April 13, 2015 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Coleman Engineering Company for an Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012

Dear Madam/Sir, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(“Reform Act”) and 14 C.P.R. Part 11, Coleman Engineering hereby applies for an 

exemption from the Federal Aviation Regulations identified below, to allow 

commercial operations of small unmanned aerial vehicles.

This exemption is made based on information outlined in this petition, as well as the 

accompanying DJI Phantom 2 Operators Manual (Appendix B) and the Coleman Engineering 

Operational Limitations (Appendix C). The DJI Phantom 2 UAS was selected because it has a 

proven capability for controlled flight as well as a gyro stabilized flight mode, GPS aided 

navigation, a compass, blinking LED’s on the bottom, a failsafe mode for returning home, and 

prop guards. These devices are offered for general sale around the world and have often been 

used as Model Aircraft in the USA.

The Requested exemption would authorize commercial operations using the DJI Phantom 2 for 

mapping and surveying applications. These operations will be subject to strict operating 

requirements defined in the user manual and conditions defined by the Safety Code of the 

Academy of Model Aeronautics (see Annex B), in order to ensure at least an equivalent level 

of safety to currently authorized operations using manned aircrafts. 

Specifically, the UAS is:

A lightweight (< 7.0 lb gross weight with all on-board equipment), battery operated 4- 

motor rotorcraft in the form of a quadcopter that takes off and lands vertically, 

manufactured by DJI, Model Phantom 2 , with the following equipment: 

 An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller; 

 An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video;

 An on-board telemetry system that delivers flight data from the on-board flight 
computer to the on-board radio transmitter including altitude AGL, horizontal 

and vertical speed, compass direction of flight and direction back to its launch site; 

 A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the onboard camera plus all the flight data from the telemetry system described above; 

The Ground Station Includes:

 A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAS while in the air; 

 A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control 

the UAS while in flight;

 A radio receiver receiving live video and flight data from the on-board

camera and computer projects it all together onto a screen for the PIC to 

view during flight; 

 A Visual Observer (VO) is a person who provides a second pair of eyes to 

visually track the UAS while in flight. 

Proposed Operations

Coleman Engineering intends to use UAS in two general areas. First, Coleman Engineering 

seeks an exemption to perform video filming and photographing by air for public and private

use. The purpose of this photography will be to aid in topographic mapping of ground based 

features on the earth. Second, it will employ UAS’s to inspect land, residential, commercial,

industrial structures and property. 

Specifically, Coleman Engineering will use UAS’s that are equipped with cameras and

sensors in order to engage in the following commercial activities:

(a) Taking photographs to support professional operations in engineering, land 

surveying, architecture, real estate and other related professional activities.

(b) Inspections by air of agricultural areas.

(c) Inspections by air of infrastructure such as bridges, highways, electrical installations, 

dams, aqueducts, photovoltaic power stations, wind farms and pipes. These inspections 

will only be done under contract with the owners or with any local government authority.

(d) Inspections by air of land and residential, commercial and industrial structures,

only under contract with the owners or with any local government authority.

(e) Inspections by air to detect sources of pollution and gas emissions, under contract 

with the owners in the area or with any local government authority.

(f) Support provided to search and rescue operations and reconnaissance in cases of need, 

emergency or natural disasters and only when government authorities have requested it by 

contract or donation.
Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the 

following considerations:

• 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 the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§

44702-44716,et seq.). A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole, and (2) would not adversely affect safety

(or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. §

11.81 (petitions for exemption).

Coleman Engineering’s Proposed UAS Operations Meet the Requirements of Section 333 of the 

Reform Act

Coleman Engineering’s proposed operations in this Petition for Exemption qualify for expedited 

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and 

relevant factors are satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability

Coleman Engineering will employ the DJI Phantom 2 quadcopters for the operations specified in 

this Petition for exemption. The Phantom 2 UASs have a maximum take-off weight of less than 7

pounds, the flight speed will not exceed 35 miles per hour, and it will not be flown in controlled

airspace or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they 

can be safely terminated with a reserve battery power of 25% of the battery's maximum charge. The 

DJI Phantom 2 UAS do not carry any flammable propellant or fuel. The Phantom 2 UAS also has 

an integrated GPS system that calculates the UAS’s position and height and relays that information 

via a secure connection to the operator. Additionally, the Phantom 2 UAS contain a failsafe mode if

its connection to the remote control is lost, and this system permits the UAS to return to a 

predetermined location and land without injury or damage. 

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manual.

Colman Engineering’s Operations Limitations and the DJI's operators manual contain all of the 

procedures and limitations necessary to successfully perform the operations specified in this Petition 

for Exemption. (Appendices B & C).
Public Interest

The public interest will be served by granting Coleman Engineering’s Petition for Exemption. 

Congress has established a national policy that favors early integration of UAS’s into the NAS in 

controlled, safe working environments such as those proposed in this Petition. In addition, the 

public also has an interest in reducing the hazards associated with alternate methods of conducting 

similar operations. Currently operations are conducted using teams that physically climb onto 

structures using ladders, using low flying helicopters or aircraft, or simply not available by 

traditional means. By using UAS, exposure to physical hazards will be reduced of conducting the 

operation while remaining safely on the ground.

Additionally, Coleman Engineering’s intended uses for the UAS’s have identifiable safety benefits 

that include reducing the danger and emissions associated with full size helicopters. UAS have no 

fuel to ignite or explode, no crew, adds a greater degree of flexibility which supplements the current 

capabilities offered by manned aircraft, and public interest for a ground impact of a small lightweight 

UAS is further minimized from an ecological and safety standpoint.

Federal Register Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed: 

Coleman Engineering seeks an exemption from the following rules:

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

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

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

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft, rotorcraft, or other methods.

Conclusion

Coleman Engineering’s Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight speed, operating capabilities, proximity to airports 

and populated areas, operation within visual line of sight and national security. Additionally, the 

Petition provides more than adequate justification for the grant of the requested exemptions to permit 

Coleman Engineering to operate the selected UAS for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, including (1) 

significantly improving safety and reducing risk by alleviating human exposure to danger, and (2) 

improving the quality of services and decreasing operating costs compared with conventional flight 

operations. 

With the advent and availability of this technology surveying and mapping functions are changing 

from a traditional ground based operations to the aerial platform. Coleman Engineering will have the 

ability to collect a tremendous amount of data in a small fraction of the time that would be needed 

for ground based efforts. As project sizes increase, the savings to both Coleman Engineering and our 

Clients will increase greatly. The cost of purchasing our DJI Phantom 2 is next to nothing in 
comparison to that of a traditional manned aircraft. A major advantage of the low operational 

expenses is that Coleman Engineering can provide these aerial acquisition services at a much lower 

cost to the consumer while remaining competitive and profitable. This will in turn lead to economic 

growth and stability at a local, state and federal lever. 

Coleman realizes that other survey and engineering firms have already been granted an exemption to 

use there UAS for commercial purposes, as shown in FAA exemption No. 11266, Docket No. FAA2014-0733 & FAA exemption No. 11285, Docket No. FAA-2014-1015 & FAA exemption No. 

11299, Docket No. FAA-2014-1008 & FAA exemption No. 11302, Docket No. FAA-2014-1032. 

With the DJI Phantom 2’s small and lightweight design it can be assembled and deployed in a 

manner of only a few minutes once the survey crews arrive on site. It will perform its mission 

effectively and efficiently and land directly at our feet. The data we collect will be able to be 

processed immediately. All of these factors prove to be a huge benefit to the consumer, and help 

advance the land surveying profession to a whole new level. 

Very Respectfully, 

James D. Blondheim 

635 Circle Drive 

Iron Mountain, MI 49801 

jblondheim@coleman-engineering.com

(906) 774-3440
Appendix A

The regulations from which the exemption is requested are listed below. Beside each 

regulation number is the page of the attached Appendix A upon which each may be found

together with our proposed equivalent level of safety for each regulation: 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

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

Exemptions Requested

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

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under§

40101 of the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.

Coleman Engineering seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 27, 

45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed below are the 

specific sections of 14 C.F.R. for which exemption is sought:

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the UAS selected provides an equivalent level of safety when compared to

aircraft normally used for the same application. (Regulatory Docket No. FAA2014-0352). These criteria are met, and therefore no exemption is needed.

Equivalent Level of Safety

The UAS selected by Coleman Engineering is safe when taking into account their size, weight, 

speed, and operational capability. The UAS weighs less than 7 pounds and will be flown at less 

than 35 miles per hour and completely outside controlled airspace. Additionally, the UAS carry 

neither pilots nor passengers, carry no explosive materials and or flammable liquid fuels, and 

operate exclusively within the parameters stated in the Operator’s Manual and Operations 

Limitations.

Operations under this exemption will be closely controlled and monitored by the operator and will be 

conducted in compliance with local public safety requirements, to provide security for the area of 

operation. Coleman Engineering will also, if necessary, provide the FAA with advance notice of all 

operations via NOTAMS and in coordination with the local FSDO. In all cases, the UAS operated 

under the proposed conditions will be at least as safe as, or safer than, conventional rotorcraft operating 

with an airworthiness certificate without the restrictions and conditions of the proposed UAS

operations.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that Coleman Engineering UAS would otherwise require 

certification under Part 27, we seek an exemption from Part 27's airworthiness standards for the same

reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.
14 C.F.R. §§45.23(b), Display of marks; general

These regulations provide that each aircraft must display "N" and the aircraft's registration number 

in letters at least 2 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station. The UAS does not have an entrance in which the word "EXPERIMENTAL" can be 

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

Coleman Engineering proposes to achieve an equivalent level of safety by including the word 

"EXPERIMENTAL" as large as practicable on the top of the aircraft, where the PIC, VO and 

others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. Finally, the ground station will display a high contrast flag or banner that contains the 

words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft 

will operate within 3/4 NM of the ground station, the banner should be visible to anyone that 

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

In a previous Grant of Exemption, Regulatory Docket No. FAA-2014-0352, the FAA determined 

that exemption from these requirements was warranted provided that the aircraft "have 

identification (N-Number) markings in accordance with 14 C.F.R part 45, Subpart C if the 

markings are as large as practicable." 

14 CFR § 61.113 (a) and (b); 61.3 (c,2-v): Private Pilot Privileges and Limitations, Medical

Certificate

In addition, Coleman Engineering seeks exemption from 14 C.F.R § 61.113, which restricts private 

pilot certificate holders from flying aircraft for compensation or hire, and which would also require 

a second class medical certificate. The purpose of this section is to ensure the skill and competency 

of any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while the UAS 

will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the 

Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the additional cost 

and restrictions attendant with requiring the PIC to have a commercial pilot certificate and class II

medical certificate. Additionally, instead of having a second or third class medical, we suggest that 

the PIC exercise the privileges similar to that of a sport pilot, requiring only a valid US driver’s 

license.

Safety Mitigation

Coleman Engineering seeks to ensure safe operation by ensuring that any PIC is thoroughly 

versed in airspace and communication issues pertaining to all aircraft operators but also in the 

unique aspects of UAS flight. 

We believe the combination of aeronautical knowledge, UAS airmanship skills, and verification 

through remaining current is a sufficient method to evaluate a pilot’s qualifications, given that 

operations will be conducted within the limitations outlined in this petition. Like with any required 

skill, the more flight time the PIC gains, the more proficient the PIC becomes. 
14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Coleman Engineering seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft 

be in airworthy condition to be operated. The FAA has stated (Regulatory Docket No. FAA-2014-

0352) that no exemption is required to the extent that the requirements of Part 21 are waived or found 

inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

Given its size, configuration, and load capacity, the Phantom 2 has no ability to carry such a manual 

on the aircraft, not only because there is no pilot on board, but because there is simply no room or 

capacity to carry such an item on the aircraft.

Safety Mitigation

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

Phantom 2 Manual at the ground control point where the pilot flying the Phantom 2 will have 

immediate access to it. Accordingly, we request an exemption from § 91.9(b) (2)'s flight manual 

requirements, on the condition that the Phantom 2 flight manual be available at the point of control 

during each operation. 

14 C.F.R. § 91.103: Preflight Action

Coleman Engineering seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to 

become familiar with specific information before each flight, including information contained in 

the FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct the flight, an exemption is requested to the extent that an 

FAA-approved Flight manual is required.

Safety Mitigation

An equivalent level of safety will be provided by following the Aircraft Operations Manual and 

flight manual provided by the manufacturer. The PIC will take all required preflight actions, 

including performing all required checklists and reviewing weather, flight requirements, battery 

charge, landing and takeoff distance, aircraft performance data, and contingency landing areas 

before initiation of flight. The Operators Manual and Operational Limitations will be kept at 

the ground station with the operator at all times.

14 C.F.R. § 91.109(a): Flight Instruction

Coleman Engineering seeks an exemption from 14 C.F.R. § 91.109(a), which 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." UAS and remotely 

piloted aircraft, by their design, do not have functional dual controls. Instead, flight control 

is accomplished through the use of a device that communicates with the aircraft via radio 

communications.
Safety Mitigation

Given the size and speed of the UAS employed by Coleman Engineering, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard the 

UAS, and all persons will be a safe distance away in the event that the UAS encounters any 

difficulties during flight instruction. In addition, we will conduct flight training at our Research and 

Development test sites, which are located on our own property. These training flights will be 

conducted in a sterile area and will otherwise comply with the provisions in the Operator’s Manual 

for flights at the R&D facility. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no 

exemption is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

Coleman Engineering requests an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, vessel, 

vehicle, or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) 

allows for a helicopter to operate at less than those minimum altitudes when it can be operated 

"without hazard to persons or property on the surface," provided that "each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopter by the 

FAA.” 

Safety Mitigation

Compared to flight operations with rotorcraft weighing far more than the maximum weights 

proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An equivalent 

level of safety will be achieved given the size, weight, and speed of the UAS, as well as the 

location where it is operated. In order to avoid any risk to aircraft, flight operations will be 

restricted to 400' AGL or below.

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required to the extent 

that the UAS does not have a barometric altimeter, but rather a GPS altitude read out.

Safety Mitigation

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be operated at

400' AGL or below and within visual line-of-sight in addition to GPS based altitude information 

relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, Docket No. FAA2014-0352. As the attached Operations Manual indicates, the chosen UAS meets these requirements, 

and a zero altitude initiation point will be obtained prior to flight
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Coleman Engineering requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements 

for flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. Coleman 

Engineering proposes that all flights comply with this requirement by mandating that the

aircraft be safely landed with no less than 25% of battery life remaining.

Safety Mitigation

The FAA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to

Astraeus Aerial, Docket No. PAA-2014-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety.

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

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so

that it is legible to passengers or crew." 

At a maximum gross weight of less than 7 pounds, the UAS is too small to carry documentation, does 

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

of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft 

by the FAA will be co-located with the crew at the ground control station and available for inspection 

upon request. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is 

required. 
14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) Maintenance

Required

Coleman Engineering seeks an exemption from the maintenance inspection requirements contained in

14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. §

91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ...have discrepancies 

repaired as prescribed in part 43 of this chapter"). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS’s will not have.

Safety Mitigation

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with the Operators Manual. As provided in the Operators Manual, 

flights will not be conducted unless a flight operations checklist is performed that includes all of 

the aircraft's components.
Appendix B:



















































ANNEX B 
Academy of Model Aeronautics National Model Aircraft Safety Code

Effective January 1, 2014 

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. It may not exceed limitations of this code and is 

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in accordance with this safety code and any 

additional rules specific to the flying site. 

1. Model aircraft will not be flown: 

(a) In a careless or reckless manner. 

(b) At a location where model aircraft activities are prohibited. 

2. Model aircraft pilots will: 

(a) Yield the right of way to all human-carrying aircraft. 

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document #540-D.) 

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an airport without notifying the airport operator. 

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base except where there is a mixed use agreement. 

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the AMA Large Model Airplane program. (AMA Document 520-A.) 

(f) Ensure the aircraft is identified with the name and address or AMA number of the owner on the inside or affixed to the outside of the model aircraft. (This 

does not apply to model aircraft flown indoors.) 

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for helicopters operated under the provisions of AMA Document #555. 

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that could adversely affect the pilot’s ability to safely control the 

model. 

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device which propels a projectile or drops any object that creates a 

hazard to persons or property. 

Exceptions: 

 Free Flight fuses or devices that burn producing smoke and are securely attached to the model aircraft during flight. 

 Rocket motors (using solid propellant) up to a G-series size may be used provided they remain attached to the model during flight. Model rockets may 

be flown in accordance with the National Model Rocketry Safety Code but may not be launched from model aircraft. 

 Officially designated AMA Air Show Teams (AST) are authorized to use devices and practices as defined within the Team AMA Program Document. 

(AMA Document #718.) 

(j) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine regulations. (AMA Document #510-A.) 

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations unless: 

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers intended or anticipated prior to the specific event. 

(b) An inexperienced pilot is assisted by an experienced pilot. 

4. When and where required by rule, helmets must be properly worn and fastened. They must be OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply 

with comparable standards. 

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall avoid endangerment of life and property of others. 

2. A successful radio equipment ground-range check in accordance with manufacturer’s recommendations will be completed before the first flight of a new or 

repaired model aircraft. 

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA Document #706.) 

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the safety line. 

(b) At air shows or demonstrations, a straight safety line must be established. 

(c) An area away from the safety line must be maintained for spectators. 

(d) Intentional flying behind the safety line is prohibited. 

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal Communications Commission (FCC). Only individuals properly 

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies. 

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site without a frequency-management agreement. (AMA 

Documents #922 and #923.) 

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff and landing, no powered model may be flown outdoors 

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the flightline. 

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it is still under power, except to divert it from striking an 

individual. 

8. RC night flying requires a lighting system providing the pilot with a clear view of the model’s attitude and orientation at all times. Hand-held illumination 

systems are inadequate for night flying operations. 

9. The pilot of an RC model aircraft shall: 

(a) Maintain control during the entire flight, maintaining visual contact without enhancement other than by corrective lenses prescribed for the pilot. 

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with the procedures outlined in AMA Document #550. 

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the procedures outlined in AMA Document #560. 

C. FREE FLIGHT 

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is launched. 

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers. 

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has completed its function. 

D. CONTROL LINE 

1. The complete control system (including the safety thong where applicable) must have an inspection and pull test prior to flying. 

2. The pull test will be in accordance with the current Competition Regulations for the applicable model aircraft category. 

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for Control Line Precision Aerobatics. 

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer than 50 feet to any above-ground electric utility lines. 

5. The flying area must be clear of all nonessential participants and spectators before the engine is started.
Appendix C Operational 

Limitations

1. The unmanned aircraft system (UAS) will weigh less than 7 pounds, including energy source(s) 

and equipment. 

2. The UAS will not be flown at a ground speed exceeding 35 MPH.

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator’s manual. All altitudes reported to ATC 

must be in feet AGL. 

4. The UAS will 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.

5. All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times.

6. Prior to each flight the PIC will inspect the UAS to ensure 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, if utilized, will be 

included in the preflight inspection. All maintenance and alterations will be properly 

documented in the aircraft records. 

7. If the UAS has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, the UAS will undergo a 

functional test flight in accordance with the operator’s manual. The PIC who conducts the 

functional test flight will make an entry in the UAS aircraft records of the flight. The 

requirements and procedures for a functional test flight and aircraft record entry will be added to 

the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will 

be established and identified in the operator’s manual. At a minimum, requirements for the 

following will be included in the operator’s manual:

a. Actuators / Servos; 

b. Transmission (single rotor); 
c. Powerplant (motors); 

d. Propellers;

e. Electronic speed controller; 

f. Batteries;

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

i. Ground control station (if used); and 

j. Any other components as determined by the operator; 

9. The Pilot In Command (PIC) will possess at least a valid U.S. driver’s license. 

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 

14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating of the make and model of 

UAS to be utilized for operations and three take-offs and three landings in the preceding 90 

days. Training, proficiency, experience-building, and take-off and landing currency flights can 

be conducted to accomplish the required flight cycles and flight time. 

11. The UAS may not be operated directly over any person, except authorized and consenting 

personnel, below an altitude that is hazardous to persons or property on the surface in the event 

of a UAS failure or emergency. 

12 The operator will ensure that no persons are allowed within 500 feet of the area except those 

consenting. This provision may be reduced to no less than 200 feet if it would not adversely affect 

safety. 

13. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the Operator’s Manual.

14. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power 

remaining, whichever occurs first. 

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

Authorization (COA) prior to conducting any operations. 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. 

16. All aircraft operated in accordance will be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N- Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
17. Each UAS operated will comply with all manufacturer Safety Bulletins. 

18. The radio frequency spectrum used for operation and control of the UA will comply with the 

Federal Communications Commission (FCC) or other appropriate government oversight agency 

requirements. 

19. At least three days before scheduled flight, the operator will submit a written Plan of 

Activities to the local FSDO with jurisdiction over the area of proposed flight area. The 3- 

day notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator 

c. Make, model, and serial or N-number of UAS to be used; 

d. Name and certificate number of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the flight operations; the list of those who gave permission 

must be made available to the inspector upon request; 

f. Signature of exemption-holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which flights will be conducted and the altitudes essential to 

accomplish the operation.

20. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. 

21. The UA will remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing 

activities, hang gliders, etc.).

22. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

23. The UAS will not be operated by the PIC from any moving device or vehicle. 

24. The UAS 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. 

25. The UAS will not operate in Class A, B, C, or D airspace without written approval from the FAA. 

The UAS may not operate within 5 nautical miles of the geographic center of a non-towered 

airport 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. 

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours.