April 8, 2015 Brad Price

CEO

Manager, Flight Standards Service Precision Air Inc.

Unmanned Aircraft Systems Integration Office 5190 Eldridge Rd.

Federal Aviation Administration Terre Haute, IN 47802

800 Independence Avenue, SW (812) 870-3399

Washington, DC 20591 brad@precision-air.co

U.S. Department of Transportation, Docket Operation

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Request for exemption from multiple regulatory provisions to allow the use of small 

unmanned aerial systems on land controlled by clients of Precision Air Inc. to assist in the safe 

inspection and evaluation of agricultural, residential and timber real-estate.

Dear Sir or Ma’am,

Precision Air Inc. respectfully requests an exemption from several provisions of Title 14 of the 

Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems 

(sUAS) to assist in the inspection and evaluation of agricultural, residential and timber real-estate 

for our clients. This request is motivated primarily by the desire to maximize safety in 

infrastructure and operations. While an exemption would not eliminate the current need for inperson visual inspection, it would allow Precision Air to broadly evaluate assets and operations 

with sUAS, resulting in a safer and more efficient process. Accordingly, the grant of an 

exemption is consistent with Congress’ intent, reflected in Section 333 of the FAA 

Modernization and Reform Act of 2012 (Modernization Act)1, that safe systems be permitted in 

the national airspace prior to the issuance of final regulations governing general use of these 

systems.2 A summary of this request suitable for publication in the Federal Register is provided 

as Appendix A.

Appendix B provides the manufacturers information regarding the design, aircraft performance, 

and fail-safe features. We have provided manufacturer information related to operating 

limitations, normal and emergency procedures, and maintenance and inspection procedures. As 

we add aircraft designs, we will update this appendix appropriately.

Appendix C provides the Precision Air preflight, during flight and post-flight operating checklist.

1

P.L. 112-95, 126 Stat 11, February 14, 2012. 

2

Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, 

as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, and operations within visual 

line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security
Background Information

Precision Air is in the business of Consulting on and operating mission Specific sUAS for our 

clients. Precision Air clients look to us for safe operations of sUAS standards equal to or above 

those included in typical commercial aviation operations. We have developed specific UAV 

Operational Procedures that are required at all flight operations and are continually reviewed for 

improvement. Increasingly, we have clients looking to operate sUAS for agriculture, forestry and 

real-estate inspection.

Target Operations:

 Agriculture Inspection/Survey

 Timber Inspection/Survey

 Personal Real-Estate Inspection

 Commercial Real-Estate Inspection

 Aerial acquisitions used for inspections of public and private structures. 

 Search and Rescue operations

As part of this Precision Air is requesting FAA Exemption for sUAS operations for safety, 

inspection and video capture usage.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may 

grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in 

the public interest. The FAA has imposed a separate requirement in its procedural regulations, 

providing that the petitioner shall explain why granting the exemption would not adversely affect 

safety or how the exemption would provide at least an equivalent level of safety as compliance 

with the underlying regulation. In this case, approval of this exemption would advance the public 

interest by significantly enhancing the safety and efficiency of infrastructure operations and by 

providing the FAA with valuable user experience on sUAS in a context with appreciable 

economic and societal benefits. As described more fully below, the requested exemption would 

permit the operation of sUAS under tightly controlled conditions, thus ensuring that operations 

will not have an adverse impact on safety. To the contrary, as explained below, Precision Air 

anticipates that use of sUAS will enhance safety during inspection operations. Granting an 

Exemption is in the Public Interest. The safety and efficiency of inspection operations is heavily 

dependent upon aged technology encompassing many different risks. There are a wide variety of 

factors that can affect conditions and cause problems for during typical aerial inspection. Even 

relatively small objects or minor failures can lead to accidents or other incidents causing 

downtime or far worse. The potential for sabotage and terrorism – or even just trespassing – are 

also among the many risks that the aerial inspection industry faces.

As a result, pursuant to federal regulations and client policy, our client’s are forced to outsource 

their aerial inspections to companies operating with the before mentioned risks. At present, this 

work is done primarily by hiring fixed wing aircraft to fly long distances and take on an 

absorbent amount of risk in order to properly verify their inspections. This is often labor 

intensive, time restrictive and cost in-effective. While our clients do all they can to make these 
inspections as safe as possible, there is an irreducible element of risk involved to the public

whenever flights are conducted with large, fast moving aircraft. Equipment moving through 

inspection zones can increase risk as well, especially in high-traffic areas. While the use of sUAS 

for inspection and general asset evaluation would not eliminate these risks entirely (as it is an 

additive safety measure), it would reduce the risks to clients and the public by allowing for 

remote aerial review. 

Additionally, the sheer size of assets and the widely dispersed locations – in many instances far 

from sizeable population centers – means that visual inspection in all instances by client

personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft is impractical 

because the required altitudes for safe flight reduce visibility below meaningful levels – it is 

simply not possible to see all asset requirements from such heights. Helicopters present better 

vantage points; however manned helicopters are much more costly, subject to human safety and 

carry highly explosive jet fuel making them impractical for deployment. By using sUAS for 

supplemental asset evaluation, PRECISION AIR will be able to substantially upgrade its 

capacity to detect and address issues with the right-of-way and other assets before they become a 

problem for safe operations. Thus, the use of sUAS has the potential to improve efficiency, 

resulting in faster and safer environments for our clients and a safer airspace.

Granting an Exemption will not Adversely Affect Safety 

Precision Air notes that there is no applicable standard for an equivalency determination. Some 

have argued that the appropriate standard is that for model aircraft, noting that their operations, if 

conducted for recreational purposes, would fall completely within the allowable operations for 

model aircraft. We believe it is difficult to argue that there is sufficient correlation between 

model operations controlled by the Academy of Model Aeronautics and the ones contemplated 

by Precision Air. At the same time, it is clear that equivalency cannot be established for 

traditional, manned civil aircraft because the design and use profiles between traditional aircraft 

and sUAS are simply too different. As such, we believe it makes more sense to focus on why the 

contemplated operations would not adversely affect safety, which is all that §11.81(e) requires.

Granting an exemption will not adversely affect safety. Precision Air contemplates conducting 

sUAS operations over client owned or controlled land, solely during daylight hours, at altitudes 

well below that which would pose a risk to other aircraft. In general, sUAS operations are 

intended to be conducted in areas distant from both congested areas and airports. Moreover, 

because of the inherent risks presented by standard inspection evaluations, our clients have 

secured property against unauthorized public access. For example, all flights will be held over 

private property that is secured from outside intervention or will have reduced access during the 

time of operation. Other long stretches of infrastructure are, as noted above, in very remote 

wilderness areas. The nature of operations anticipated by Precision Air requires that the sUAS be 

flown at relatively low altitudes and relatively low speeds. Precision Air expects that in most 

instances, the sUAS will be flown less than 75 feet from the highest structure along the path of 

the sUAS. Accordingly, the risk of interference with another aircraft is minimal. Precision Air 

also plans to conduct sUAS operations at least three miles from any public airports (including 

heliports). In the event an operation needs to be conducted closer to an airport, Precision Air will 
inform the airport operator and airport air traffic control tower of the contemplated operation and 

will comply with any directions issued by air traffic control at that airport.

Approval of exemptions allowing commercial operations of sUASs in the real-estate aerial 

inspection industry will enhance safety by reducing risk. Conventional operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from the subject being 

inspected and in extreme proximity to people and structures; and present the risks associated 

with vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or 

other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the inspection site. 

In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all 

of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS is 

carried to the inspection site. The sUAS 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 55 lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including 333 Aircraft Exemption Status exempting the applicant from 

conventional aircraft requirements and allowing commercial operations. These lightweight 

aircraft operate at slow speeds, close to the ground, and in a controlled environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people.

The safety of those on the ground is protected by the fact that no one will be allowed into the 

area without the permission of the company. Security will be established for the flight area as 

part of the pre-flight control. Each individual within the secure area will be briefed prior to flight 

and will consent to being in the area. All others will be excluded from the area.

PRECISION AIR intends to use a dedicated staff for sUAS operations. All operations will be 

within visual line-of-sight (i.e., no more than approximately 0.5 miles from the manipulator of 

the controls, or pilot in command (PIC)). Each PIC will conduct at least three take-offs and 

landings with the sUAS on which he or she is trained every 90 days. PIC’s will establish their 

qualifications thru a combination of aeronautical knowledge, UAS airmanship skills, and 

verification through testing of flight ability before infrastructures operations have commenced. 

Depending on the type of operation, additional ground-based visual observers may be employed 

as well. These observers will be within constant visual line of sight and in constant contact with 

the PIC. The visual observers will assist the PIC in avoiding objects near the sUAS.

There are no standards for either Private or Commercial sUAS pilot certificates. The safe 

operation and control of the UAS as described in this application does not depend on the type of 

FAA license held by the PIC. Given the restricted and controlled airspace within which 

operations will take place, the key factors needed by the PIC are knowledge of the airspace 

within which the operation will take place and how that airspace fits into the National Airspace 

System (NAS). That knowledge can be and is gained primarily through ground school and not 

through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a 

commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the factors 

and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It 
cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing 

aircraft, has the skill or ability to safely operate a small unmanned aerial vehicle, operating at 

400 AGL or lower, within strictly controlled pre-approved airspace. Besides knowledge of 

airspace regulations, dexterity in the control and operation of the sUAS acquired from actual 

operation of the aircraft is the most important factor in establishing an equivalent level of safety.

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant issues are 

(1) where the aircraft will be flown, (2) the size of the aircraft relative to what is being used 

today to accomplish the same mission, and (3) what precautions will be taken to ensure the 

safety of those in the area of operation. We propose that the aircraft be operated within a secure 

environment; and that no one be allowed to enter the secure environment unless they are part of 

the operation, have been fully briefed of the risks prior to operation of the sUAS, and have 

consented to the risks associated with being in the operating area. Should there be a mishap, the 

sUAS being flown pose significantly less of a threat than the helicopters and fixed wing aircraft 

now being employed because they are a fraction of the size, carry no flammable fuel, do not 

carry crew or passengers, and pose an infinitesimal risk to others. This is in stark contrast to 

conventional aircraft that are flown to the site, carry explosive fuel, carry passengers and crew, 

and operate in a much larger area.

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who are 

also qualified to fly the type of sUAS that are utilized for infrastructure image-capture 

operations. There are even fewer commercial pilots that can fly these sUAS – to the point that to 

do both is considered rare. Assuming that it is unlikely for a company to find a pilot that has both 

qualifications, that company would either have to source a qualified sUAS pilot to train and 

obtain a commercial certificate, or find a commercial certificated pilot who would be willing to 

learn to fly a sUAS to the competency level required for professional use.

PRECISION AIR intends to use commercially available sUAS Components for sUAS. These 

sUAS systems will be tested for quality & safety in our test facility before being deployed to the 

field. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and 

operates exclusively within a secured area. We have a routine maintenance schedule to verify 

that the sUAS will remain in safe and operational condition. Please see Appendix B, for Specific 

Types of sUAS.

Notes Regarding: 14 C.F.R. Part 21, Subpart H 

In accordance with the statutory criteria provided in Section 333 of PL 112-95 in reference to 49 

USC 44704, and in consideration of the size, weight, speed, and limited operating area associated 

with the aircraft and its operation, we request that this aircraft exemption meets the conditions of 

Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any associated noise 

certification and testing requirements of part 36, is not necessary. 

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Given the size of the sUAV, two-inch lettering will be impossible. UA 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 will be as large as 

practicable. 
Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness 

PRECISION AIR’s request is based on the fact that no airworthiness certificate will be issued for 

the UAS. PRECISION AIR’s UAS will not require an airworthiness certificate in accordance 

with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness certificate will not be 

issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations was to display an aircraft’s 

airworthiness, certification, and registration documents so they would be easily available to 

inspectors and passengers. Based on the FAA Memorandum subject “Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft’s control station,” 

dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is 

not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests 

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 considered for use by PRECISION AIR 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 predetermined and/or safe 

landing location. PRECISION AIR does not describe training scenarios in which a dual set of 

controls would be utilized or required, i.e. dual flight instruction, provided by a flight instructor 

or other company-designated individual, that would require that individual to have fully 

functioning dual controls. Rather, PRECISION AIR evaluates the qualification of its PICs based 

on their experience with the UAS to be operated and verifies through testing, in lieu of 

formalized training. As such, PRECISION AIR does not seek relief from 14 CFR § 91.109.

Notes Regarding § 14 CFR 91.119(b) 

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, because the 

PRECISION AIR’s operations will only be conducted within the secured area described herein.

No Privacy Issues. 

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

Precision Air’s proposed operation of the UASs will not implicate any privacy issues. 

Specifically, the UASs will be operated only in compliance with operating documents (i.e., 

Flight Checklist, DJI Inspire 1 Instruction Manual) 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.
PRECISION AIR Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from 

highly-reputable industry partners will include features –

1. Auto descent (landing) if communication signal were to be severed. If the sUAS loses 

communications, the sUAS will have capability to return to a pre-determined location 

within the Security Perimeter and land. 

2. Auto descent (landing) if battery were to drop lower than nominal level. 

3. Flights will be terminated at 30% battery power reserve. 

4. Live video for operator gives real-time positioning feedback. In other words, we can 

monitor the scene from the vehicle's perspective for collision avoidance, and to maintain 

spatial orientation. 

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at 

all times: speed, altitude, number of GPS satellites (when available), heading and voltage. 

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link 

failures occur (highly improbable), vehicle returns automatically to the point of launch. 

8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed on board the aircraft, using 

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be 

established and confirmed for accuracy by the pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the 

pilot, thus eliminating the concern of signal severance (flying behind objects/walls). 

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots. 

3. Batteries should far exceed the capacity required for actual flight time. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site. 

6. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or 

as otherwise authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, 

gimbal op, director) 

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/communication. 
3. A briefing will be conducted in regard to the planned sUAS operations prior to each 

day’s activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 

4. The operator will obtain the consent of all persons involved in the sUAS operations 

and ensure that only consenting persons will be allowed within 100 feet of the flight 

operations. 

5. Observer and pilot will at all times be able to communicate by voice. 

6. Written and/or oral permission from the relevant property holders will be obtained. 

7. Pilot and observer will have been trained in operation of UAS generally and received 

up-to-date information on the particular UAS to be operated.

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including 

energy source(s) and equipment. Operations authorized by this petition of exemption 

are limited to the following aircraft described in Appendix B. Proposed operations of 

any other aircraft will require a new petition or a petition amendment to this request. 

2. The UA may not be flown at a ground speed exceeding 50 knots. 

3. Flights must 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 UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued medical certificate. 

5. All operations must 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. The operator’s checklist included as Appendix C and this petition of exemption must 

be maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operator’s manual, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator must follow the procedures 

as outlined in its operator’s manual. The operator may update or revise its operator’s 

manual. 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. If 

the operator determines that any update or revision would affect the basis for which 

the FAA grants this petition for exemption, then the operator must petition for 

amendment to their exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operator’s manual.
7. Prior to each flight the PIC must 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, must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight in accordance with the operator’s manual. The 

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

records of the flight. The requirements and procedures for a functional test flight and 

aircraft record entry must be added to the operator’s manual.

9. The operator must 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 must be established and identified in the operator’s manual. At a 

minimum, requirements for the following must be included in the operator’s manual: 

a. 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;

10. Prior to operations conducted for the purpose of real-estate inspections, the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and 

at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or 

multirotor). Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this petition of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, 

and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119.

11. Prior to operations conducted for the purpose of real-estate inspections, the PIC must 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of five hours as UAS pilot operating the make and model of UAS to be 
utilized for operations under the exemption and three take-offs and three landings in 

the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and 

landing currency flights can be conducted under this petition of exemption to 

accomplish the required flight time and 90 day currency. During training, proficiency, 

experience-building, and take-off and landing currency flights all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 

CFR § 91.119.

12. Prior to operations conducted for the purpose of real-estate inspections, a flight 

demonstration, administered by an operator-approved and -qualified pilot must be 

successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship 

test qualifications have been developed by the operator, and there are no established 

practical test standards that support a jurisdictional FAA FSDO evaluation and 

approval of company designated examiners, the petitioner will conduct these tests in 

accordance with the operator’s manual.

13. The UA 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.

14. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must 

be essential to the operations.

15. Regarding distance from nonparticipating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved 

and necessary for the infrastructure inspection operations. This provision may be 

reduced to no less than 200 feet if it would not adversely affect safety and the 

Administrator has approved it. For example, an equivalent level of safety may be 

determined by an aviation safety inspector’s evaluation of the infrastructure 

inspection area to note terrain features, obstructions, buildings, safety barriers, etc. 

Such barriers may protect nonparticipating persons (observers, the public, news 

media, etc.) from debris in the event of an accident.

16. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual.

17. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

18. Each UAS operation must be completed with 30% battery power remaining.
19. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this petition 

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.

20. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

21. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be 

added to the operator’s manual.

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

Bulletins.

23. The operator must develop UAS technician qualification criteria. These criteria must 

be added to the operator’s manual.

24. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator’s manual.

25. 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.

26. At least three days before scheduled flight, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with 

jurisdiction over the area of proposed flight. The 3-day notification may be waived 

with the concurrence of the FSDO. The plan of activities must include at least the 

following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS inspection operations 

conducted under this petition of exemption; 

c. Name and phone number of the person responsible for the on-scene operation 

of the UAS; 

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

e. Name and certificate number of UAS PICs involved in the inspection event; 
f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the inspection event; the list of those who 

gave permission must be made available to the inspector upon request; 

g. Signature of exemption-holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which inspection will be conducted and 

the altitudes essential to accomplish the operation.

27. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

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

enforcement official upon request.

28. The UA must 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.).

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

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

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

31. 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.

32. The UA may not operate in Class B, C, or D airspace without written approval from 

the FAA. The UA 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.

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. Further flight operations may not 

be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided.
Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, PRECISION AIR provides 

the following information:

Contact Information:

Bradley Price

CEO 

Precision Air Inc.

5190 Eldridge Rd.

Terre Haute, IN 47802

812-870-3399

brad@precision-air.co

admin@precision-air.co

Regulatory Provisions from which PRECISION AIR seeks an Exemption 

PRECISION AIR believes it may need an exemption from the following provisions to conduct 

the contemplated operations. In some instances, relief is needed because relief from another 

provision renders compliance with the regulation at hand infeasible.

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1)&(2) 

14 C.F.R. §91.417(a)&(b)

PRECISION AIR believes an exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional relief is required for PRECISION 

AIR to conduct the operations described here, we request an exemption from any such regulatory 

provisions as well.3

3

For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. Since none of the underlying 

requirements (e.g., inspection intervals) can be met and will require an exemption, PRECISION AIR believes a separate exemption should not be 

required for §91.417(a).
The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status: 

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 sUAS operated without an airworthiness 

certificate in the areas and under the conditions contemplated by PRECISION AIR 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 sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by the operator and observer. Operations will be 

conducted in compliance with the FAA and with local public safety requirements to provide 

security for the area of operation as is now done with conventional equipment, infrastructure, 

bridge and out building evaluation. These safety enhancements provide an expanded degree of 

safety to the 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. 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 sUAS. In all cases, 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 rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

14 C.F.R. §61.113(a) and (b) 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as pilot in command of an aircraft that is carrying 

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

or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation 

or hire, act as pilot in command 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. ***** 
PRECISION AIR anticipates initially using a cadre of specially trained staff to conduct the 

sUAS operations. While these individuals will not hold commercial pilot licenses. The sUAS

will not carry property for compensation or hire since they will be used solely to assist in 

evaluation of the agriculture, timber, commercial and residential real-estate in furtherance of 

PRECISION AIR’s client’s primary business. However, the employees’ operation of the sUAS 

will not be incidental to their employment with PRECISION AIR, and they will be compensated 

for such work. Without an exemption, the pilot would be required to hold a commercial pilot 

certificate under §61.133. However, the risk associated with the contemplated operations is less 

than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the 

permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a 

geographical envelope under the sole control of PRECISION AIR clients. Accordingly, the risk 

would be limited to PRECISION AIR personnel, who will be appropriately outfitted in safety 

gear, and PRECISION AIR client’s property on the ground. Requiring a commercial pilot 

certificate would provide no appreciable safety benefit and would needlessly impose additional 

cost on PRECISION AIR. Because the contemplated operations would not comply with 

§61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is needed from both 

paragraphs (a) and (b). 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General.

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. ***** 

PRECISION AIR 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, PRECISION AIR clients has 

exclusive use of the land over which the sUAS will be operated, and public access will be

restricted during time of operation. Any owner of significant portions of land adjacent to the 

primary objective will be made aware of flight operations in advance of said operation. 

PRECISION AIR’s Clients tightly control access to land and have the ability to assure that no 

individuals unassociated with the planned operations are on the affected land. As such, the risk 

of injury is minimal. PRECISION AIR does not contemplate conducting operations over 

congested areas, so relief is not requested from paragraph (b). 
14 C.F.R. 91.121 

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 altimeter setting available before departure.” ***** 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight. Altitude information will be provided to the sUAS pilot 

via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based 

on-screen display. This altitude information will be generated by equipment installed on board 

the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio 

altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be 

established and confirmed for accuracy by the pilot. 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. (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. (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. 

***** 

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve fuel does not raise 

the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it 

has to be flown to an alternate airport or circle the planned airport in the event of unanticipated 

conditions. PRECISION AIR does not intend to use the sUAS for point-to-point flights and will 

not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order 

to land. Rather, PRECISION AIR will operate the sUAS using pre-planned flight paths (taking 

into account weather conditions) designed to allow the sUAS to fly to the point of intended 

landing. As such, there is no need for a timebased excess fuel requirement. Rather it should be 

sufficient to require only as much additional excess flight capacity as necessary to safely land the 

sUAS. We believe that a 30% battery reserve is more than sufficient to meet this objective. 
14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & 

(b) 

§91.405 Maintenance required.

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; ***** 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

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

rebuilding, or alteration unless – (1) It has been approved for return to service by 

a person authorized under §43.7 of this chapter; ***** 

§91.409 Inspections.

(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. ***** 

§91.417 (a) & (b) *****

PRECISION AIR believes that an exemption from these three maintenance requirements is 

appropriate because the FAA has not developed maintenance standards that would allow an 

operator to meet the part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct 

the initial airworthiness and annual return to service inspections required by §91.409(a). 

PRECISION AIR will maintain the aircraft as instructed in the owner’s manual and ASTM 

F2909, where applicable, and will not operate the aircraft until it has reasonably determined that 

any needed repairs have been made. However, because of the technical impossibility of meeting 

the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), we believe an exemption from 

these provisions is appropriate. Please do not hesitate to contact me at the phone number or via 

the e-mail address provided above should you have any questions or concerns. 

Respectfully submitted,

Bradley Price

CEO, Precision Air Inc
Appendix A 

Summary for Federal Register Publication 

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

Register should the FAA determine that publication is needed. 

Petitioner: Precision Air Inc 

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 

61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 91.417(a)&(b) 

to conduct sUAS operations over Precision Air Client’s owned or controlled land, solely during 

daylight hours, to assist in the safe evaluation and analysis of infrastructure and operations. In 

general, sUAS operations are intended to be conducted in areas remote from both congested 

areas and airports. The nature of operations anticipated by Precision Air requires that the sUAS 

be flown at relatively low altitudes. Precision Air expects that in most instances, the sUAS will 

be flown less than 75 feet from the highest structure along the path of the sUAS and in no 

instances will be flown higher than 400 feet above the ground. Accordingly, the risk of 

interference with other aircraft is minimal.
Appendix B

Specific type(s), make, and model

#1 DJI Inspire 1

Link to Flight Manuals

 DJI Inspire 1 User Manual 1.0

 DJI Inspire 1 Safety Guidelines

 Intelligent Flight Batter Safety Guidelines V1.0

 DJI Inspire 1 Maintenance Manual V1.0
Appendix C

Please see attached operation checklist.