control having to handle fewer aircraft that require

assistance during takeoff, landing and other instances where aircraft require ground control 

assistance. 

C. UASs Are Efficient and Safe 

By using battery power and electric motors, the sUASs produce no air pollution, and are 

a much more environmentally conscious alternative to the aircraft traditionally used for aerial 

photography, videography, surveying and data collection, which can burn approximately 20-30 

gallons of leaded aviation fuel per hour. The sUASs also create far less noise pollution as they 

are propelled by battery powered, electric motors rather than internal combustion engines. 

Most importantly, the sUASs pose far less potential for collateral damage to life and 

property in the air and on the ground compared to a manned aircraft weighing approximately 

6,500 pounds with much greater wingspans, length and combustible fuel capacity. 

D. Use of the UAS Will Benefit the Economy 

Use of UASs will allow United States based companies to remain competitive and 

contribute to growth of the U.S. economy. In addition, due to the rising cost of fuel and the 

Environmental Protection Agency’s regulatory actions seeking to phase out leaded aviation fuel, 

U.S. owned and operated companies must adopt new and alternative methods to remain 

competitive and cost efficient. UASs have a much lower operational cost than manned aircraft, 

which allows companies to conduct a service more cost effectively, and in many instances a 

service that the company would not otherwise be able to offer. UASs will allow companies to 

provide a better, more efficient service to clients, which will free up resources to be used in other 

aspects of a business. The resulting impact of all of this will be greater stability and resources, 

which will benefit the local, state and the national economy overall. 

PRIVACY 

All flights will occur over private property or controlled-access property with the 

property owner’s consent and knowledge. Therefore, any issues with privacy are minimal or, if 

certain operations pose privacy concerns, Petitioner will take special precautions to ensure that 

the privacy of individuals and businesses are not violated. Any commercial operations proposed 

by Petitioner are similar, if not identical, to manned flights whereby aerial photography, 

videography, surveying and data collection have been done for decades. The confined area of 

operation ensures that – unlike manned operations – the sUASs will not have to travel from an 

airport or other takeoff point to the area of operation, and therefore will not flyover property or 

individuals not involved with the operation. 

All images, video, and data collected will be used solely to advance the efficiency and 

quality of services for which Petitioner was hired by its clients, and will not be published or 

shared with anyone other than in the furtherance of said services and with the consent of any 

person depicted therein. 
Page 12 

EQUIVALENT LEVEL OF SAFETY 

Petitioner proposes that the exemptions requested apply to civil aircraft that have the 

characteristics and that operate within the limitations listed herein. These limitations provide for 

at least an equivalent or even higher level of safety than operations under the current regulatory 

structure, because the proposed operations represent a safety enhancement to the already safe 

protocols followed by aerial photography, videography, surveying and data collection operations 

conducted with helicopters and other conventional manned aircraft. The limitations will ensure 

that any risk to the NAS and persons/property on the ground are minimized. 

In addition to any measures described above in this Petition, Petitioner will be bound by 

the following limitations when conducting its UAS operations under any FAA issued exemption: 

 

1. The UA will weigh less than 55 pounds including payload. 

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

In any event, the Phantoms have a maximum speed of 16 m/s (approximately 31 knots), while 

the Inspire has a maximum speed of 22 m/s (approximately 43 knots). Moreover, the UA will not 

be operated at airspeeds greater than the maximum operating airspeed recommended by the 

manufacturer. 

3. The UA will be operated at an altitude of no more than 400 feet AGL. 

4. The UA will be operated within the visual line of sight of the PIC at all times, 

unaided by any device other than corrective lenses. The PIC will be designated before the flight 

and will not transfer such designation for the duration of the flight. 

5. All operations will use a VO. In some circumstances, the VO may be used to 

satisfy the VLOS requirement as long as the PIC maintains VLOS capability. The PIC will be 

responsible for ensuring that the VO can perform the duties required of the VO. 

6. The PIC and VO will be able to communicate verbally at all times. Electronic or 

text messaging will not be permitted. 

7. All operating documents needed to operate the UA and conduct specific 

operations in accordance with any grant of exemption will be accessible during UA operations. 

8. All UAs that undergo maintenance or any alteration affecting the UA’s operation 

or flight characteristics will undergo a functional test flight prior to conducting any operations. 

Functional test flights will be conducted by a PIC with a VO and will be done at least 500 feet 

from other people. Special care will be taken by the PIC to survey the surrounding area of the 

functional test flight to ensure that no undue hazard is posed to persons or property. 

9. Petitioner will maintain and inspect the UA to ensure safe operating condition. 

10. The PIC will conduct a pre-flight inspection to determine that the UA is in 
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condition for safe flight. During the pre-flight inspection the PIC will take into account any 

inoperable components, items, or equipment. If the PIC discovers a condition affecting the safe 

operation of the UA, the aircraft will not be operated until the necessary maintenance is 

performed and the UA is in safe flying condition. The PIC will also take any pre-flight steps 

recommended in the User Manuals and/or Safety Guidelines. 

11. Petitioner will follow the UA’s manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the UA and its components. The UA will 

also comply with any and all manufacturer safety bulletins. 

12. The UA will be operated by a PIC with an airline transport, commercial, private, 

recreational or sport pilot certificate. The PIC will also hold a current FAA airmen medical 

certificate or valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a

territory, a possession of the Federal government. 

13. Petitioner will require any PIC to demonstrate the ability to safely operate the UA 

in a manner consistent with the proposed operations under this Petition and any grant of 

exemption by the FAA, including evasive and emergency maneuvers, and maintaining 

appropriate distances from persons, vessels, vehicles and structures. 

14. No operations of the UA will occur during night and will only be conducted under 

VMC. 

15. No operation will take place within 5 nautical miles of an airport reference point 

(“ARP”) or for airports not denoted with an ARP, the center of the airport symbol, unless a letter 

of agreement with that airport’s management is obtained or otherwise permitted by a COA issued 

to Petitioner. 

16. 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. 

17. In the event the UA loses communications or GPS signal, the UA will return to a 

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

18. The PIC will abort the flight in the event of any unpredicted obstacles or 

emergencies. 

19. The PIC will not begin any operation unless (considering wind and forecast 

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

operation and to operate after for at least five minutes or with the reserve power recommended 

by the manufacturer if greater. 

20. All UAs will be identified by serial number, registered, and have N-Number 

markings in letters as large as practicable. 

21. All operating documents ensuring the safe operation and flight of the UA will be