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1110 Molly Road

Fairbanks, AK 99709

15 January, 2015

U.S. Department of Transportation Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Request for Exemption from Certain Regulations per Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations.

Dear Sir or Madam:

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

Part 11, PT Aeronautics hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of sUAS (small Unmanned Aircraft Systems), so long as such 

operations are conducted in compliance with the conditions outlined herein or as established by the 

FAA as required by Section 333.

I. Description of the Petitioner:

PT Aeronautics is a Fairbanks, Alaska based company born of operations, research, and engineering 

experience at the University of Alaska Fairbanks. The petitioner’s experience includes engineering 

and operations on a variety of sUAS. We have been involved in projects ranging from wildlife 

research to sea ice monitoring to wildfire support.

As a commercial entity, we intend to offer the following aerial services:

 Surveying and Photogrammetry 

 Aerial Surveillance

 Aerial Photography and Videography

 Infrastructure Inspection

 Aerial Mapping

 Precision Agriculture

 Flight Training

 Research and Development

A list of specific Regulations from which exemption is requested is listed below in Section V.
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II. Background and basis for the petition:

The passing by Congress of Section 333 (a) through (c) of the Reform Act provides a mechanism for 

such exemption requests. In passing the act, Congress directed the Secretary of Transportation to 

fairly consider whether certain UAS may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UAS do not create a significant 

hazard to users of the NAS or the public, or pose a threat to national security. The UAS size, weight, 

speed, and operational capability; operation of the UAS in close proximity to airports and populated 

areas; and operation of the UAS within visual line of sight of the operator are conditions to be 

considered. If the Secretary determines that such UAS “may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system.” Reform Act, Section 333 (a). This petition follows the precedent of over 

2000 previously granted exemptions in which requirements for such safe operations have been 

established.

III. Public Benefit and Operational Safety

From the dawn of their use in the military theater, Unmanned Aircraft have had one fundamental 

purpose: to remove the risk associated with sending a human into a dangerous situation. While 

manned aviation is far safer for civil pilots and crew than for those at war, there is still an inherent 

risk involved in every manned aviation flight. The main goal of the petitioner’s commercial

operations is to eliminate casualty risk entirely from certain aerial imagery and monitoring flights, 

thus opening these capabilities to persons and agencies that would otherwise be unable to accept 

such risk or the financial burden associated with it. In addition, unmanned aerial imagery can

remove risks to humans and the environment associated with low-altitude aerial and ground-based

monitoring and inspection. Examples of this include an increased level of safety in infrastructure 

inspection (currently performed by persons scaling scaffold or ladders, or from ground-based boom 

apparatus) and monitoring of sensitive biological systems such as animal breeding colonies and 

delicate wetland ecosystems (currently monitored on foot or from loud, low-flying manned aircraft).

While the risks of striking persons on the ground or other manned aircraft are real, we will provide 

an overall lower-risk environment than manned aviation for dull, dirty, and dangerous aerial sensing 

work through the considerations listed below.

A. UAS Design Safety. All sUAS operated by the petitioner will

 Be under 55 lbs gross weight at takeoff. 

 Be operated in frequency bands allocated by the FCC as unlicensed or amateur.

 Operate below 87 kts (100 mph). 

 Use geo-fencing, which will limit the range and altitude at which the vehicle can operate.

 Be operated only in visual line-of-site (VLOS) of the pilot or observer.

 Only operate under 500’ AGL.

 Return, at a safe altitude, to the launch position and land or circle in the event of loss of 

link with the control station.

 Terminate flight via parachute deployment, controlled landing-in-place, or CFIT in an 

unpopulated location upon combined loss of link to control station and loss of GPS signal.

 Maintain a minimum 5-minute power reserve at the time of landing.
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 Be registered with the FAA, and marked as large as practicable, IAW 14 CFR 45C.

 Be maintained by the operator in a condition for safe flight IAW manufacturer 

specifications and industry best practice. We have an FAA licensed A&P mechanic on staff 

who will oversee maintenance operations.

B. Flight Crew Safety. All pilots, trainees, and observers operating under the authority of this 

petition will

 If acting as PIC, hold at least an FAA Private or Sport Pilot license.

 If acting as VO, hold at least a valid driver’s license.

 Hold an FAA 3rd Class medical if operating in the vicinity of airports under a letter of 

agreement (LOA) with the administrator.

 Be properly trained for the operation of the sUAS either IAW manufacturer’s training 

protocol or by a comprehensive training program established by the petitioner.

 Be properly trained in safe maintenance practices.

 In the case of the PIC, log flight hours and currency IAW 14 CFR 61.51.

 Abort flight operations using RTL functionality or other flight termination in the event of an 

emergency or for traffic deconfliction.

 Use operations manuals and checklists for every stage of flight; such materials will be at 

hand in the vicinity of the GCS during flight ops.

C. Operational Safety. All flight operations will

 Be conducted after the air vehicle has undergone a thorough preflight inspection to assure 

that it is in a condition for safe operation, IAW manufacturer operation instructions and/or 

safety checklists created by the petitioner.

 Comply with operations and maintenance recordkeeping and reporting requirements set 

forth by the FAA in response to this petition.

 Comply with all manufacturer operations and maintenance instructions, and with any 

safety bulletins issued by the manufacturer of the UAS.

 Be operated by pilots trained to operate the UAS in a manner consistent with 

manufacturer’s operational instructions and any conditions set forth by the FAA in 

response to this petition.

 Only be conducted once a NOTAM has been issued for the operational area.

 Be conducted under visual flight rules (VFR) and in visual meteorological conditions (VMC).

 Be conducted at least 5 miles from a towered airport and 2 miles from a non-towered 

airport, unless a specific LOA exists with the administrator.

 Always give way to manned flight operations, and operations of less maneuverable UAS.

 Be conducted at least 500’ from non-participating persons unless such persons are 

protected from UAS debris by sufficient barriers.

 Be conducted at least 500’ from structures or vehicles, unless the owner or controller of 

the structure or vehicle has granted permission to operate closer.

 Be based on private or controlled access property, or on public property with the IAW the 

policy of the controlling agency.

D. Additional Safety Considerations. All training, maintenance, or functional test flights will

 Only take place during dedicated training, maintenance, or functional test flight sessions.

 Be performed at least 500’ feet from structures and non-participating persons.
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In the event of an accident or incident, the operator will report to the UAS Integration office within 

24 hours, and to the NTSB as applicable.

IV. SPECIFIC sUAS FOR WHICH EXEMPTION IS REQUESTED

The sUAS for which we request exemption are listed below. 

Aircraft Exemption # under which aircraft has been 

previously approved

DJI Phantom 11267, 11309

DJI Inspire 11204, 11239

DJI Flamewheel 11318, 11397

DJI Spreading Wings 11260, 11423, 11401

3DRobotics Aero 11393, 11379

3DRobotics IRIS+ 11741, 11778

3DRobotics Solo 11633, 11832

Aeromapper EV2 11405, 11447

Hobby King Bixler 12079, 12104

Each of these sUAS has been previously exempted by another petitioner. We chose previously 

exempted systems for our operations specifically in order to streamline the exemption process. 

Each of these systems’ autopilots allow for return to home functionality in the event of a loss of 

communication link between the aircraft and PIC. Each system also allows for a geofence to be 

set up that will not allow the PIC or autopilot to accidentally fly out of the pre-determined safe 

flight area. 

Specification pages for DJI controllers, including the Naza and Wookong series, are easily 

available on the DJI Wiki pages at http://wiki.dji.com/en/index.php/Main_page.

Specification pages for 3DR controllers, including the APM and Pixhawk, are also readily 

available online through the Arduplane and Arducopter information portals at 

http://plane.ardupilot.com and http://copter.ardupilot.com, respectively.

In the case of the Pixhawk autopilot, there are dual independent sensor sets for both IMU suite, 

barometer, and compass. The autopilot also supports dual GPS, RTK GPS, laser altimeter, and 

sonar. Safety in further increased by redundant power supplies, independent attitude, 

navigation, and communication software loops, and a completely independent second 

processor for manual control and communication in the unlikely case of total system failure in 

flight.

Manufacturer’s operations and maintenance information for each sUAS operated by the 

petitioner will be kept on file and will be collocated with the system GCS when the system is in 

use.
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V. SPECIFIC REGULATIONS FROM WHICH EXEMPTION IS REQUESTED, and EQUIVALENT LEVEL OF 

SAFETY ACHIEVED.

14 CFR 21, Subpart H: Certification Procedures for products and parts, Airworthiness Certificates. 

Airworthiness Certification procedures have not been established for sUAS parts, nor are Airworthiness 

Certificates available for this class of aircraft. We believe that an equivalent level of safety can be 

attained by 1) careful attention by operators and maintainers to manufacturer’s instructions and 

procedures, 2) flight termination hardware and programming, 3) proper training of operators and 

maintainers, and 4) operational constraints and conditions in accordance with typical Section 333 

Exemptions which eliminate casualty risk in the event of a catastrophic failure of the sUAS. The 

petitioner will keep records of wear and failure of parts and will provide this information to the FAA on 

request. Furthermore, all of the sUAS we are requesting be included in our exemption have been 

approved by the FAA in previous Section 333 Exemptions.

14 CFR 45.23 and 45.29: Marking of aircraft. The sUAS for which we request exemption are not large 

enough to display registration markings as required in this regulation. In addition, the sUAS will not 

carry an airworthiness certificate, and thus will not be subject to placarding with airworthiness 

categories such as “experimental” or “provisional”. We request exemption from this FAR and will 

provide an equivalent level of safety by applying indelible placarding of the aircraft’s registration 

numbers with as large a character as is practicable on the aircraft’s hull and by conducting a thorough 

preflight briefing with all affected persons before the flight. This is consistent with item #22 in typical 

Section 333 exemptions.

14 CFR 61.101, 61.113, and 14 CFR 61.133: Recreational, Private, and Commercial Pilot privileges and 

limitations. We request exemption from the requirement that the PIC of commercial sUAS flights have a 

commercial pilot certificate with a second-class medical. We propose an equivalent level of safety by 

using careful preplanning, required training, and reduced complexity of operations, combined with 

at least a Sport Pilot certificate (or sUAS operator certificate, should that certificate become 

available), and a valid US driver’s license. We require pilots to have a pilot certificate in order that 

flight crew 1) have an understanding of aeronautical knowledge and 2) understand the 

consequences of interfering with manned flight. This mirror’s FAA’s guideline in item #13 in typical 

Section 333 exemptions where a PIC of an sUAS must hold least a Sport Pilot certificate and, for 

medical testing, at least a Driver’s License and that the PIC maintain currency in their type and 

category of manned aircraft.

14 CFR 91.7 (a): Operating an aircraft in an airworthy condition. Reference exemption request for 14 

CFR Part 21 (h), above. We request exemption as airworthiness standards do not exist for this size and 

class of aircraft. We will provide an equivalent level of safety as described in the exemption request for 

14 CFR Part 21 (h) above.

14 CFR 91.9 (b)(2): Flight manual in aircraft. Due to the small size of sUAS and that the flight manual is 

generally required to be on board the aircraft in order that it be accessible to the pilot, we request 

exemption from this FAR. An equivalent level of safety will be provided by ensuring an operating 

manual provided by the manufacturer, and including supplemental material generated by the petitioner, 

be co-located with the PIC at the ground control station for the system as per the FAA’s guideline in item

#7 in typical Section 333 exemptions.
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14 CFR 91.103 (b)(2) : Preflight Action. FAA-approved rotorcraft and airplane flight manuals are not 

available for the sUAS for which we request exemption, thus, we cannot fully comply with this FAR. We 

request exemption, and will provide an equivalent level of safety using 1)All manufacturer-provided 

(non-approved) flight and maintenance manuals and checklists, 2) Petitioner-developed operational 

checklists (where the manufacturer does not provide a checklist or to supplement manufacturer 

checklists) and other supplemental material, and 3) thorough training of flight and ground crew on 

preflight checks. This is consistent with the FAA’s guidelines in item #10 of a typical Section 333 

exemption.

14 CFR 91.105: Flight Crewmembers at stations. Exemption from this FAR is not necessary. Though the 

nature of sUAS prevents the flight crewmembers from being physically present on the aircraft, the 

required flight crewmembers (generally a PIC and a visual observer) will be at their stations throughout 

the duration of the flight.

14 CFR 91.109: Flight instruction. Section 91.109 provides that no person may operate a civil 

aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. We request exemption from this FAR and can provide an 

equivalent level of safety because of 1) the physical station of the flight crew during training 

activities and 2) the autonomous nature of the vehicle, and 3) the operational safeties in effect to 

mitigate casualty risk. During training, the trainee may hand off the controls to the PIC by passing 

the controls physically to the PIC’s possession, or the trainee may step out of the way and let the 

PIC take over. This is not possible in most manned aircraft due to cockpit limitations. In addition, 

the vehicle will almost always be under some level of autonomous flight, so a brief interruption 

while control is transferred will not disrupt flight. Finally, the operational constraints requested in

this exemption provide an equivalent level of safety even if a mishap should occur during training; 

the petitioner will abide by the FAA’s guideline in item #7 in typical Section 333 exemptions. For 

training activities involving direct control or free-flight (non-autonomous r/c-type flight such as that 

done by model aircraft operators), dual controls will be used until the trainee has shown a level of 

command of the system so as to operate it safely.

14 CFR 91.119: Minimum Safe Altitudes. The nature of sUAS operations is such that they are 

purposefully flown below the minimum safe altitudes of manned aircraft. Furthermore, the precedent 

for petition places maximum altitudes for sUAS operations below 400’AGL (item #4 in the typical 

exemption). We request exemption to this FAR and will provide an equivalent level of safety by 

maintaining 500’ horizontal separation from nonparticipating persons, structures, and vehicles, unless 

the petitioner has been granted permission from the owner/operator of the structure or vehicle. In this 

case, all nonessential persons will be adequately sheltered from UAS operations occurring within 500’. 

Kinetic energy evaluations of the system will be performed prior to operations to determine adequate 

shelter characteristics. This is consistent with the typical Section 333 exemption, item #26.

14 CFR 91.121: Altimeter settings. The sUAS for which the petitioner requests exemption are equipped 

with both GPS and dual barometric altimeters. They typically auto-correct GPS altitude for current 

barometric conditions upon startup, and flight times will generally not bridge major barometric changes. 

In addition, flights requested in the context of this petition will not exceed VLOS, and will generally 

return to the point of origin, thus barometric changes during flight are unlikely to present altitude 

deconfliction problems even with other sUAS. We request exemption to this FAR and will provide an 

equivalent level of safety by maintaining a maximum operational altitude of 400’ AGL, 100’ below 
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minimum safe altitudes for manned aircraft. Even in the event of barometric altimeter OR GPS altimeter 

failure, this provides an ample buffer from normal manned VFR traffic altitudes. In addition, all of our 

operations will be conducted with a visual observer, in accordance with the typical Section 333 

exemption item #6. The VO will be able to verify aircraft altitude using a combination of laser rangefinding and visual estimation. Before flight, the accuracy of the altitude being used by the UAS will be 

verified against known field elevations. 

14 CFR 91.151: Fuel Requirements for flights in VFR conditions. Maximum flight times for most sUAS 

are below the required 1⁄2-hour fuel margin requirement of this regulation. We request exemption from 

this regulation and will provide an equivalent level of safety by ensuring a 5-minute battery margin for 

battery-powered sUAS (meaning the sUAS will land with at least 5 minutes of ‘fuel’ remaining). For 

sUAS with gas or hybrid powerplants, we will ensure manufacturer’s recommended fuel reserve is 

maintained at landing, or 20% or 1⁄2 hour fuel reserve, whichever is lesser, to provide an equivalent level 

of safety. Return to landing under battery or fuel failsafe will be programmed into the aircraft prior to 

operation and will be automated. This mirrors and expounds upon item #20 in the typical Section 333 

exemption.

14 CFR 91.203: Carrying Civil Aircraft Certification and Registration. We request exemption from this 

regulation on the following grounds: 1) As requested above, the sUAS will not be issued an airworthiness 

certificate. Thus, there will be no airworthiness certificate to display. 2) We will provide an equivalent 

level of safety by requiring that the registration of the sUAS be kept with the aircraft logbooks, which 

will be co-located with the PIC during flight and will be available for inspection by authorities, 

participating personnel, and bystanders, as per the FAA’s guideline in item #23 in typical Section 333 

exemptions.

14 CFR Subpart E (91.401- 91.417) Maintenance, Preventive Maintenance, Alterations 

This regulation requires that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. Item #’s 8-12 of a typical section 333 exemption address 

the minimums for achieving an equivalent level of safety upon exemption from this regulation, and 

it is our intention to adhere to those precedents. In addition, we maintain on-staff an FAA-certified 

A&P Mechanic, who will perform maintenance and record-keeping training sessions for all PIC’s. 

PIC’s will be required to keep thorough maintenance logs, and repairs and alterations considered 

significant (as per item #8 in a typical exemption) will be documented and approved for return to 

service only by a certificated A&P mechanic. In general, the PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed inspections after every 

flight. We believe this, along with the FAA’s guidelines in bullet points #8-#12 in typical Section 333 

exemptions, provide for an equivalent level of safety.

VII. SUMMARY

In summary, PT Aeronautics seeks an exemption from the FAA Regulations listed above in order to 

operate the sUAS listed in Section IV of this request in the NAS. We will use a combination of sUAS 

design, flight crew training, and operational safety, combined with stringent administrative oversight 

and meticulous log-keeping to ensure not only an equivalent level of safety to regulations for which we 

request exemption, but also to exceed such regulations in the benefit to the public. At PT Aeronautics, 
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we believe that the safe, responsible use of proven sUAS platforms in a controlled environment can 

create a safer working environment for dull, dangerous, and dirty tasks. We appreciate the 

consideration of our request for exemption, and appreciate a prompt decision.

Sincerely,

Peter Elstner

Director of Operations

PT Aeronautics