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Integrity	Management, LLC

James	G. Grubbs	– Owner

9001	Faulkner	Lane

Knoxville,	TN	37922

Phone:	(865)	560-3100

Email:	jgrubbs@integritymgt.com

August	19,	2015

U.S.	Department	of	Transportation	(DOT)

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Exemption	Request

As	follows	please	find	the	Integrity	Management,	LLC		(“Integrity	Management”)	

request	for	an	exemption	from	the	listed	Federal	Aviation	Regulations	to	allow	

commercial	operation	of	the	DJI	Phantom	3 Small	Unmanned	Aircraft	Systems	

(“UASs”)	for	aerial	surveying,	safety	and	monitoring	of	secured	and	controlled	

environment	of	Telecommunication/Cell	tower	sites.	This	exemption	request	is	

exclusively	for	the	use	of	the	UAS	operated	by	Integrity	Management,	LLC,	a	

Tennessee	based	company.

Also	attached	to	this	letter	is	the	DJI	Phantom	3	UAS	User	Manual and	Safety	

Guidelines	and	Disclaimer (“the	Manual”),	which	outlines	the	operating	

requirements,	limitations,	maintenance	and	technical	specifications	for	the	DJI	

Phantom	3	UAS.	

Thank	you	for	your	time	and	consideration,	please	contact	me	with	any	questions.

Regards,

James	G. Grubbs

Integrity	Management,	LLC	
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August	19,	2015

U.S.	Department	of	Transportation	Docket

Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	from	14	CFR	Part	21;	14	CFR	61.113	(a)	&	(b);	91.7	(a);	

91.9	(b)	(2);	91.103	(b);	91.109;	91.121;	91.151	(a);	91.203	(a) &	(b);	91.405	(a);	

91.407	(a)	(1);	91.409	(a)	(1)	&	(a)	(2);	91.417	(a)	&	(b).

Dear	Sir	or	Madam:

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

(the	Reform	Act)	and	14	C.F.R.	Part	11,	Integrity Management,	LLC	(“Integrity	

Management”),	operator	of	the	DJI	Phantom	3	Small	Unmanned	Aircraft	System(s)	

(“UASs”),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	

Regulations	(“FAR”)	to	allow	commercial	operation	of	its	UASs	for	aerial	surveying	

of	structures,	equipment	condition,	safety	and	monitoring	of	Telecommunication	/	

Cellular	Towers	in	a	secured	and	controlled	environment,	so	long	as	such	operations	

are	conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	

established	by	the	FAA	as	required	by	Section	333.

As	detailed	in	this	document	and	the	attached	UAS	Flight	Manual,	the	

requested	exemption	would	permit	the	operation	of	UAS	under	controlled	

conditions	in	airspace	that	is	1)	limited	2)	predetermined	3)	controlled	as	to	access	

and	4)	would	provide	safety	enhancements	best	practices	safety	protocols	followed	

by	Integrity	Management	at	Telecommunication/Cellular	Tower	sites.	Approval	of	

this	exemption	would	thereby	enhance	safety	and	fulfill	the	Secretary	of	

Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	“...establish	

requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	

system.”	Section	333(c)	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is:

Integrity	Management,	LLC

James	G. Grubbs

PH:	865-510-3100

Email:	jgrubbs@integritymgt.com

Address:	9001	Faulkner	Lane,	Knoxville,	TN	37922

Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	Part	21

14	C.F.R.	61.113	(a)	&	(b)
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14	C.F.R.	91.7	(a)

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

14	C.F.R.	91.103	(b)

14	C.F.R.	91.119	(c)

14	C.F.R.	91.121

14	C.F.R.	91.151	(a)

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

14	C.F.R.	91.405	(a)

14	C.F.R.	407	(a)	(1)

14	C.F.R.	409	(a)	(1)	&	(a)	(2)

14	C.F.R.	417	(a)	&	(b)

STATUTORY	AUTHORITY	FOR	EXEMPTIONS

The	Federal	Aviation	Act	expressly	grants	the	FAA	authority	to	issue	

exemptions.	This	statutory	authority	includes	exempting	civil	aircraft,	as	the	term	is	

defined	under	40101	of	the	Act,	including	UASs,	from	the	requirement	that	all	civil	

aircraft	must	have	a	current	airworthiness	certificate.

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	

regulation prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections	

44702-44716	of	this	title	if	the	Administrator	finds	the	exemption	in	the	public	

interest.	49	U.S.C.	44701(f)	See	also	49	USC	44711(a);	49	USC	44704;	14	CFR	

91.203(a)(1).

Section	333(b)	of	the	Reform	Act	assists	the	Secretary	in	determining	

whether	UAS	may	operate	in	the	Nation	Airspace	System	(NAS)	without	creating	a	

hazard	to	the	user,	the	public,	or	a	threat	to	national	security.	In	making	this	

determination,	the	Secretary	must	consider:

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

• Whether	the	UAS	operates	within	the	visual	line	of	sight	of	the	PIC;

• Whether	the	UAS	operates	outside	of	highly	populated	areas	and	away	from	

close	proximity	to	airports.

Reform	Act	333(a).	If	the	Secretary	determines	that	a	UAS	“may	operate	safely	in	the	

national	airspace	system, the	Secretary	shall	establish	requirements	for	the	safe	

operation	of	such	aircraft	in	the	national	airspace	system.”	Id.	333	(c).

Integrity	Management’s	UASs	are	multi-rotor	vehicles,	weighing	less	than	15	

lbs. including	payload.	They	operate	under	normal	conditions	at	a	speed	of	no	more	

than	50	mph	and	have	the	capability	to	hover,	and	move	in	the	vertical	and	

horizontal	plane	simultaneously.	The	UASs	will	operate	only	in	the	visual	line	of	

sight	(VLOS)	of	the	PIC	at	all	times.	Operations	will	take	place	only	within	the	

controlled	environments	around	Cellular	towers.	These	operations	will	insure	that	
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the	UASs	will	“not	create	a	hazard	to	users	of	the	national	airspace	system	of	the	

public.”	Reform	Act	Section	333	(b).

Provided	the	small	size	of	the	UASs	involved	and	the	controlled	environment	

within	which	they	will	operate,	our	application	is	equivalent	to	the	level	of	safety	in	

which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow	commercial	

operations	of	UASs	to	commence	immediately.

In	addition,	due	to	the	small	size/weight	of	the	UASs,	the	low	altitudes	and	

controlled	areas	in	which	our	UASs	will	operate,	approval	of	the	application	

presents	no	national	security	issues.

Given	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	

contained	in	the	Federal	Aviation	Act,	as	amended;	the	strong	equivalent	level	of	

safety	surrounding	the	proposed	operations,	and	the	significant	public	benefit,	

including	enhanced	safety,	the	grant	of	the	requested	exemptions	is	in	the	public	

interest.	Accordingly,	Integrity	Management	respectfully	requests	that	the	FAA	

grant	the	requested	exemption	without	delay.

PUBLIC	INTEREST

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

passing	Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	

of	Transportation	to	consider	whether	certain	unmanned	aircraft	systems	may	

operate	safely	in	the	NAS	before	completion	of	the	rule	making	required	under	

Section	332	of	the	Reform	Act.	By	granting	an	exemption the	FAA	will	fulfill	

Congress’s	intent	of	allowing	UASs	to	operate	with	significant	safety	precautions	in	

low	risk	environments.

The	telecommunications	industry	provides	the	gateway	for	emergency	

communication	and	response	capabilities.	As	well,	tower	climbers	have	one	of	the	

most	dangerous	jobs	in	America	with	multiple	deaths	per	year.	A	UAS	can	gather	

valuable	information	to	help	increase	safety	and	productivity	while	limiting	the	

need	for	tower	climbers.	Falls	are	the	leading	source	of	workplace	fatality	and	

injury,	and	reducing	falls	through	UAS	use	for	site	surveying	could	save	worker’s	

lives	while	providing	the	necessary	information	to	make	sure	communications	are	

operating	properly.

EQUIVALENT	LEVEL	OF	SAFETY

Integrity	Management	proposes	that	the	exemption	requested	herein	apply	

to	civil	aircraft	that	have	the	characteristics	and	that	operate	with	the	limitations	

listed	herein.	These	limitations	provide	for	at	least	an	equivalent	or	even	higher	

level	of	safety	to	operations	under	the	current	regulatory	structure	because	the	

proposed	operations	represent	a	safety	enhancement	to	the	already	safe	protocols	
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followed	in	Telecommunications/Cell	tower	sites	and	imaging	and	surveying	

operations.

Integrity	Management	will	be	bound	by	the	following	when	conducting	its	UAS	

operations	under	an	FAA	issued	exemption:

• The	UA	will	weigh	less	than	15	pounds.

• Flights	will	not	exceed	the	indicated	air	speed	of	50	mph	(43.3	knots).

• Flights	will	be	operated	at	or	below	an	altitude	never	exceeding	400	feet	AGL.

• The	UA	will	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	and	

potential	observers	at	all	times.

• The	PIC	will	follow	the	operations	and	maintenance	procedures	outlined	in	

the	UAS	Flight	Manual	at	all	times.

• Prior	to	each	flight	the	PIC	will	inspect	the	UAS	to	ensure	it	is	in	a	safe,	

operational	condition	per	the	UAS	Flight	Manual.

• Any	UA	that	has	undergone	maintenance	will	undergo	a	functional	test	flight.

• All	operators	will	be	required	to	demonstrate	the	ability	to	safely	operate	the	

UAS	in	a	manner consistent	with	what	is	outlined	in	the	UAS	Flight	Manual,	

including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	

distances	from	people,	vessels,	vehicles	and	structures.

• UAS	operations	will	not	be	conducted	during	the	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)	will	not	be	conducted.

• The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	

horizontally	from a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	

the	PIC.

• If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA	will	return	to	

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

and	land	or	be	recovered	in	accordance	with	the	UAS	Flight	Manual.

• The	PIC	will	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	

emergencies	in	accordance	with	the	UAS	Flight	Manual.

• The	PIC	is	prohibited	from	beginning	a	UAS	flight	unless	(considering	wind	

and	forecast	weather conditions	and	assuming	normal	cruising	speed)	there	

is	enough	power	to	fly	to	the	first	point	of	intended	landing	prior	to	utilizing	

battery	reserve	power.

• Before	conducting	operations,	the	radio	frequency	spectrum	used	for	

operation	and	control	of	the	UA	must	comply	with	the	Federal	

Communications	Commission	(FCC)	or	other	appropriate	government	

oversight	agency	requirements.

• 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	UA	is	operating.	

These	documents	will	be	made	available	to	the	Administrator	or	any	law	

enforcement	official	upon	request.

• The	UA	will	remain	clear	and	yield	the	right	of	way	to	all	other	manned	

aviation	operations	and	activities	at	all	times.
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• The	UA	will	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.

• The	UA	will	not	be	operated	over	congested	or	densely	populated	areas.	

These	areas	include	but	are	not	limited	to	the	yellow	areas	depicted	on	

World	Aeronautical	Charts	(WAS),	Sectional	Aeronautical	Charts	(sectionals),	

or	Terminal	Area	Charts	(TAC).

• All	operations	shall	be	conducted	over	private	or	controlled-access	property	

with	permission	from	the	land	owner/controller	or	authorized	

representative.	

• Any	incident,	accident,	or	flight	operation	that	transgresses	the lateral	or	

vertical	boundaries	of	the	operational	area	will	be	reported	to	the	FAA’s	UAS	

Integration	Office	(AFS-80)	within	24	hours.	Accidents	will	be	reported	to	the	

National	Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	

the	NTSB	website:	www.ntsb.gov.

DESCRIPTION	OF	SPECIFIC	REGULATIONS

Regarding	the	Unmanned	Aircraft	System	(UAS)

14	C.F.R. Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	91.203(a)(1)

Subpart	H, entitled	Airworthiness	Certificates,	establishes	the	procedural	

requirements	for	the	issuance	of	airworthiness	certificates	as	required	by	FAR	

91.203	(a)(1).	Given	the	size	and	limited	operating	area	associated	with	the	aircraft	

to	be	utilized	by	Integrity	Management,	an	exemption	from	Part	21	Subpart	H	meets	

the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	

the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	

an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,	

operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	

particular	UAS.	Our	small	UAS	will	be	operated	at	low	speed	in	a	controlled	

environment,	at	least	five	miles	from	an	airport	and	more	than	three	miles	from	any	

city	or	densely	populated	area.	An	analysis	of	these	criteria	demonstrates	that	the	

UAS	operated	without	an	airworthiness	certificate,	in	the	restricted	environment	

and	under	the	conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	

conventional	aircraft	(fixed	wing	or	helicopter)	operating	with	an	airworthiness	

certificate	without	the	restrictions	and	conditions	proposed.

The	UAS	to	be	operated	hereunder	is	less	that	15lb.	fully	loaded,	carries	neither	a	

pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	

operates	exclusively	within	a	secured	area	as	set	out	in	the	Manual.	Like	other	civil	

aircraft,	operations	under	this	exemption	will	be	tightly	controlled	and	monitored	

by	the	operator,	pursuant	to	the	Manual’s	requirements,	and	under	the	

requirements	and	in	compliance	with	local	public	safety	requirements,	to	provide	

security	for	the	area	of	operation	as	is	currently	done	on	active	Telecommunication/

Cell	tower	sites.	
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These	safety	enhancements,	which	already	apply	to	civil	aircraft	operated	in	

connection	with	Telecommunication/Cell	towers,	provide	a	greater	degree	of	safety	

to	the	public	and	property	owners	than	conventional	operations	conducted	with	

airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	Lastly,	

application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	

national	security	posed	by	the	UAS,	due	to	its	size,	speed	of	operation,	location	of	

operation,	lack	of	explosive	materials	or flammable	liquid	fuels.

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

Maintenance	Inspections

These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft	

inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	

inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	

repaired	as	prescribed	in	part	43	of	this	chapter...,”	and	others	shall	inspect	or	

maintain	the	aircraft	in	compliance	with	Part	43.

Given that these	sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	

certificate,	these	sections	will	not	apply	to	Integrity	Management.	Maintenance	will	

be	accomplished	by	the	operator	pursuant	to	the	UAS	Flight	Manual.	An	equivalent	

level	of	safety	will	be	achieved	because	these	small	UASs	are	very	limited	in	size	and	

will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	limited	periods	of	

time.	If	mechanical	issues	arise	the	UAS	can	land	immediately	and	will	be	operating	

from	no	higher	than	400	feet	AGL.	As	provided	in	the	Manual,	the	operator	will	

ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required	

maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	the	

manufacturer	and	operator	is	most	familiar	with	the	aircraft	and	best	suited	to	

maintain	the	aircraft	in	an	airworthy	condition	to	provide	the	equivalent	level	of	

safety.

Regarding	the	Pilot	In	Command	(PIC)	of	the	UAS

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

command

Sections	61.113	(a)	&	(b)	limit	private	pilots	to	non-commercial	operations.	Because	

the	UAS	will	not	carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve	

the	equivalent	level	of	safety	of	current	operations	by	following	the	requirements	

listed	in	the	Manual.

Unlike	a	conventional	aircraft	that	carries	the	pilot	and	passengers,	the	UAS	is	

remotely	controlled	with	no	living	thing	or	cargo	on	board.	The	area	of	operation	is	

controlled	and	restricted,	and	all	flights	are	planned	and	coordinated	in	advance.	

The	risks	associated	with	the	operation	of	the	UAS	are	so	diminished	from	the	level	

of	risk	associated	with	commercial	operations	contemplated	by	Part	61	when	
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drafted,	that	allowing	operations	of	the	UAS	as	requested	above	via	a PIC	exceeds	

the	present	level	of	safety	achieved	by	14	C.F.R.	61.113	(a)	&	(b).

Regarding	the	Operating	parameters	of	the	UAS

14	C.F.R.	91.7	(a):	Civil	aircraft	worthiness

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is in	

airworthy	condition.	As	there	will	be	no	airworthiness	certificate	issued	for	the	

aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for	

determining	airworthiness.	Given	the	size	of	the	aircraft	and	the	requirements	

contained	in	the	Manual	for	maintenance	and	use	of	safety	checklists	prior	to	each	

flight	an	equivalent	level	of	safety	will	be	provided.

14	C.F.R.	91.9	(b)(2):	Civil	Aircraft	Flight	Manual,	marking,	and	placard	

requirements

The	UAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	UAS	

Flight	Manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	

because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.

The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	UAS	Flight	Manual	

at	the	ground	control	point	where	the	pilot	flying	the	UAS	will	have	immediate	

access	to	it.

Based	on	the	FAA	Memorandum	“Interpretation	regarding	whether	certain	required	

documents	may	be	kept	at	an	UA’s	control	station,”	dated	August	8,	2014	the	

requested	relief	from	91.9(b)(2)	may	not	be	necessary.

In	addition,	the	FAA	has	issued	the	following	exemptions	to	this	regulation:	

Exemption	Nos.	8607,	8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,	

32827,	and	10700.

14	C.F.R.	91.203	(a)	&	(b):	Carrying	civil	aircraft	certification	and	registration

This	regulation	provides	in	part:

(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...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.
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The	UAS	fully	loaded	weighs	no	more	than	15	lb.	and	is	operated	without	an	

onboard	pilot.	Therefore	there	is	no	ability	or	place	to	carry	certification	and	

registration	documents	or	to	display	them	on	the	UA.

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

ground	flight	control	point	where	the	pilot	flying	the	UAS	will	have	immediate	

access	to	them,	to	the	extent	they	are	applicable	to	the	UAS.	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.

In	addition,	based	on	the	FAA	Memorandum	“Interpretation	regarding	whether	

certain	required	documents	may	be	kept	at	an	UA’s	control	station,”	dated	August	8,	

2014	the	requested	relief	from	91.203	(a)	&	(b)	may	not	be	necessary.

14	C.F.R.	91.103(b):	Preflight	Action

This	regulation	requires	each	pilot	in	command	take	certain	actions	before	flight	to	

ensure	the	safety	of	flight.	An	exemption	is	needed	from	this	requirement	as	the	

pilot	will	take	separate	preflight	actions,	including	checking	for	weather	conditions,	

checking	flight	battery	requirements,	checking	takeoff	and	landing	distances,	and	all	

other	actions in	the	Preflight	Checklist	of	the	Manual.	These	actions	will	provide	an	

equivalent	level	of	safety.

14	C.F.R.	91.109:	Flight	Instruction

Section	91.109	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	

manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	

fully	functioning	dual	controls.

By	design,	UASs	and	remotely	piloted	aircraft	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.	As	a	result,	training	will	

be	conducted	during	dedicated	sessions	following	the	guidelines	in	the	Manual.

The	FAA	has	previously	approved	exemptions	for	aircraft	without	fully	functional	

dual	controls.	See	Exemption	Nos.	5778K	&	9862A.	The	equivalent	level	of	safety	

provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	

aircraft,	the	ability	to	control	the	UAS	via	radio	signals	from	the	controller,	and	by	

the	size	and	speed	of	the	aircraft.

14	C.F.R.	91.119(c):	Minimum	Safe	Altitudes

Section	91.119(c) prescribes	that,	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	
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sparsely	populated	areas.	In	those	cases,	the	aircraft	may	not	be	operated	closer	

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

This	exemption	is	for	a	multi-rotor	craft	that	flies	similarly	to	a	helicopter,	with	a	

vertical	takeoff	and	vertical	landing,	which	will	typically	operate	at	altitudes	from	0	

feet	to	400	feet	AGL,	so	an	exemption	may	be	need	to	allow	such	operations.	The	

UAS	will	never	operate	at	altitude	higher	than	400	AGL	and	will	be	in	a	restricted	

area	with	security	perimeter,	where	buildings	and	people	will	not	be	exposed	to	

operations	without	their	pre-obtained	consent.	

The	equivalent	level	of	safety	can	be	achieved	where	all	UAS	Flight	operations	will	

be	conducted	at	least	500	feet	from	all	nonparticipating	persons	(persons	other	than	

the	PIC	or	VO),	vessels,	vehicles,	and	structures	unless:

a. Barriers,	fencing	or	structures	are	present	that	sufficiently	protect	

nonparticipating	persons	from	debris	in	the	event	of	an	accident.	The	

operator	will	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	will	cease	

immediately	and/or;

b. The	aircraft is	operated	near	vessels,	vehicles	or	structures	where	the	land	

owner/controller	has	granted	permission	and	the	PIC	has	made	a	safety	

assessment	of	the	risk	of	operating	closer	to	those	objects	and:

c. Operations	near	the	PIC	do	not	present	an	undue	hazard	to	the	PIC	,	per	

91.119(1).

In	addition,	the	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.	No	flight	will	be	taken	

without	the	permission	of	the	authorized	representative.	Compared	to	flight	

operations	with	aircraft	or	rotorcraft	weighing	far	more	than	the	maximum	15	lb.	

proposed	herein	and	carrying	flammable	fuel,	any	risk	associated	with	our	

operations	is	far	less	than	those	presently	presented	with	helicopters	and	other	

conventional	aircraft	operating	at	or	below	500	AGL	in	the	telecommunications	

industry.

14	C.F.R.	91.121:	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	

altitude	by	reference	to	an	altimeter	that	is set	“...to	the	elevation	of	the	departure	

airport	or	an	appropriate	setting	available	before	departure.”	As	the	UAS	may	not	

have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	

be	needed.

The	UA	will	automatically	provide	onboard	GPS	altitude	information	to	the	UAS	PIC	

via	a	radio	communications	telemetry	data	link,	which	downlinks	from	the	aircraft	
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to	the	PIC	and	is	displayed	on	the	Ground	Station	Controller	for	active	monitoring	of	

the	flight	information.

An	equivalent	level of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	

Manual	and	Safety	Checklist,	confirming	the	altitude	of	the	launch	site	shown	on	the	

GPS	altitude	indicator	before	flight.

14	C.F.R.	91.151	(a):	Fuel	requirements	for	flight	in	VFR	conditions

Section	91.151	(a)	outlines	fuel	requirements	for	beginning	a	flight	in	VFR	

conditions.	Our	UAS	is	limited	to	operations	in	sterile	and	controlled	environments	

as	outlined	in	the	Manual,	and	has	a	limited	range	and	flight	time	which	require	an	

exemption	from	14	CFR	91.151(a).

The	battery	powering	the	UAS	provides	up	to	approximately	35	minutes	of	powered	

flight.	To	meet	the	30	minute	reserve	requirement	in	14	CFR	91.151,	UAS	flights	

would	be	limited	to	5	minutes	in	length. Given	the	limitations	on	the	UAS’s	proposed	

flight	area	and	the	location	of	its	proposed	operations	within	a	predetermined	area,	

a	longer	time	frame	for	flight	in	daylight	VFR	conditions	is	reasonable.

Integrity	Management	believes	that	an	exemption	from	14	CFR	91.151(a)	falls	

within	the scope	of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	

Martin	Corporation	to	operate	without	compliance	with	FAR	91.151(a)).	Operating	

the	small	UAS,	in	a	secure	controlled	area	with	less	than	30	minutes	of	reserve	fuel,	

does	not	engender	the	type	of	risks	that	Section	91.151(a)	was	intended	to	alleviate	

given	the	size	and	speed	of	the	small	UAS.	Additionally,	limiting	UAS	flights	to	5	

minutes	would	greatly	reduce	the	utility	for	which	the	exemption	will	be	granted.

An	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to 30	minutes,	or	

enough	battery	reserve	to	ensure	that	that	UAS	lands	at	the	ground	station	with	at	

least	20%	of	battery	power	whichever	happens	first.	The	Integrity	Management	UAS	

onboard	power	management	system	continuously	monitors	flight	time	and	amount	

of	battery	power.	It	transmits	this	information	to	the	PIC	at	the	ground	station	in	

real-time.	Similar	exemptions	have	been	granted	to	other	operations,	including	

Exemptions	2689F,	5745,	10673,	and	10808.

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:

Applicant	seeks	an	exemption	from	the	following	rules:	14	C.F.R. 21,	subpart	H;	14	

C.F.R.	61.113	(a)	&	(b);	91.7	(a);	91.9	(b)	(2);	91.103	(b);	91.109;	91.119	(c);	91.121;	

91.151	(a);	91.203	(a)	&	(b);	91.405	(a);	91.407	(a)	(1);	91.409	(a)	(1)	&	(a)	(2)	and	

91.417	(a)	&	(b)	to	operate	commercially	a	small	unmanned	vehicle	(15lb.	or	less)	in	

its	operations.
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Approval	of	exemptions	allowing	commercial	operations	of	UASs	enhances	safety	

while	reducing	risk.	Manned	aircraft	monitoring	and	surveying	creates	a	greater	

risk	because	the	craft	are	much	larger,	have	combustible	fuel,	and	carry	an	onboard	

human	pilot.	In	contrast,	a	UAS	weighing	fewer than	10	lb.	and	powered	by	batteries	

eliminates	virtually	all	of	that	risk	given	the	reduced	weight	and	lack	of	combustible	

fuel	carried	on	board.	The	UAS	will	carry	no	passengers	or	crew	and,	therefore,	will	

not	expose	them	to	the	risks	associated	with	manned	aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	15	lb.,	conducted	in	the	strict	

conditions	outlined	above	and	in	the	manual,	will	provide	an	equivalent	level	of	

safety	supporting	the	grant	of the	exemptions	requested	herein,	including	

exempting	the	applicant	from	the	requirements	of	Part	21	and	allowing	commercial	

operations.	These	lightweight	aircraft	operate	at	slow	speeds,	close	to	the	ground,	

and	in	a	sterile	environment	and,	as	a	result,	are	far	safer	than	conventional	

operations	conducted	with	turbine	helicopters	operating	in	close	proximity	to	the	

ground	and	people.

Privacy

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

owner’s	prior	consent	and	knowledge.	Images	taken	will	be	of	individuals	who	have	

also	consented	to	being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where	

aerial	photography	will	take	place.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	– size,

weight,	speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	

operation	within	visual	line	of	sight	and	national	security	– provide	more	than	

adequate	justification	for	the	grant	of	the	requested	exemptions	allowing	

commercial	operation	of	applicant’s	UASs	in	the	telecommunications	industry	

pursuant	to	the	Manual	appended	hereto.

Sincerely,

James	G. Grubbs

Owner

Integrity	Management,	LLC