CCLD Technologies Inc

2705 Faith Industrial Drive,

Buford GA, 30519

Email: bburke@ccldtech.com

Petition: March 24th 2015

U.S Department of Transportation, Docket Operations

Federal Aviation Administration

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE, Washington DC 20590

Subject: Request for exemption of certain conditions from the Title 14, Code of Federal 

Regulations (14 CFR) for CCLD Technologies.

Sir or Madam:

CCLD Technologies Inc. is here by requesting exemption from specific regulations of Title 14 of 

the Code of Federal Regulations. These exemptions are in accordance with the Section 333 of the 

FAA Modernization and Reform Act of 2012.

According to current FAA rules and regulations all recreational unmanned aviation flying must 

be kept below 400 feet AGL and the pilot must keep line of sight on the aircraft.

CCLD Technologies Inc. is requesting for the permission of the FAA to be able to use a 

unmanned Ariel vehicle for commercial use to fly and inspect cell phone towers, and other tall 

structures for consumers. In doing so CCLD will abide by all FAA regulations such as, staying 

under 2,000 feet AGL and will not fly in restricted areas. If exemption is allowed, CCLD will be 

able to provide high definition Laser scanning as well as Thermal Imaging for inspections to 

detect cracking in towers, bridges, and other structures, as well as provide full data extraction for 

construction companies for build outs, as built surveys and progression builds. Being able to 
conduct such inspections will help each state’s Department of Transportation detect and correct 

any bridge, road or structure damage before it causes harm for the community.

In order to maintain a completely safe operating environment CCLD will not, in any

circumstances will never enter Class B, C, or D airspaces. CCLD will also keep all awareness of 

any TFR’s, restricted/prohibited areas. CCLD will not come within three nautical miles of any

active airfields or airports. We will fly in areas that we have been given clearance to fly in, and 

file NOTAMs at least 24 hours to operating. CCLD will notify all parties affected by the area 

being flown by our UAV. CCLD will conduct and receive any prior authorizations required from 

local areas before flight is confirmed.

AIRCRAFT DISCRPTION:

CCLD Technologies would be operating with the Aibotix X6. This is a 6 bladed multi rotor 

aircraft that weighs less than 14 pounds. It is made of Carbon Fiber Reinforced Polymer. Its dead 

weight is 7 pounds; its takeoff weight is 10.3 pounds. Its max speed is 31 MPH. 30 minute flight 

times. It is equipped with accelerometer, magnetometer, barometer, ultrasonic sensors and 

gyroscope. It operates on Lithium- Polymer 10,000 Milliamp batteries. This is a (VTOL) 

Vertical Takeoff and landing aircraft.

CCLD Inc. will operate an unmanned aircraft weighing less than 14 pounds and is bright green 

in color, which will make it highly visible and identifiable. Our Aircraft will possess all 

programmable failsafe’s such as lost communications, lost geospatial positioning, and lost 

magneto features, as well as instantaneous overrides. All operations with our UAV will be kept 

in the line of sight of the pilot. It will not cause hazard to users or any surrounding by standers or 

to the users of the national airspace system, or pose a threat to the national security. The UAS 

will maintain 2 way communication with all crewmembers and observers as well as the local 

CTAF or other necessary operational frequencies during the flight.

With this petition CCLD Technologies Inc. is requesting an examination of its UAS by the FAA 

to be exempt from certain parts of Title 14 Code of Federal Regulations.

CCLD Technologies Inc. will use the Aibotix x6 aircraft strictly for business purposes. We will 

operate under all normal conditions at a speed no more than 22 knots (KIAS) and has the 

capability to hover. We will always be kept in line of sight of pilot in control. Operation 

guidelines are within the 100 foot radius surrounding the telecommunications or utility structure 

and under 400 feet AGL. 

REQUEST FOR EXEPTION FROM:

§21.1(a)(1)(iii): This part prescribes procedural requirements for issuing and changing 

airworthiness certificates.
Reason for Exemption:

CCLD Technologies Inc. requests approval to produce documentation verified and signed by a 

licensed A&P which states that that the aircraft in use will adhere to the MIL-HDBK-516B 

Airworthiness Certification Criteria in lieu of any conventional aircraft airworthiness processes 

until such time as the administration establishes a standard for national regulation for 

commercial unmanned aircraft operations pursuant to Report 112-381.

§61.113(a): No person who holds a private pilot certificate may act as pilot in command of an 

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

compensation or hire, act as pilot in command of an aircraft.

Reason for Exemption:

CCLD Technologies INC. will not pilot any aircraft carrying passengers or property. However 

we do request approval to operate in a commercial capacity for compensation or hire for the 

purposes of doing inspections on tall structures, and roadways until such time as the 

administration establishes a standard for national regulation for commercial unmanned aircraft 

operations pursuant to Report 112-381. CCLD Technologies employs a private pilot single 

engine land; rotorcraft – helicopter certificate holder who can competently act as pilot in

command over the unmanned aircraft. 

§91.203(a)(1): Except as provided in §91.715, no person may operate a civil aircraft unless it has 

within it the following: An appropriate and current airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with this subparagraph.

Reason for Exemption:

CCLD Technologies Inc. requests approval to produce documentation verified and signed by a 

licensed A&P which states that that the particular aircraft in use will adhere to the MIL-HDBK516B Airworthiness Certification Criteria in lieu of any conventional aircraft airworthiness 

processes required by Part 91.203(a)(1) until such time as the administration establishes a 

standard for national regulation for commercial unmanned aircraft operations pursuant to Report 

112-381. The airworthiness documentation based on MIL-HDBK-516B will be accessible by

the ground based flight crew during all operations.

§91.203(a)(2): Except as provided in §91.715, no person may operate a civil aircraft unless it has 

within it the following: An effective U.S. registration certificate issued to its owner or, for 

operation within the United States, the second copy of the Aircraft registration Application as 

provided for in §47.31(c), or a registration certification issued under the laws of a foreign 

country.

Reason for Exemption:

CCLD Technologies Inc. requests exemption from producing registration for its aircraft. This 

request couples with the request for exemption for airworthiness under §21.1(a)(1)(iii) in this 
petition. This request acknowledges Order 8130.20 regarding registration requirements for 

United States civil aircraft seeking airworthiness and requests relief until such time as the 

administration establishes a standard for national regulation for commercial unmanned aircraft 

operations pursuant to Report 112-381. 

Reason for Exemption:

Given the unmanned nature of the aircraft, CCLD Technologies Inc. requests that it be approved 

to have an airworthiness documentation based on MIL-HDBK-516B accessible to the ground 

based flight crew at all times.

§91.9(b)(2): No person may operate a U.S.-registered civil aircraft For which an Airplane or 

Rotorcraft Flight Manual is not 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.

Reason for Exemption:

CCLD Technologies Inc. will be operating small, unmanned aircraft that do not possess a type 

certificate, relieving it of the requirements for §21.5. Given the nature of the unmanned aircraft, 

CCLD Technologies Inc. wishes to require an aircraft manual present with the flight crew at 

ground level in lieu of making the aircraft manual available in the aircraft.

CCLD Technologies is a telecommunication company that has been in operation for 16 years. 

We have formed and held many multi-million dollar accounts in which we have done service for 

in the past. CCLD Technologies plans to monitor and inspect all aspects of the safety portion of 

the Departments of Transportation, ensuring the public roadways and bridges are safe for the 

population to travel on. 

Pilots:

All pilots will maintain currency on the UAS by performing at least three launch and recovery

operations that include maneuvering within the preceding 90 days. 

Name: Cory O’Leary

Specs: 

Private Pilot License

Training completed a Delta Connection Academy in Sanford, FL. 

AMA Member

Certified since 2009.

Observer’s:
All observers will maintain relevant currency according to FAR part 61 and be updated on all 

current UAS protocol. In addition to that all observers will meet the following requirements:

1. FAR Part 91 training

2. Knowledge of the capabilities of the unmanned aircraft in operation

3. Crew Resource training

4. Participation in preflight planning and mission planning

5. Capacity to visually and audibly detect aircraft intrusions exceeding one nautical mile.

CCLD Technologies Inc. holds the highest regard for the rules and regulations of the FAA in 

protecting the general public as well as not to disrupt or interfere with the United States National 

Airspace System. 

On Behalf of all UAS advocates in both the public and private sections who are working toward 

a safe integration of the UAS world and the NAS world, we want to thank you for your 

consideration of this petition for exception, an also look forward to your comments and or 

feedback on how we can continue to expand this outstanding technology.

Brett Burke

Owner/ President

CCLD Technologies Inc.

bburke@ccldtech.com

www.ccldtech.com