Date: Aug 18th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of the Michael R. Limotta & Co., Inc. DBA "LIMOTTAIT.com" , for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, LIMOTTAIT.com ("Company") hereby applies for an exemption from the Federal Aviation 

Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles 

(i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting controlled flights for aerial sensor 

research, precision agriculture research, UAS flight training and maintenance. Additionally will provide for

14-21 young adult education in the fields of aerial robotic applications, gamification programs and sharing 

services.

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as but not limited to these accompanying documents; 

1. Company Flight Operations Manual and;

2. Company Operations Manual 

(collectively referred to as "Company’s Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual")

1

The Company submits these as well as other Company supporting materials as confidential 

documents pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or 

proprietary information that the Company has not and will not share with others. Additionally, these

documents contain operating conditions and procedures that are not generally available to the public and

are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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Aug 18th, 2015

Page 2

This Petition is organized as follows:

I. Petitioner

II.Description of Proposed Operations

A. Aerial Sensor and Systems Research, Agriculture Systems Research, Precision 

Agriculture, and UAS Education.

II.Relevant Statutory Authority

IV. Company’s Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

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

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

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

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

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

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

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

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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Aug 18th, 2015

Page 3

I. DESCRIPTION OF PETITIONER

Based in Solvang, California, Michael R. Limotta & Co., Inc, the (Company) since 1997, has been 

supplying IT Services and automation solutions to SMB, Mid-market and enterprise businesses primarily 

focusing on Hospitality, Education and Brewery verticals. Existing relationships in agriculture (wine, crop 

production in Santa Maria, Santa Ynez and the Solvang valleys) increasing automation opportunities in the 

field of the grape Brewery industry. Historical experience in system design and data collection techniques 

via probes and sensors with 3rd party software products, has helped the Company in creating a data 

acquisition platform that includes UAS of varying sizes and typologies. Currently the Company is 

developing a turn-key Managed Agriculture Automation kit system and cloud based data storage services 

system. Additionally, the Company created LEARNROBOTS.org a 501c3 to provide training and education selfsustained business providing mentor-mentee matching, cloud based services and kit deliverables for STEM-UAS

(hands-on), STEM-UAS Competition opportunities for pre-teen and teen robotic sciences. The Company seeks an

exemption to allow the Company to commercially operate UAS to facilitate controlled flights for aerial 

sensor research, precision agriculture research, UAS flight training and maintenance. Additionally will 

provide for 14-21 young adult education in the fields of aerial robotic applications, gamification programs 

and sharing services.

The contact information for Petitioner is as follows:

Michael R. Limotta & Co., Inc. DBA "LIMOTTAIT.com" 

320 Alisal Road, #101 

Solvang, CA 93463

888-884-6278

mlimotta@limottait.com

II.DESCRIPTION OF PROPOSED OPERATION

Company seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Phantom 

II, S1000 also known as, (LI-UAS) for the proposed operations discussed below. All UAS operations will 

occur under tightly controlled conditions at locations where Company has received permission to operate

from the landowner, controller or authorized representatives. The proposed UAS operations will be 

conducted in accordance with the conditions and limitations of this Petition for Exemption and Company’s

Operations Manuals. As detailed in Company’s Operations Manuals, all UAS operations will be limited to 

daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator and or (“VO”) visual 

observers, in uncontrolled airspace, and will occur at least 5 nm away from an airport. Moreover,

Company’s Operations Manuals incorporate redundant safeguards to assure that the aircraft does not travel 

outside the controlled area of UAS operations, including GPS "geo-fencing" technologies.

A. Aerial Sensor and Systems Research, Agriculture Systems Research, Precision 

Agriculture, and UAS Education.
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Aug 18th, 2015

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Company seeks to use small UASs for the purpose of conducting commercially UAS for sensor and 

systems aerial research, agriculture systems research, precision agriculture operations and UAS education.

Additionally, the Company has tailored its operations to meet the requirements established by the FAA in 

prior grants of exemptions authorizing commercial use of UAS in aerial research, agriculture, and 

education for UAS flight training, maintenance and industry application uses including:

 Counsel for Mountain High Aviation, LLC (Exemption No. 11581)

 Soundview Aerial Photography (Exemption No. 12189)

 TRIMBLE NAVIGATION LTD (Exemption No. 11110)

 SkyWard IO, Inc. (Exemption No. 11521)

 Turin Aviation Group (Exemption No. 11895)

 Michael Baker International, LLC (Exemption No. 11711)

 M2 Flight Solutions, LLC (Exemption No. 11519)

 BizUAS Corp, (Exemption No. 11351)

All UAS aerial missions and operations will be conducted at approved property in a controlled area, 

away from spectators and persons not involved. All UAS aerial missions and operations will be conducted 

during daylight hours, VFR conditions, at altitudes below 400' AGL. As set forth below, Company’s

operations provide a superior level of safety and quality compared to performing the same filming work 

using conventional fixed-wing aircraft or helicopters.

Company seeks to use small UASs for the purpose of conducting controlled flights for aerial 

sensor research, precision agriculture research, UAS flight training and maintenance. Additionally will 

provide for14-21 young adult education in the fields of aerial robotic applications, gamification programs 

and sharing services. Traditional methods of aerial research in education for UAS flight training, 

maintenance and industry application use is extremely important for the national education of UAS and for 

the growth and expansion of the UAS industry and the hundreds of UAS application uses. The growth of 

the small UAS industry will ultimately reduce uncalled for risk, physical harm, serious injury and death 

associated with the manned aircraft that currently perform and number of aerial tasks. Further, the use of 

traditional aircraft exposes participants and pedestrians a risk of dangerous low level aircraft engine failure 

making recovery or emergency landings as one of the extremes. The use of small UASs mitigates these

hazards and is ultimately a much safer method of performing these and most all applications where the 

need for aerial operations are required.

Small UAS aerial research in education for UAS flight training, maintenance and industry application 

uses is much safer than the use of traditional manned aircraft performing the same function. Conventional 

operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated with 

vehicles weighing thousands of pounds and carrying large amounts of fuel. It is important to note that the

use of small UAS in this area will not only be safer and more cost effective, but the quality of collected 

data and information is far superior. 
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Small UAS aerial research in Education for UAS flight training, maintenance and industry application 

uses is more reliable, and allows for the collection, dissemination, and storage of visual and other sensory

data with greater precision and duration. Small UASs are also capable of accessing and inspecting areas 

and many other tasks that would otherwise be inaccessible to humans or cannot be completed with 

conventional aircraft.

III. 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).

IV. Company’s PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION

333 OF THE REFORM ACT

The small UAS operations proposed by Company 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.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the LI-UAS UASs due to its size weight, 

speed, and operational capability.
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Aug 18th, 2015

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 The LI-UAS has been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 The LI-UAS weighs less than 55 pounds, including payload.

 The LI-UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety

and predictability of the system. If connection to the remote control or ground control station is 

lost, failsafe systems will permit the UAS to return to a predetermined location and safely land

without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the LI-UAS is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference

in weight between the LI-UAS and a helicopter significantly reduces the potential harm to the participating

and non- participating individuals or property in the event of an accident or incident. In addition, the risk to 

the onboard pilot and camera operator is eliminated.

 ______________________

2

See e.g., Grant of Exemption to Michael Baker International, LLC (Exemption No. 11711),

M2 Flight Solutions, LLC (Exemption No. 11519), BizUAS Corp, (Exemption No. 11351).
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Aug 18th, 2015

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B. Approval is Warranted Based on the Operational Restrictions Set Forth in Company’s 

Operations Manuals

Company’s Operations Manuals and the Manufacturer's Manual for the selected UASs will contain all

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

Petition for Exemption. To assist the FAA in making a safety assessment of Company’s proposed 

operations, below is a summary of operational limitations and conditions that Company will adhere to, and 

which will ensure an equivalent or higher level of safety to operations conducted under current regulatory

guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

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

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

authorized representative will be obtained for each flight operation.

3. All UASs operated under the Grant of Exemption 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.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the UAS, and one or more Visual Observers ("Observer") as necessary to safely conduct 

the mission.

5. PICs shall possess at least a Sport Pilot's Certificate and current Class III Medical Certificate and/or 

a valid state driver’s license. The PIC will also meet the flight review requirements specified in 14 

C.F.R 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the Company’s 

Operations Manuals. 
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Aug 18th, 2015

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The Operations Manuals will be maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in the Grant of Exemption and Company’s

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and must 

be followed. Otherwise, Company shall follow the procedures outlined in their Operations Manuals.

10. Company may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. Company will also present an updated

and revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption. If an

update or revision would affect the basis upon which the FAA grants the exemption, Company will seek an 

amendment to its Grant of Exemption. Company will contact the FAA’s UAS Integration Office (AFS-80) if

questions arise regarding updates or revisions to the operating documents.

11. Company’s Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the UAS is operating.

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

conditions) there is enough power to fly to the first intended point of landing, and assuming normal cruising

speed, to fly after that for at least 10 minutes.

13. Maximum total flight time for each operational flight using the LI-UAS will be limited to 40 

minutes or the amount of time the UAS can be flown and still maintain a reserve battery power of no less 

than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the structure

being inspected exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest 

point on the structure, and no more than 50 feet horizontally from the structure.

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

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating

persons remain under such protection. If a situation arises where nonparticipating persons leave

such protection and are within 500 feet of the UA, flight operations must cease immediately

and/or;
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b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such

vessels, vehicles or structures has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an undue

hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

16. 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.

17. The UA may not operate within 5 miles of an airport reference point as denoted on a current FAApublished 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 Company COA. The letter of

agreement with the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. 

The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, 

not already covered in the relevant sections of the operating documents. The PIC shall not operate the UAS

if the inspection reveals a condition that affects the safe operation of the UAS until the necessary

maintenance has been performed and the UAS is found to be in a condition for safe flight. The ground 

control station shall be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS records as required by Company’s Operations Manuals.

19. Company students will learn to will carry out its maintenance, inspections, and record keeping 

requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be 

noted in the UAS records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service.

20. 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 Company Operations Manuals. The PIC who conductsthe functional test flight must make an

entry in the UAS aircraft records of the flight. The requirements and proceduresfor a functional test flight and

UAS record entry shall be included in the Company’s Operations Manuals.
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21. The UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

Company’s Operations Manuals.

23. Company will learn how to obtain an Air Traffic Organization ("ATO") issued Certificate of 

Waiver or Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

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

potential transponder requirements.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or

emergencies.

28. PICs and Observers will have at least a current Class III Medical Certificate or a valid state 

driver’s license.

29. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a 

UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type.

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, in a 

manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR § 61.51(b), a minimum of 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 landing in the preceding 90 days.
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31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall 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.).

33. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The UAS will not be operated from an elevated platform or moving device / vehicle.

35. Before conducting operations, 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.

V. REGULATIONS FROM WHICH EXEMPTION IS 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.

3

Company seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a

UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety better 

than or equal to the rules from which exemption is sought.

4

_________________________________________

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption would

provide a level of safety at least equal to that provided by the rule from which you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

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. These criteria are met, and therefore no exemption is needed.

5 If, however, 

the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements 

of the Reform Act, an exemption is requested.

Equivalent Level of Safety

Company’s use of the LI-UAS is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), the LIUAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in excess 

of 50 knots. UAS is also equipped with safety features that will allow Petitioner to operate the UAS

safely after experience certain in-flight contingencies or failures.

6,7

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [DJI S1000] has the capability to operate safely after experiencing certain in-flight contingencies or

failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to respond

to a loss of global positioning system (GPS) or a lost-link event with a pre-coordinated, predictable,

automated flight maneuver, and manual flight control functionality as a backup. These safety features

provide an equivalent level of safety compared to a manned aircraft performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The LI-UAS with upgrades can be operated entirely by a touch-screen, map-based interface. This means

the operator only needs to command the system where to go, and the system does all the flying for the 

operator. The LI-UAS can be operated in both semi and fully autonomous flight modes. In addition, the LIUAS with upgrades comes with pre-programmed no fly zones the UAS cannot enter areas.

{footnote continued}
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Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within the parameters stated in Company’s Operations Manuals.

Operations conducted 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. Company will also provide the FAA with advance notice of all operations via NOTAMs as

required by the applicable COA. In all cases, operation of the LI-UAS under the proposed conditions will be

at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and Observer, who are not onboard the UAS.

8 In addition, no 

sense-and-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the PIC and Operator.

9

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

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that Company’ss small UASs would otherwise require

certification under Part 27, Petitioner seeks 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, supra.

{continued from previous page}

deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent

fault handling which allowsthe LI-UAS to detect a system fault while in the air and automatically fly back

to its takeoff location and land. Faults that can be detected include: loss of communication; exceeding preset wind thresholds; and low battery levels. 

All flight operations are global positioning system (GPS) controlled, making the system easy to navigate.

At any point if the operator is not explicitly commanding the system to move, the system automatically 

holds its GPS position. The flight control system employs not only GPS positioning but a variety of sensors

including sonar, barometric pressure, temperature, wind speed and othersto ensure stability so long as wind

thresholds are not exceeded. Also a flight termination link – to prevent a 'fly away' or other potentially

dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. 
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

Company seeks an exemption from the aircraft marking and identification requirements contained in 

14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or

"provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, 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."

10

Equivalent Level of Safety

All UA flown by Company will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

11

__________________________

10

FAA Docket No. FAA-2014-0352.

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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Page 15

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

Company seeks an exemption from the maintenance inspection requirements contained in

14 C.F.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.F.R. Part 43. See, e.g., 14 C.F.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 to be operated under this grant of exemption will not have.

Equivalent Level of Safety

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

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by Company’s Operations Manuals, the PIC will conduct a pre-flight inspection of the 

UAS and all associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe operation of

the UAS and no flights will occur unless, and until, all flight critical components of the UAS have been 

found to be airworthy and in a condition safe for operation. A functional test flight will be conducted 

following the

replacement of any flight-critical components. As required by Company’s Operations Manuals, the PIC who 

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

Company’s Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, Company’s Operations Manuals also 

includes 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 UASs used 

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in 

Company’s Operations Manuals ensure that an equivalent or higher level of safety will be achieved.

 
U.S. Department of Transportation

Aug 18th, 2015

Page 16 PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Company seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for

hire. In this case, while the UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

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

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions Company has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial. Company will operate on private property away from persons and property not

involved in the operation. Company will also obtain an ATO issued COA prior to conducting any operations 

under this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 

NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, Company will further ensure safe operation by requiring that 

any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will

have experience not only in UAS operations generally but have logged flight time in the specific make and

model used for the operations before they are permitted to participate in commercial flights on behalf of

Company. The pilot qualification, training, and currency requirements in the Operations Manuals ensure that 

Company’s pilots are competent and proficient in the UAS they are operating. Company’s training and 

qualification requirements are consistent with those contained in prior FAA Section 333 Grants of 

Exemption, and will provide a higher level of competency and proficiency for its pilots and will ensure at 

least an equivalent level of safety.

_____________________

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Aug 18th, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the UASs, Company 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 that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

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

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

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

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved 

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

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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.

13

See id. at 13-14, 22 
U.S. Department of Transportation

Aug 18th, 2015

Page 18

Given the small size and configuration of the UASs, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS because there is simply no room and the UAS has 

no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be

achieved by ensuring that the pilot has access to the documents at the ground control station from which he

or she is piloting the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

Company seeks an exemption from 14 C.F.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.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the Company’s Operations Manuals and 

the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the Company’s Operations Manuals, including checklists

covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review

weather, flight requirements, battery charge, landing and takeoff distance, UA performance data, and

contingency landing areas—before initiation of flight. Company’s Operations Manuals and the 

Manufacturer's Manual will be kept at the ground control station and will be accessible to the PIC at all

times while operating the UAS.

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

14Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
U.S. Department of Transportation

Aug 18th, 2015

Page 19

Company seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part 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." UASs 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. Accordingly, an exemption will be 

required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that Company intends to use, an equivalent level of safe

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

as required by the Company’s Operations Manuals, all persons will be a safe distance away in the event that 

the UAS experiences any difficulties during flight instruction. Moreover, as required by the Company’s

Operations Manuals, all flight training will be conducted in controlled and sterile environment. As a whole,

the safety procedures provided for in Company’s Operations Manuals ensure that the proposed UAS

operations provide an equivalent or higher level of safety than that provided by the flight instruction 

regulations.

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

Company requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).

15 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

helicopters by the FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and within 

50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or

Observers(s) may need to be less than 500 feet away from the UAS.

____________________

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b)

will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial 

(FAA-2014-0534 at 15)
U.S. Department of Transportation

Aug 18th, 2015

Page 20

Equivalent Level of Safety

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

herein, and given the lack of flammable fuel with the UASs, 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 UASs, as well the controlled location where the operations will 

occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or 

below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest 

point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person 

is in a position where he or she is shielded from the UAS and any possible debris resulting from UAS failure. 

As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet 

of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from 

vehicles or structures unless the property owner/controller has granted permission and the PIC has made a

safety assessment of the risk of operating closer to those objects and, operations near the PIC or Observer 

will not present an undue hazard per § 91.119(a). Adherence to these restrictions in the elevation of the 

departure airport or barometric pressure. An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out. Company’s Operations Manuals will ensure

operations can be conducted without compromising safety.

16

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

Company 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 UASs do not have a

barometric altimeter, but rather a GPS altitude read out.

____________________________

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the UA or

debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such

protection. The operator must also ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight

operations must cease immediately. When considering how to immediately cease operations, the primary 

concern is the safety of those nonparticipating persons. In addition, the FAA finds that operations may be 

conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any such

vessels, vehicles orstructures grants permission for the operation and the PIC makes a safety assessment of

the risk of operating closer to those objects and determines that it does not present an undue hazard.”
U.S. Department of Transportation

Aug 18th, 2015

Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that Company intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by Company’s Operations Manuals, the PIC will be required to 

calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of 

Exemption, the UASs Company intends to use, and the safety mitigation procedures contained in the

Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a Grant of 

Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Company requests an exemption from 14 C.F.R. § 91.151(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 battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required.

__________________________________

17

If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more

than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

Aug 18th, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a LI-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. In reaching this conclusion, the FAA considered that 

the UAS batteries for the LI-UAS provided provide approximately 20 minutes of powered flight (with 

payload) and provided battery level and battery time remaining in minutes and seconds to the PIC.19 The 

FAA also considered the fact that the LI-UAS operating manual states: “start every flight with a fully 

charged battery in the aerial vehicle”, and that in the event that the UAS should run low on power, the PIC 

will be alerted and can land the LI-UAS as soon as possible. Like the VDOS Grant of Exemption, 

Company use of the LI-UAS, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the LI-UAS unless (considering wind and forecast weather 

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

the UA with 25% battery power remaining. Company will adhere to this limitation for LI-UAS flights. 

The LI-UAS includes a low battery warning system and the amount of battery reserve power

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a groundbased-on-screen display.20 As required by Company’s Operations Manuals, the PIC will promptly fly the 

UAS back to the home launch location or pre-determined abort location where the UAS may safely land, 

while still maintaining a minimum of 25% reserve battery power. Company submits that the procedures 

requiring flights to be safely terminated once the batteries fall below 25% capacity, combined with the 

requirement that flights only be conducted within a secure, isolated area, using a UAS weighting less than 

55 pounds, and within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide 

an equivalent or higher level of safety to that provided by the regulations from which exemption is sought. 

______________________________

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The LI-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS. 
U.S. Department of Transportation

Aug 18th, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

Company will have policies in place to ensure that no person may participate in UAS flight 

operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting Company’s Petition for Exemption. Congress has 

established a national policy that favors early integration of UAS into the NAS in controlled, safe working

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improves safety and 

reduces risk, harm or serious injury to farmers, employees, maned pilots, crews and other participants. New 

methods of aerial research, agriculture and education for flight training, maintenance and industry 

applications use is extremely important for the national education of UAS and for the growth and 

expansion of the UAS industry, the hundreds of applications and the thousands on jobs. The growth of the 

small UAS industry will ultimately reduce uncalled for risk, physical harm, serious injury and death 

associated with the manned aircraft that currently perform and number of aerial tasks. Further, the use of 

traditional aircraft exposes participants and pedestrians a risk of dangerous low level aircraft engine failure 

making recovery or emergency landings as one of the extremes. The use of small UASs mitigates these

hazards and is ultimately a much safer method of performing these and most all applications where the 

need for aerial operations are required.

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no passengers 

or crew. Further, in the unlikely event of an accident, Company small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit from a reduction in 

harmful emissions associated with conventional aircraft performing in the same functions proposed herein. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption to filmmakers, UASs provide 

an additional tool for the aerial filming industry, adding a greater degree of flexibility, which supplements 

the current capabilities offered by manned aircraft.22

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAS will weigh 

less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard pilot

and crew during an incident or accident is eliminated with the use of a UA for the aerial filming operation." 

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Aug 18th, 2015

Page 24

VIII. PRIVACY 

All Company UAS operations will be conducted in accordance with applicable federal, state, or 

local laws regarding privacy. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

IX. 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:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & 

(b).

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

the substantial hazards associated with performing equivalent controlled flights for aerial sensor research, 

precision agriculture research, UAS flight training and maintenance. Additionally will provide hospitality 

and 14-21 young adult education such as aerial robotic applications, gamification programs and sharing 

services with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

Company 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 VLOS and national security. The proposed UAS operations will benefit the public as a whole by 

improving safety and reducing risk by alleviating human exposure to danger. In consideration of the 

foregoing, this Petition for Exemption provides the FAA with more than adequate justification for granting 

the requested exemptions allowing Company to use small UASs for controlled flights for aerial sensor 

research, precision agriculture research, UAS flight training and maintenance. Additionally will provide for

14-21 young adult education in the fields of aerial robotic applications, gamification programs and sharing 

services.
U.S. Department of Transportation

Aug 18th, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully submitted,

Michael R. Limotta

Michael R. Limotta & Co., Inc. DBA "LIMOTTAIT.com" 

320 Alisal Road, #101 

Solvang, CA 93463

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

Michael R. Limotta & Co., Inc. DBA "LIMOTTAIT.com" 

Phone: 888-884-6278

Email: mlimotta@limottait.com

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals