August 3, 2015

Exemption No. 12289

Regulatory Docket No. FAA–2015–1231

Mr. Frank Mastrandrea

Curve and Line LLC

3625 Elwing Avenue

Eugene, OR 97401

Dear Mr. Mastrandrea:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 17, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Curve and Line LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct video filming 

and photography; inspections of land, residential commercial and industrial structures and 

property; and UAS training .

1

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

 

1 The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize 

UAS operations for training until a further assessment is completed. When the FAA completes its review, we 

will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is 

permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the 

other conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Curve and Line LLC is granted an exemption from 

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

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Curve and Line LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

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

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. 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 airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 
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documents must be accessible during UAS operations 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 operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 
5

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

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

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

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

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

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 
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exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. 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 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, 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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. 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 
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reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. 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 aerial filming conducted 

under this grant 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 aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production 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 filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 17, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of Curve and Line LLC for an Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 

Dear Sir or Madam: 

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

("Reform Act") and 14 C.P.R. Part 11, Curve and Line LLC hereby applies for an 

exemption from the Federal Aviation Regulations ("FARs") identified below, to 

allow commercial operations of small-unmanned aerial vehicles. 

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

the accompanying DJI Inspire I Operators Manual (Appendix B) and the Curve 

and Line LLC Operational Limitations (Appendix C). The DJI Inspire I UAS was 

selected because it has a proven capability for controlled flight as well as a gyro 

stabilized flight mode, GPS aided navigation, a compass, blinking LED’s on the 

bottom, a failsafe mode for returning home, and prop guards. These devices are 

offered for general sale around the world and have often been used as Model 

Aircraft in the USA. 

Specifically, the UAS is: 

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

operated 4- motor rotorcraft in the form of a quadcopter that takes off and lands 

vertically, manufactured by DJI, Model Inspire I, with the following equipment: 

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

receives signals for flight controls from a ground-based 

transmitter/controller; 

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

high definition still photos and video; 

• An on-board telemetry system that delivers flight data from the on-board 

flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction 

back to its launch site; 

• A 600mW, 5.8GHz on-board radio transmitter that transmits live video 

from the on-board camera plus all the flight data from the telemetry 

system described above; 
The Ground Station Includes: 

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

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

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

control the UAS while in flight; 

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

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

view during flight; 

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

visually track the UAS while in flight. 

Proposed Operations

Curve and Line LLC intends to use UAS in three general areas. First, Curve and 

Line LLC seeks an exemption to perform video filming and photographing by air 

for public and private use. Second, it will employ UAS’s to inspect land, 

residential commercial and industrial structures and property. Third, Curve and 

Line LLC seeks permission to use UAS to offer training to persons, from both 

private and public entities, which are interested in the safe operation of UAS.

Specifically, Curve and Line LLC will use UASs, which are equipped with 

cameras and sensors, in order to engage in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, 

including: television, cinematography, advertising, promotions, public or 

news mass events.

(b) Video filming by air and photographing to support professional operations 

in engineering, land surveying, architecture, real estate and other related 

professional activities. 

(c) Inspections by air of agricultural areas. 

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

installations, dams, aqueducts, photovoltaic power stations, wind farms 

and pipes. These inspections will only be done under contract with the 

owners or with any local government authority. 

(e) Inspection by air of land and residential, commercial and industrial 

structures, only under contract with the owners or with any local 

government authority. 
 (f) Inspections by air to detect sources of pollution and gas emissions, under 

contract with the owners in the area or with any local government 

authority. 

 (g) Support provided to search and rescue operations and reconnaissance 

in cases of need, emergency or natural disasters and only when 

government authorities have requested it by contract or donation. 

 (h) Curve and Line LLC is passionate about offering training to persons, 

private and public entities, which are interested in the safe use of UASs, 

for purposes of enhancing the skills and safety controls which make the 

NAS safer and for the protection of persons and property.

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). 

Curve and Line LLC Proposed UAS Operations Meet the Requirements of 

Section 333 of the Reform Act 

Curve and Line LLC proposed operations in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the 

statutory criteria and relevant factors are satisfied. 
Approval is Warranted Based on the UAS Size, Weight, Speed, and 

Operational Capability 

Curve and Line LLC will employ the DJI Inspire I quadcopters for the operations 

specified in this Petition for exemption. The Inspire I UASs have a maximum 

take-off weight of less than 7 pounds, the flight speed will not exceed 35 miles 

per hour, and it will not be flown in controlled airspace or at an altitude that 

exceeds 400 feet AGL. All flights will be flown in such a way that they can be 

safely terminated with a reserve battery power of 25% of the battery's maximum 

charge. The DJI Inspire I UAS do not carry any flammable propellant or fuel. The 

Inspire I UAS also has an integrated GPS system that calculates the UAS’s 

position and height and relays that information via a secure connection to the 

operator. Additionally, the Inspire I UAS contain a failsafe mode if its connection 

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

predetermined location and land without injury or damage. For additional safety, 

the Inspire I will be retrofitted with prop guards. 

Approval is Warranted Based on the Operational Restrictions Set Forth in 

the Operations Manual.

The Curve and Line LLC Operations Limitations and the DJI's operator’s manual 

contain all of the procedures and limitations necessary to successfully perform 

the operations specified in this Petition for Exemption. (Appendices B&C). 

Public Interest 

Granting Curve and Line LLC Petition for Exemption will serve the public interest. 

Congress has established a national policy that favors early integration of UASs 

into the NAS in controlled, safe working environments such as those proposed in 

this Petition. In addition, the public also has an interest in reducing the hazards 

associated with alternate methods of conducting similar operations. Currently 

operations are conducted using teams that physically climb onto structures using 

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

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

conducting the operation while remaining safely on the ground. 

Additionally, Curve and Line LLC intended uses for the UAS’s have identifiable 

safety benefits that include reducing the danger and emissions associated with 

full size helicopters, UAS have no fuel to ignite or explode, no crew, adds a 

greater degree of flexibility, which supplements the current capabilities offered by 

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

UAS is further minimized from an ecological and safety standpoint. 

Federal Register Summary 

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

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

Curve and Line LLC seeks an exemption from the following rules: 

Parts 21; §§ 45.23(b); 27; 61.113(a) and (b); 61.3; 91.7(a); 91.9(b)(2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR). 

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

property owners from the substantial hazards associated with performing 

equivalent work with conventional aircraft, rotorcraft, or other methods.

Conclusion 

Curve and Line LLC Petition for Exemption satisfies the criteria articulated in 

Section 333 of the Reform Act of 2012 including weight, speed, operating 

capabilities, proximity to airports and populated areas, operation within visual line 

of sight and national security. Additionally, the Petition provides more than 

adequate justification for the grant of the requested exemptions to permit Curve 

and Line LLC to operate the selected UAS for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, 

including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing 

operating costs compared with conventional flight operations. 

Respectfully, 

Frank Mastrandrea

3625 Elwing Ave

Eugene, OR 97401

Mastf7@gmail.com

Appendix A 

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

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

may be found together with our proposed equivalent level of safety for each 

regulation:
Parts 21,§§ 45.23(b); 27, 61.113(a) and (b) 61.3; 91.7(a); 91.9(b)(2); 91.103; 

91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR). 

Exemptions Requested 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil 

aircraft, as the term is defined under§ 40101 of the Act, including UASs, from its 

safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. 

Curve and Line LLC seeks an exemption from several interrelated provisions of 

14 C.F.R. Parts 21, 27, 45, 61 and 91 for purposes of conducting the requested 

operations using a UAS. Listed below are the specific sections of 14 C.F.R. for 

which exemption is sought: 

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

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

made under the Reform Act that the UAS selected provides an equivalent level of 

safety when compared to aircraft normally used for the same application. 

(Regulatory Docket No. FAA-2014-0352). These criteria are met, and therefore 

no exemption is needed.

Equivalent Level of Safety

The UAS selected by Curve and Line LLC is safe when taking into account their 

size, weight, speed, and operational capability. The UAS weigh less than 7 

pounds and will be flown at less than 35 miles per hour and completely outside 

controlled airspace. Additionally, the UAS carry neither pilots nor passengers, 

carry no explosive materials and or flammable liquid fuels, and operate 

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

Operations Limitations.

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

operator and will be conducted in compliance with local public safety 

requirements, to provide security for the area of operation. Curve and Line LLC

will also provide the FAA with advance notice of all operations via NOTAMS and 

coordination with the local FSDO. In all cases, the UAS operated under the 

proposed conditions, will be at least as safe as, or safer than conventional 

rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions of the proposed UAS operations.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft
14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness 

certification of normal category rotorcraft. To the extent the Curve and Line LLC

UAS would otherwise require certification under Part 27, we seek an exemption 

from Part 27's airworthiness standards for the same reasons identified in the 

request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§45.23(b), Display of marks; general

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

registration number in letters at least 2 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. The UAS does not have an 

entrance in which the word "EXPERIMENTAL" can be placed, and may not have 

a registration number assigned to it by the FAA.

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

FAA determined that exemption from these requirements was warranted 

provided that the aircraft "have identification (N-Number) markings in accordance 

with 14 C.F.R part 45, Subpart C if the markings are as large as practicable."

14 CFR § 61.113 (a) and (b): Private Pilot Privileges and Limitations, Medical 

Certificate

In addition, Curve and Line LLC seeks exemption from 14 C.F.R § 61.113, which 

restricts private pilot certificate holders from flying aircraft for compensation or 

hire, and which would also require a second class medical certificate. The 

purpose of this section is to ensure the skill and competency of any PIC where 

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

will be operated as part of a commercial operation, it carries neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the 

FAA determined that the unique characteristics of UAS operation outside of 

controlled airspace did not warrant the additional cost and restrictions attendant 

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

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

suggest that the PIC exercise the privileges similar to that of a sport pilot, 

requiring only a valid US driver’s license.

Safety Mitigation

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

versed in airspace and communication issues pertaining to all aircraft operators 

but also in the unique aspects of UAS flight. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness
Curve and Line LLC seeks an exemption from 14 C.F.R. § 91.7(a), which 

requires that a civil aircraft be in airworthy condition to be operated. The FAA has 

stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required to 

the extent that the requirements of Part 21 are waived or found inapplicable.

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

Given its size, configuration, and load capacity, the Inspire I has no ability to 

carry such a manual on the aircraft, not only because there is no pilot on board, 

but because there is simply no room or capacity to carry such an item on the 

aircraft.

Safety Mitigation

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

by maintaining the Inspire I Manual at the ground control point where the pilot 

flying the Inspire I will have immediate access to it. Accordingly, we request an 

exemption from § 91.9(b) (2)'s flight manual requirements, on the condition that 

the Inspire I flight manual be available at the control point during each operation.

14 C.F.R. § 91.103: Preflight Action

Curve and Line LLC seeks an exemption from 14 C.P.R.§ 91.103, which requires 

a PIC to become familiar with specific information before each flight, including 

information contained in the FAA-approved Flight Manual on board the aircraft. 

While the PIC will be familiar with all information necessary to safely conduct the 

flight, an exemption is requested to the extent that an FAA-approved Flight 

manual is required.

Safety Mitigation

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

Manual and flight manual provided by the manufacturer. The PIC will take all 

required preflight actions- including performing all required checklists and 

reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas- before 

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

at the ground station with the operator at all times.

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

Curve and Line LLC seeks an exemption from 14 C.F.R. § 91.109(a), which 

provides that "no person may operate a civil aircraft (except a manned free 

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

functioning dual controls." UAS and remotely piloted aircraft, by their design, do 
not have functional dual controls. Instead, flight control is accomplished through 

the use of a device that communicates with the aircraft via radio communications.

Safety Mitigation

Given the size and speed of the UAS employed by Curve and Line LLC, an 

equivalent level of safe training can still be performed without dual controls 

because no pilot or passengers are aboard the UAS, and all persons will be a 

safe distance away in the event that the UAS encounters any difficulties during 

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

Development test sites, which are located on its own property. These training 

flights will be conducted in a sterile area and will otherwise comply with the 

provisions in the Operator’s Manual for flights at the R&D facility. The FAA has 

stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

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

Curve and Line LLC requests an exemption from the minimum safe altitude 

requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe 

altitudes under which aircraft may not operate, including 500 feet above the 

surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to 

operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA.

Safety Mitigation

Compared to flight operations with rotorcraft weighing far more than the 

maximum weights proposed herein, and given the lack of flammable fuel, any 

risk associated with these operations is far less than those that presently exist 

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

size, weight, and speed of the UAS, as well as the location where it is operated. 

In order to avoid any risk to aircraft, flight operations will be restricted to 400' AGL 

or below.

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

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

person operating an aircraft to maintain cruising altitude or flight level by 

reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. An exemption is required to the extent that the UAS do not 

have a barometric altimeter, but rather a GPS altitude read out.
Safety Mitigation

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

will be operated at 400' AGL or below and within visual line-of-sight in addition to 

GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352. As the attached 

Operations Manual indicates, the chosen UAS meets these requirements, and a 

zero altitude initiation point will be obtained prior to flight

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

Curve and Line LLC requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 states:

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

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed –

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

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

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

meaningful flight operations can be conducted while still maintaining a 30 minute 

reserve. Curve and Line LLC proposes that all flights comply with this 

requirement by mandating that the aircraft be safely landed with no less than 

25% of battery life remaining.

Safety Mitigation

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

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

Exemption to Astraeus Aerial, Docket No. PAA-2014-0352. The Operations 

Manual conforms to this limit, providing an equivalent level of safety.

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

The regulation provides that an airworthiness certificate, with the registration 

number assigned to the aircraft and a registration certificate must be aboard the 

aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate 

be "displayed at the cabin or cockpit entrance so that it is legible to passengers 

or crew."

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

documentation, does not have an entrance, and is not capable of carrying 

passengers or crew. To obtain an equivalent level of safety and meet the intent 
of 91.203, we propose that documents deemed appropriate for this aircraft by the 

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

for inspection upon request. The FAA has stated (Regulatory Docket No. FAA2014-0352) that no exemption is required.

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

Maintenance Required

Curve and Line LLC seeks an exemption from the maintenance inspection

requirements contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 

91.417(a) and (b). These regulations specify maintenance and inspection 

standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. § 91.405(a) 

(stating that each owner or operator of an aircraft "[s]hall 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 

UASs will not have.

Safety Mitigation

An equivalent level of safety will be achieved because maintenance and 

inspections will be performed in accordance with the Operators Manual. As 

provided in the Operators Manual, flights will not be conducted unless a flight 

operations checklist is performed that includes all of the aircraft's components.

Appendix B:

Inspire_1_User_Manual_v1.0 (Attached)

For Inspire 1 Firmware v1.2.1.0

Appendix C 

Operational Limitations 

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

energy source(s) and equipment. 

2. The UAS will not be flown at a ground speed exceeding 35 MPH. 
3. Flights will be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operator’s manual. 

All altitudes reported to ATC must be in feet AGL. 

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses. 

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times. 

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station, if utilized, will be included in the preflight 

inspection. All maintenance and alterations will be properly documented in the 

aircraft records. 

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

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

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

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

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

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

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

maintenance, overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements will be established and identified in the 

operator’s manual. At a minimum, requirements for the following will be included 

in the operator’s manual: 

a. Actuators / Servos; 

b. Transmission (single rotor);

c. Powerplant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 
g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

i. Ground control station (if used); and 

j. Any other components as determined by the operator; 

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

10. The UAS may not be operated directly over any person, except authorized 

and consenting personnel, below an altitude that is hazardous to persons or 

property on the surface in the event of a UAS failure or emergency. 

11. The operator will ensure that no persons are allowed within 500 feet of the 

area except those consenting. This provision may be reduced to no less than 200 

feet if it would not adversely affect safety. 

12. The UAS will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual. 

13. Each UAS operation will be completed within 30 minutes flight time or with 

25% battery power remaining, whichever occurs first. 

14. Each UAS operated will comply with all manufacturer Safety Bulletins. 

15. 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. 

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

and/or local officials to conduct the flight operations; the list of those who gave 

permission must be made available to the inspector upon request; 

f. Signature of exemption-holder or representative; and 

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

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

essential to accomplish the operation. 

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

operations and activities at all times (including, but not limited to, ultralight 

vehicles, parachute activities, parasailing activities, hang gliders, etc.). 
17. UAS operations will not be conducted during night, as defined in 14 CFR § 

1.1. All operations will be conducted under visual meteorological conditions 

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

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

19. The UAS will not be operated less than 500 feet below or less than 2,000 feet 

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

PIC. 

20. The UAS will not operate in Class B, C, or D airspace without written 

approval from the FAA. The UAS may not operate within 5 nautical miles of the 

geographic center of a non- towered airport as denoted on a current 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 operator’s COA. The letter of agreement with the 

airport management must be made available to the Administrator upon request.