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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DONALD LINDSAY, Director, FRONTERA UTILITY FLIGHT OPERATIONS CONSULTANTS

HEREBY KNOWN THROUGHOUT THIS DOCUMENT AS “FRONTERA”

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.9(b)(2), 

91.109(a), 91.119, 91.121, 91.151(b), 91.203(a) and (b), 91.405(a) 91.407(a)(1), 91.409(a)(1) & (a)(2), 

AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF MONARCH AND DJI 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 PUBLIC LAW 112-95

Submitted on 6/10/2015

Donald Lindsay, Director

Frontera Utility Flight Operations Consultants

10181 E Running Water Dr.

Gold Canyon, AZ 85118

602 510 5253

don@fronteraflightops.com

www.fronteraflightops.com
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section

SO Safety Observer

SOP Standard Operating Procedures

T&D Transmission/Distribution power lines

UA Unmanned Aircraft

UAV Unmanned Aerial Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Frontera seeks exemption from the requirements of 14 C.F.R 61.113(a) & (b), 91.7(a), 91.9(b)(2), 

91.109(a), 91.119, 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Frontera to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video, photography

and reconnaissance patrol of construction sites, transmission and distribution line and substation 

inspection, pipeline inspection, wind turbine inspection, solar panel inspection, infrared imaging, GIS 

mapping, LIDAR survey, fall protection placement, sock line stringing and other utility flight operations 

in all areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Frontera’s primary mission is to enhance safety in utility flight operations by removing the human factors 

from some of its processes and eliminating exposure to pilots, aircrew and linemen by using advanced 

technology. Also to reduce the environmental footprint in the overall operations of utilities and 

contractors with the additional benefit of cost savings.

There are upwards of 40 missions performed by utility flight operations crews including patrol, 

inspections, setting poles, towers, wire stringing, Human External Cargo/HEC, longline/skid transfer 

operations for crew/material transport to sites and structures using light, medium and heavy rotorcraft.

sUAV’s can reduce the use of conventional aircraft for several of these missions and likely many more as 

possibly larger UAV’s come into the civilian market such as the unmanned KMAX and FireScout type 

military aircraft as well as fixed wing assets for reconnaissance, damage assessments and routine 

maintenance patrols. Frontera plans to eventually deploy more advanced systems as they come available 

as the company and industry matures with this technology.

Frontera provides its clients with the expertise and knowledge in utility flight operations for conventional 

rotor wing aircraft as well as implementing sUAV systems for advanced transmission/distribution line

inspection and project solutions to increase reliability of utility T&D systems.

Donald Lindsay, Director of Frontera has over 40 years of professional experience in 

Transmission/Distribution Line work and is recognized as an industry expert in operations, maintenance, 

construction, quality control inspection and management of transmission, distribution and substation

assets. He has over 20 year’s professional experience in all aspects of aerial video and photography. The 

objective of Frontera’s aerial video and photography operations is to provide high quality imaging for a 

variety of commercial, public, utility and government agency’s specifically targeting:

 Construction Project Site Reconnaissance and Mapping

 Civil Works Inspection

 Transmission Line Inspection

 Distribution Line Inspection

 Substation Inspection

 Wind Turbine Inspection

 Solar Panel Site Inspection

 Pipeline Inspection

 Security Patrols

 Post Storm/Disaster Event infrastructure Damage Assessments
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BACKGROUND

Unmanned Aircraft Systems: Monarch LS and DJI Inspire 1, Phantom II and III UAS

Frontera seeks an exemption to operate Monarch, Inc. systems and DJI systems for compensation or hire

within the NAS. Both the Monarch LS systems and the DJI aircraft line are vertical takeoff and landing 

(VTOL) Unmanned Aircraft Systems (UAS) with a Ground Control Stations (GCS) utilizing electronic 

tablet or smart phone systems.

The Monarch LS is a quadcopter and has a maximum gross weight of 15 pounds (including sensors and 

battery), height of 17.5 inches, width of 40 inches, and a maximum speed of approximately 48 knots. 

The Monarch is equipped with four main rotors driven by Lithium Polymer battery-powered electric 

motors and electronic speed controllers. The Monarch was previously named in an approved 333 Waiver 

on 22 May 15 (Exemption # 11662 Regulatory Docket Number FAA-2015-0522).

The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 

17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom II, 

III and Inspire 1 UAS’s are equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors.

The Monarch LS operates under FAA Certification of Aircraft Registration Number N537RM which 

expires 31 March 2018. The DJI Inspire 1, Phantom II and III UAS operated by Frontera will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

BASIS FOR PETITION

Petitioner, Donald Lindsay, Director, Frontera Utility Flight Operations Consultants pursuant to the 

provisions of the Federal Aviation Regulations (14 C.F.R. 11.61) and the FAA Modernization and 

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby

petitions the Administrator to commercially operate various Monarch and DJI UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 61.113(a) & (b), 

91.7(a), 91.9(b) (2), 91.109(a), 91.119, 91.121, 91.151(b), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

aircraft and its operation, Frontera’s operation of the Monarch and DJI UAS meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H.

Accordingly, Frontera requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with 

an airworthiness certificate.

Frontera submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Frontera will use experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the operating 
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documents (i.e., Monthly Maintenance Log, and Monarch and DJI Inspire 1, Phantom II and III 

Instruction Manuals). Furthermore, Frontera will document and maintain all maintenance records for all 

Frontera operated Monarch and DJI UAS.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by Frontera to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that 

the PIC is able to safely operate the Monarch and DJI UAS in a manner consistent with this exemption, 

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

vehicles and structures.

Frontera seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Monarch and 

DJI UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Frontera submits that he will ensure that the Monarch and DJI UAS are in an airworthy condition, 

prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Instruction Manual), and that the aircraft is in a condition for safe 

flight.

Frontera also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as 

the Monarch and DJI UAS will not have a typical barometric altimeter onboard. However, altitude 

information of the Monarch and DJI UAS will be provided to the PIC via Global Positioning System 

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

GCS for active monitoring of the flight path. This altitude information, combined with Frontera’s 

operation of the Monarch and DJI UAS within visual line of sight, at or below 500 feet AGL, will ensure 

a level of safety equivalent to Section 91.121. 

Additionally, Frontera seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Frontera submits that safety will not be affected by operation 

of the Monarch and DJI UAS during daylight hours in visual meteorological conditions (VMC) under 

visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. 

In accordance with 14 C.F.R. 11.81, Frontera provides the following information in support of its petition 

for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Donald Lindsay, Director

Frontera Utility Flight Operations Consultants

10181 E Running Water Dr.

Gold Canyon, AZ 85118

602-510-5253

Email: don@fronteraflightops.com

www.fronteraflightops.com
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B. The Specific Sections Of 14 C.F.R. From Which Frontera Seeks Exemption.

1. Frontera Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) 

prescribe the following, in relevant part: 

a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as PIC of an aircraft.

b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if—

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

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

2. Frontera Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. Frontera Seeks Exemption From The Requirements Of Section 91.9.

Section 91.9, entitled Civil aircraft flight manual, marking, and placard requirements. States the 

following:

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

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

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

material, markings, and placards, or any combination thereof.

4. Frontera Seeks Exemption From The Requirements Of Section 91.109 

Section 91.109, entitled Flight instruction; Simulated instrument flight and certain flight
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tests. States the following:

(a) 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....

5. Frontera Seeks Exemption From The Requirements Of Section 91.119 

Section 91.119 Minimum safe altitudes: General. States the following:

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

6. Frontera Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

7. Frontera Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

8. Frontera Seeks Exemption From The Requirements Of Section 91.203 

Section 91.203 Civil Aircraft: Certifications required. States the following:
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(a) Except as provided in 91.715, no person may operate a civil aircraft unless it

has within it the following:

(1) An appropriate and current airworthiness certificate.

(2) An effective U.S. registration certificate issued to its owner or, for

operations within the United States, the second copy of the Aircraft

Registration Application as provided for in 47.31(c), or a registration

certification issued under the laws of a foreign country.

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

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

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

passengers or crew.

9. Frontera Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or 

operator of an aircraft—

(a) 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[.]

10. Frontera Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.]

11. Frontera Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

12. Frontera Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).
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Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or operator 

shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Frontera Seeks And The Reason Frontera Seeks The Relief. 
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1. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 61.113(a) 

And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, 

is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as 

well as a current and valid airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot 

may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire. 

As set forth more fully below, Frontera submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the Monarch and DJI UAS unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able to safely operate Monarch and 

DJI UAS in a manner consistent with the operations specifications as described in this exemption, 

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

vessels, vehicles and structures. 

Further, Frontera submits that all flights of the Monarch and DJI UAS, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to Frontera’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow Frontera to determine that the Monarch and DJI UAS are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Frontera Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Inspire 1, Phantom II and III Instruction 

Manuals). Frontera seeks the requested relief because Monarch and DJI UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Donald Lindsay will 

ensure that the Monarch and DJI UAS are in airworthy condition based upon compliance with the 

operating documents (i.e., Monthly Maintenance Log, and Monarch and DJI Instruction Manuals) prior to 

every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

3. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.9(b)(2)

The Monarch and DJI UAS come with access to online manuals that provide instructions for the safe

operation and maintenance of the aircraft. Compliance with this regulatory provision is not

possible because this information has not been, and cannot be, approved by the FAA since there

are no applicable standards established by the FAA against which to evaluate it. Additionally,

the Monarch and DJI UAS are too small to carry a printed manual. Since, by definition, there will never 

be a person aboard the Monarch or DJI UAS, Frontera submits that there is no need to require the manual 

to be placed on the Monarch and DJI UAS and an exemption is appropriate. Safety will be maintained by 

keeping the flight manual at the ground control point where the PIC will have immediate access to it. 

Since the Monarch and DJI UAS cannot be operated without the control box containing the manuals, 

there is minimal risk that the manuals will become separated from the Monarch and DJI UAS, and 
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Frontera will be able to immediately locate the manuals to effectuate any needed repairs on the Monarch 

and DJI UAS detailed in the flight manual.

4. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief Rom Section 91.109(a)

Small UASs, by their design, do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via radio

communications. Aircraft being submitted for use by Frontera allow the UAS Instructor to place

the aircraft into ‘loiter’ mode (fixed altitude stationary hold). In the event of the student losing

control, the UAS Instructor can quickly and via alternate equipment (equipment not in the hands

of the student) place the aircraft into a mode that then allows the instructor to bring the aircraft

back into control and back to the pre-determined and/or safe landing location.

5. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.119

Frontera submits that the only relief it requires from 91.119 is from the minimum altitudes

listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because

asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since

operations at this altitude also pose a heightened risk of collision with another aircraft, safety can

only be assured through the grant of an exemption. The anticipated rotorcraft operations should

be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from

paragraph (a) because an emergency landing of the aircraft due to a power failure will not create

an undue hazard to persons or property on the surface. As noted in the explanation of why an

exemption will not adversely affect safety, Frontera will operate on utility right of way lands which the

Monarch and DJI UAS will fly and public access is restricted. Frontera personnel are already required to 

wear mandatory PPE/personal protective equipment, including hard hats, HI-VIZ FR clothing, safety 

glasses and composite hard-toe boots whenever dispatched to a work site. As such, the risk of injury is 

minimal. Frontera does not contemplate conducting operations over congested areas, so relief is not

requested from paragraph (b).

6. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the 

Monarch and DJI UAS, which does not utilize a barometric pressure sensor, rather, GPS equipment, and a 

radio communications telemetry datalink to downlink altitude information from the UAS to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), Frontera seeks the 

requested relief because the Monarch and DJI UAS altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the 

extent necessary to comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the Monarch and DJI UAS are not 

equipped with a barometric pressure sensor, rather GPS equipment, which automatically ensures that a 
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ground level pressure setting equivalent of zero will be established prior to each flight from the takeoff 

point, and provides the PIC with AGL altitude information of the UAS on the heads-up display of the 

GCS.

7. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the 

extent required to allow flights of the battery powered Monarch and DJI UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. Frontera seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered Monarch and DJI UAS will severely constrain 

the practicality of any aerial video or still photo flight operations that Frontera proposes to conduct 

pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Monarch and DJI UAS, and Monarch 

and DJI UAS operating documents, and Frontera’s proposed operating limitations, ensure that Frontera

will safely operate the battery powered Monarch and DJI UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 4.5 minutes.

8. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Section 91.203

The DJI UAS that Frontera intends to operate will not qualify for an airworthiness certificate

unless the FAA chooses to issue them a restricted category certificate. This is because the Monarch and 

DJI UAS do not meet the current conditions for either a standard airworthiness certificate or an

experimental airworthiness certificate. Notably, under 14 C.F.R. 21.191,8 experimental

airworthiness certificates are only available for research and development, showing compliance

with regulations, crew training, exhibitions, air racing, market surveys, operating amateur-built

aircraft, operating primary kit-built aircraft and operating light-sport aircraft. Until such time as

the FAA develops airworthiness standards applicable to sUAS for non-recreational and non-experimental

use, Frontera submits that the FAA should consider exemptions to the requirements

of 91.203(a). The absence of such exemptions hinders the development of sUAS and

applicable uniform standards since it is only through the development of the aircraft that the

FAA can reliably evaluate them and determine appropriate design standards.

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the

requirement for an airworthiness certificate based on a consideration of the size, weight, speed,

operational capability of the particular UAS, as well as its proximity to airports and populated

areas. An analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate in the areas and under the conditions contemplated by Frontera will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the conditions proposed in this request. The UAS is less than

55 lbs. fully loaded, carries neither a pilot nor passenger, and typically operates within a

restricted access utility right of way area as set out in the Frontera Operations Manual (a copy of which is 

attached as Appendix E). Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by the operator and observer. Operations will be conducted in
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compliance with the FAA and with local public safety requirements to provide security for the

area of operation as is now done with conventional train, track, bridge and out building

evaluation. These safety enhancements provide an expanded degree of safety to the utility

inspectors over conventional operations. Lastly, application of these same criteria demonstrates

that there is no credible threat to national security posed by the sUAS, due to its size, speed of

operation, location of operation, lack of explosive materials and inability to carry a substantial

external load.

If the FAA waives the requirements of paragraph (a) (1), then it is technically impossible

to comply with paragraph (b), so an exemption is merited there as well.

9-12. Extent Of Relief Frontera Seeks And The Reason Frontera Seeks Relief From Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft 

with an airworthiness certificate, Frontera requests relief from these Sections because the Monarch and 

DJI UAS do not require airworthiness certificates. As set forth more fully below, the Monarch and DJI 

UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Frontera will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the Frontera Aerial Operations Manual, Monthly Maintenance Log, and

Monarch and DJI Instruction Manuals). Furthermore, Frontera will document and maintain all 

maintenance records for the Monarch and DJI UAS.

D. The Reasons Why Granting Frontera’s Request Would Be In The Public Interest; That Is, How 

It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Frontera to safely, efficiently, 

and economically perform aerial video and photography for Transmission Line Inspection, Distribution 

Line Inspection, Pipeline Inspection, construction site reconnaissance and civil inspection in all areas of 

the United States. The reliability of the Power Grid is important to the Public benefit. The UAS will 

allow Frontera to use its expertise in transmission line inspection to ensure that there are not power 

outages due to poor maintenance or workmanship.

Additionally, use of the Monarch and DJI UAS will decrease congestion of the NAS, reduce pollution, 

eliminate much of the risk and provide significant benefits to the economy. Notably, the benefits of 

Frontera’s proposed operation of the Monarch and DJI UAS will be realized without implicating any 

privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The Monarch and DJI UAS is battery powered and serves as a safe, efficient, and economical alternative 

to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of the Monarch and DJI

UAS will reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as 

reducing risk and increasing the safety of life and property in the air and on the ground.
14

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The Monarch and DJI UAS does not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of flight operations.

Frontera’s operations on transmission/distribution lines will be limited when practical to non-flyable

airspace by conventional aircraft within the transmission/distribution/substation corridor on energized

lines and new construction greatly limiting any interference with any manned aircraft operation in the 

NAS. These missions are always pre-planned for flight path/profiles according to structure type, number 

of circuits, hardware and conductor bundle configuration, static/shield wire/fiber optic cable 

configurations, conductor catenary curves and other factors such as wind and natural lighting. This allows 

operations in non-flyable airspace to be strictly adhered to and documented by flight track recording in all 

areas of the NAS and especially on transmission/distribution lines near airports. Operations in these areas 

will be conducted within rotor strike distance by conventional manned rotorcraft therefore deemed non 

flyable airspace by methods other than UAS missions.

2. The Public Will Benefit From The Safety And Efficiency Of The Monarch and DJI UAS.

Conducting aerial acquisitions with the Monarch and DJI UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial video and still photography flight operations. By using battery power and electric motors, the 

Monarch and DJI UAS produce no air pollution, and is the most viable environmentally conscious 

alternative to the turbine engine rotorcraft that are typically utilized for transmission/distribution line

aerial video and photography. The Monarch and DJI UAS, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, 

rather than an internal combustion engine.

By using the Monarch and DJI UAS to perform aerial acquisitions, the substantial risk to life and property 

in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, 

will be substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the Monarch and DJI UAS (weighing approximately 6 pounds 7.5 ounces at 

the maximum gross weight with a lengths of 17.3 inches, widths of 17.7 inches respectively, and with no 

fuel on board), has less physical potential for collateral damage to life and property on the ground, and in 

the air, compared to the manned aircraft that typically conduct similar operations.

3. Performing Aerial Video and Photography Operations With The Monarch and DJI UAS Will 

Benefit The Economy.

In addition to being safe and efficient, the Monarch and DJI UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the Monarch and DJI 

UAS will allow United States based companies, like Frontera, to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. Operating the 

battery powered the Monarch and DJI UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft.

By operating the Monarch and DJI UAS, companies such as Frontera, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately
15

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the Monarch and DJI UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Frontera’s proposed operation of the Monarch and DJI UAS will not implicate any privacy issues. 

Specifically, the Monarch and DJI UAS will be operated only in compliance with operating documents 

(i.e., the Frontera Aerial Operations Manual, Monthly Maintenance Log, and DJI Instruction Manuals) 

which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Frontera Seeks Exemption. 

1. Reasons Why The Monarch and DJI UAS Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

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

aircraft and its operation, Frontera’s operation of the Specifically, the Monarch and DJI UAS will be 

operated only in compliance with operating documents (i.e., the Frontera Aerial Operations Manual, 

Monthly Maintenance Log, and Monarch and DJI Instruction Manuals) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. meet the conditions of 

FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General--Notwithstanding any other requirement of this subtitle, and not later than 180 

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rule making required by section 332 of this Act or the guidance 

required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection 

(a), the Secretary shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and 
16

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation--If the Secretary determines under this section that certain 

unmanned aircraft systems may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft systems in the national 

airspace system. 

In seeking this exemption, Frontera submits that the Frontera’s operation of the Specifically, the Monarch 

and DJI UAS will be operated only in compliance with operating documents (i.e., the Frontera Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Instruction Manuals) which requires property 

owner involvement as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulationscan operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: 

(a) the characteristics of the Monarch and DJI UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations.

a. The Specifications Of The Monarch and DJI UAS Demonstrate Its Safe Characteristics. 

The Monarch and DJI UAS do not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Inspire 1 UAS. 

The technical specifications of the Monarch and DJI UAS are set forth by the Monarch LS and DJI 

Specifications and Data Sheets, attached hereto as Exhibit A. 

ii. The Monarch and DJI UAS Autonomous Flight And Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area. 

The Monarch and DJI UAS may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI UAS is provided at pages 12-16 and 

45-50 of the DJI Inspire 1 User Manual, attached hereto as Exhibit Appendix B. [ADD REF. TO 

MONARCH USER MANUAL]

iii. The Monarch and DJI UAS are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the Monarch and DJI UAS will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the Monarch and DJI UAS do not reacquire control link data from the GCS, 

the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e.,

failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the Monarch and DJI UAS are set forth at pages ...of 

the Monarch User Manual and at pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto 

as Exhibit B.

iv. The Monarch and DJI UAS GCS And Its Operation.
17

A complete description of the operation and specifications of the Monarch and DJI UAS GCS and flight 

control software is provided at pages 40 through 47 of the DJI Inspire 1 User Manual. The DJI Inspire 1 

User Manuals is attached hereto as Exhibits B.

b. Flight Operations Of Monarch and DJI UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer.

Frontera will only utilize certificated pilots who possess a current and valid airman medical certificate to 

act as a pilot in command (PIC) of the Monarch and DJI UAS. Additionally, a safety observer will assist 

all pilots during flight time.

c. Flights Of Monarch and DJI UAS Will Be Conducted Pursuant To Specific Operating 

Limitations.

In seeking this exemption, Frontera proposes to commercially operate Monarch and DJI UAS for the 

special purpose of conducting aerial video and photography over all areas of United States, pursuant to 

the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft UAS weighing less than 55 pounds maximum gross weight: Monarch 

LS and DJI Inspire 1, Phantom II and III Unmanned Aircraft Systems. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made and 

approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS 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. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO 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 SO can perform the functions prescribed in the 

operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air 

traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions and 
18

limitations contained in the grant of exemption and the procedures outlined in the operating documents, 

the conditions and limitations contained in the grant of exemption 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 upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for 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. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records.

11. 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. The 

PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the UAS 

to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS 

will be operated under the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must 

be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the 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 C.F.R. § 91.119.
19

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must 

be conducted under visual meteorological conditions (VMC). If flight at night is required, a special 

request will be made at the FAA office closest to proposed area of operations. Flights under special visual 

flight rules (SVFR) are not authorized. 

20. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current 

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

and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the Administrator upon 

request. 

21. The UAS 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. 

22. If the UAS loses communications or loses its GPS signal, it must return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with 

the operating documents. 

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered 

in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 

14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UAS must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

29. The UAS must remain clear and yield the right of way to all manned aviation operations and activities 

at all times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other 

than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. 

Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or 
20

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 and/or; b. The aircraft is operated near 

vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has 

granted permission 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, and; c. Operations nearer to the PIC, SO, 

operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission from the 

land owner/controller or authorized representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

33. 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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety. 

Frontera submits that the equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate Monarch and DJI UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the Monarch and DJI UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Considering Frontera’s proposed area of operations, and the operating limitations set forth-above; the 

parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the 

Monarch and DJI UAS, Frontera submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for Frontera’s

specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 

11160, 11161). 

Frontera will not allow any PIC to operate the Monarch and DJI UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the Monarch and DJI UAS training and currency 

requirements, that the PIC is able to safely operate the Monarch and DJI UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a 

UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In 

addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). 
21

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in 

compliance with applicable regulations will ensure an equivalent level of safety during Frontera’s

proposed operations. The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in 

a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations 

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption. For clarification, the FAA considers these minimum hour requirements to 

be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 

hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the 

flight-hour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The 

FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to accomplish the required 

flight time. During training, proficiency, and experience-building flights the PIC is required to

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Accordingly Frontera will ensure safe operation by not allowing any PIC to operate the Monarch and DJI 

UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that 

the PIC is able to safely operate the Monarch and DJI UAS in a manner consistent with the exemption, 

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

vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every 

flight, Frontera will ensure that the Monarch and DJI UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.9(b)(2) Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.99(b)(2) will be maintained because; 

The safety related purpose of this manual requirement can be equally satisfied by maintaining the sUAS 

flight manual at the ground control point where the pilot flying the sUAS will have immediate access to 
22

it. Accordingly, Petitioner requests an exemption from § 91.9(b)(2)'s flight manual requirements, on the 

condition that the sUAS flight manual be available at the control point during each operation. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. F. 14

5. Reasons Why An Exemption From The Requirements Of Section 91.109(a) Would Not Adversely 

Affect Safety.

The equivalent level of safety established by 91.109(a) will be maintained because; 

Given the size and speed of the sUAS, an equivalent level of safe training can still be performed without 

dual controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance 

away should the sUAS experience any difficulties during flight instruction. 

The FAA has approved exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. 

6. Reasons Why An Exemption From The Requirements Of Section 91.119 Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by 91.119 will be maintained because; 

Compared to flight operations with rotorcraft weighting far more than the maximum 55 lbs. proposed 

herein, and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft. An equivalent level of safety will be achieved given the 

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

UAS will be operated in a restricted area, where buildings and people will not be exposed to operations 

without their pre-obtained consent. No flight will be taken without the permission of the property owner 

and/or local officials. Because of the advance notice to the property owner and participants, all affected 

individuals will be aware of the planned flight operations as set forth in the Manual. Furthermore, by 

operating at such lower altitudes, the UAS will not interfere with other aircraft that are subject to the 

minimum safe altitude regulations. 

7. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude 

information of the Monarch and DJI UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of 

the flight path and altitude. This altitude information, combined with Frontera’s operation of the Monarch 

and DJI UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the 

UAS at ground level.
23

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

8. Reasons Why An Exemption From The Requirements Of Section 91.203(a) and (b) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.203(a) and (b) will be maintained because; 

To the extent these regulations are applicable to the proposed sUAS operations, an equivalent level of 

safety will be achieved by keeping these documents at the ground control point where the pilot flying the 

sUAS will have immediate access to them. 

The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions 

includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

9. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b) as a result of (1) the technical specifications of the Monarch and DJI UAS; (2) the limitations 

on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

Frontera will ensure that it will safely operate the battery powered Monarch and DJI UAS during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the Monarch and DJI UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will ensure an 

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured 

as the Monarch and DJI UAS provide audible and visual warnings to the PIC at the GCS when the UAS 

experiences low battery voltage, the first warning occurring at approximately 33% remaining battery 

power, and again at approximately 10% remaining battery power. At the critically low battery level, the 

Monarch and DJI UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed 

in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

10-13. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Frontera submits that the equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Frontera will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 
24

and practices prescribed in the operating documents (i.e., the Frontera Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Instruction Manuals). Furthermore, Frontera will document and

maintain all maintenance records for the Monarch and DJI UAS.

Since the Monarch LS and DJI Phantom II, III and DJI Inspire 1 UAS will be inspected as prescribed by 

the operating documents, Frontera will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). Monarch LS and DJI Inspire 1 User Manuals and Maintenance 

LOGs are available upon request.

Likewise, the exemption sought will not adversely affect safety because Donald Lindsay will use trained 

technicians to perform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 

91.407, 91.417(a) and 91.417(b), because all maintenance of the Monarch and DJI UAS will be 

performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered.

In consideration of Frontera’s proposed operating limitations, the operating documents, and the technical 

aspects of the Monarch and DJI UAS, Frontera submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, Frontera requests that the FAA prescribe special conditions 

for the intended operation of the Monarch and DJI UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by

14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAS for the limited purpose of conducting aerial video and photography over all areas of 

the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security; and further, provides the authority for such UAS to operate without airworthiness 

certification in accordance with any requirements that must be established for the safe operation of the 

UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 21.16, for operation 

of the DJI Phantom II, III and DJI Inspire 1 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the 

aircraft. Section 21.16, entitled Special Conditions, states the following:
25

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft 

engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established 

in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special 

conditions for intended operation of the Monarch LS and the DJI Phantom II, III and DJI Inspire 1 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

Frontera Seeks Exemption:

Frontera seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a),91.9(b)(2), 

91.109(a), 91.119, 91.121, 91.151(b), 91.203(a)and(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Frontera Seeks: 

This exemption will permit Frontera to commercially operate an Unmanned Aircraft System (UAS) for 

the purpose of conducting aerial video and photography over all areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support Frontera’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, Frontera’s request for exemption may be granted pursuant to the authority of FMRA Section 333 

and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to 

users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Frontera will operate the Monarch and DJI UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Frontera seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the Monarch 

and DJI UAS commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over all areas of the United States. By granting this Petition, the FAA 
26

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing Frontera to safely, efficiently, and 

economically operate the Monarch and DJI UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, Frontera respectfully requests that the Administrator grant this Petition 

for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Frontera to operate the 

Monarch and DJI UAS commercially for the purpose of conducting aerial video and photography over all 

areas of the United States.

Dated: 2015

Donald Lindsay

____________________

Donald Lindsay, Director

Frontera Utility Flight Operations Consultants

10181 E Running Water Dr.

Gold Canyon, AZ 85118

Appendices:

A – DJI Inspire Specification Sheet

B – Link to DJI Inspire 1 Manufacturer’s User Manual
27

APPENDIX – A

Monarch LS TECHNICAL SPECIFICATIONS

Aircraft Components

• Monarch LS Drone Aircraft 

(Quadcopter)

• Autopilot with GPS

• Dual radios (telemetry and 

controller)

• Motors and electronic speed 

controllers

• FAA-approved Strobe light

• 22Ahr battery

• Charger

• Cocoon Sensor Housing

• Gimbaled arm (optional)

• TSA-Approved Carrying Case

Specification

• Weight: 12-15lbs

• Height: 18'' with strobe 28''

• Width: 41''

• Propellers: 16''

• Time Aloft: 30 Minutes

• Coverage: 160 Acres

• Ceiling: 500' AGL

• Temp. Range: -40 to +85 deg C

Results

• Google Maps integrated result

• GIS map

• Measurable resultmaps 

(Pointclouds)

• 3D georectefied map

Sensors (Options)

• High Resolution day light 

camera

• Tau2 IR sensors

• Hyperspatial sensors

Ground Control Station

• Butterfly Bridge

• Autonomous flight planning 

software

• Analysis software

• Flight controller

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Frontera only utilizes safe and reliable UAS. DJI is an industry leader in small UAS production. DJI UAS 

are loaded with ground breaking software enabling the user to set parameters which will not allow flight 

into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined 

and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software 

provides real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 
28

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 18 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 30 

2.2.3 Camera 

2.2.3.1 Name – X3 

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 

1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

2.2.4 Transmitter 

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 2.2.4.6 Battery – 600mAh 

LiPo 2S

ADD SPECS FOR PHANTOM II & III
29

APPENDIX – B

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

ADD;

MAINTENANCE MANUALS

SAFETY MANUAL

JHA/TAILBOARD FORM

FRONTERA AIR OPS MAN

EMERGENCY ACTION PLAN

PPE REQUIREMENTS

SURVIVAL GEAR

FIRE PLAN

ENVIRO PLAN