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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C.

Regulatory Docket No.________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DIRTPREP SOLUTIONS, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF AN 

EVENT38 E384 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on 14 April 2015

Jason Lambrich, Managing Partner 

DirtPrep Solutions, LLC

9227 Reseda Blvd #180

Northridge, CA 91324

Phone: 415-975-1615

Email: jason@DirtPrep.com
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Table of Contents 

Petition Summary ....................................................................................................3 

Background .............................................................................................................3 

Statutory Authority .................................................................................................5 

Basis for Petition .....................................................................................................11 

E384 Operations Manual * ..................................................................... Appendix A

E834 Maintenance Manual* ................................................................... Appendix B

Event 38 Training Syllabus* ................................................................... Appendix C

* Documents were submitted confidentially for proprietary reasons and will not be available to the public 
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A. Petition Summary

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, DirtPrep 

Solutions, LLC (DirtPrep Solutions) requests exemption from the following Federal Aviation 

Regulations that are found under Title 14 of the Code of Federal Regulations (CFR): Part 21 

Subpart H, 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) 

(b), Part 91 Subpart E (91.40191.417). DirtPrep Solutions seeks expedited approval and 

exemption from the CFRs listed above in order to operate the E384 Unmanned Aircraft System 

(UAS) for the purpose of gathering high resolution aerial imagery to create 3D information and 

orthographic photos. Operation of the E384 by DirtPrep Solutions will follow strict operational 

limitations as outlined in this document and all recommendations by the FAA.

B. Background 

1. DirtPrep Solutions, LLC

DirtPrep Solutions is a 3D data preparation firm that provides services to the 

construction and surface mining industries. The use of a UAV will allow us to provide

analysis, monitoring and reporting of geographic data captured via remote sensing from 

this small platform rather than from fixed wing aircraft. 

2. E384

The E384 UAS is manufactured by Event 38 located in Akron, Ohio. The system 

consist of a lightweight battery operated aircraft, ground control station, and associated 

data link equipment. The E384 airframe is constructed of EPO foam with a carbon fiber 

tail and weighs 5.9 lbs. with a wingspan of 6.2 ft. and total length of 4.3 ft. The E384 is 

powered by one or two lithium polymer batteries, depending on duration needed, that 

drive an electric propeller. It is hand launched, has maximum flight time of 100 minutes, 
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and operates at a cruising speed of 27 mph. The ground control station consist of a 

Turnigy 9XR remote and PC computer which have a maximum data link range of 1 NM. 

If the E384 loses link with the ground control station or detects a low battery state at any 

time it will initiate a return-to-launch sequence. 

The E384 has extensive flight experience and a history of operational success 

overseas, including flights by over one hundred professional operators on 6 continents. It 

has been used in Uganda to survey potential land for the construction of a hydroelectric 

power plant. It has also been used in Greece by the National Technical University of 

Athens to study open-pit mining. In Belize the Fishery Department started routine flights 

with the E384 to track illegal fishing in protected waters. More recently in the United 

States the E384 was flown over three days at the Cleveland Airshow, demonstrating its 

ability to safely integrate and operate in the National Airspace System (NAS). 

For additional information on the E384, reference Appendix A (E384 Operations 

Manual) and Appendix B (E384 Maintenance Manual), which specify manufacturing 
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information, aircraft performance, operating limits, normal and emergency procedures, 

fail-safe features, and maintenance and inspection procedures. 

C. Statutory Authority

1. FAA Modernization and Reform Act of 2012, Section 333

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safety in the national airspace system before completion of the plan 

and rulemaking required by Section 332”. Section 333 (b) then lists several factors that 

should be considered in determining which UAS’ would be eligible for expedited 

integration into the National Airspace System (NAS). Specifically UAS’ that “as a result 

of their size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to the users of the 

national airspace system or the public, or pose a threat to national security”. If a UAS 

meets the criteria laid forth in Section 333 (b), Section 333 (c) then gives the FAA the 

authority to decide if an airworthiness certification as specified by Title 49 United States 

Code, Section 44704 is even required for operation. Section 333 (c) specifically states 

that the FAA can determine “whether a certificate of waiver, certificate of authorization, 

or airworthiness certification under section 44704 of Title 49, United States Code, is 

required for the operation of unmanned aircraft systems”. Thus, the FAA has the ability 

to allow a UAS that meets the criteria put forth in Section 333 (b) to operate within the 

NAS without an airworthiness certification as long as the UAS does not pose any hazard 

or threat to the NAS, public, and national security. 
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2. How DirtPrep Solutions meets the criteria laid forth in Section 333

Below are the criteria laid forth in Section 333 (b) and a detailed description of

how DirtPrep Solutions meets each of these criteria. 

a. Size, Weight, and Speed

The E384’s foam airframe weighs 5.9 lbs., has a 6.2 ft. wingspan, length 

of 4.3 ft., and operates at cruising speeds of 27 mph. This small, lightweight 

aircraft that operates at relatively slow speeds will pose little hazard to people or 

structures on the ground, thus making it an exponentially safer alternative to 

manned, fixed wing aircraft for aerial imaging. 

b. Operational Capability

The primary function of the E384 is to provide aerial imagery using one of 

two interchangeable geo-reference capable still cameras. High resolution data 

generated from these cameras offer a wide range of applications through analysis, 

such as 3D models for quarry pile quantities, orthophotos for progress 

comparisons and topographic maps with contours and ground features for 

planning purposes. The use of the UAV removes personnel from close proximity 

to heavy equipment and from potential fall hazards.

The E384 is hand launched on-site, requiring no runway for take-off and 

landing and no transit to and from the site. Once airborne, the E384 will fly at an 

altitude of 400 ft. AGL or less over the designated mapping zone. Prior to flight, 

the Pilot in Command (PIC) sets a designated flight area and flight parameters to 

ensure that the E384 will remain within the confines of the approved site and not 
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exceed a maximum altitude 400 ft. AGL. If a critical issue such as a low battery 

state or a loss of data link is detected at any time the E384 will immediately 

execute a return-to-launch sequence (Reference Appendix A). The E384’s small 

operational footprint and built-in safety protocol provide a much safer alternative 

for aerial imaging and would pose a minimal hazard to the NAS or public. 

c. Proximity to Airports/Populated Areas

Grant of the exemption to DirtPrep Solutions will be subject to the 

following mandatory conditions, which are based upon operating conditions set 

forth for operation of UAS by public entities pursuant to Certificates of 

Authorization, with additional restrictions: 

• All operations to occur in Class G airspace.

• Operations to avoid congested or populated areas, which are depicted in 

yellow on VFR charts. 

• Operations to be conducted over private or controlled-access property. 

• Permission from land owner/controller required before commencing any 

flight. 

• Operations to occur during Visual Flight Rules Meteorological Conditions 

(VMC). 

• Aircraft to remain within Visual Line of Sight (VLOS). 

o VLOS guaranteed with a cylinder of operation around operator of 

1⁄2 nautical miles (NM). 

o Cylinder walls may be expanded by observer with ability to control 

aircraft. 
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• Operations to occur during daylight hours. 

• Above Ground Level (AGL) altitude to be restricted to 400 feet. 

• All operations conducted in vicinity of airport to remain more than 2.5 

NM from centerline azimuth of runway centerline measured from runway 

thresholds. 

• Operator will file a NOTAM for each flight. 

• 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.

d. Visual Line of Sight (VLOS)

The E384 will be flown in accordance with day Visual Flight Rules (VFR) 

and only in Visual Meteorological Conditions (VMC) during day-light hours. The 

E384 will operate within 1 NM and VLOS of the PIC (and the Safety Observer 

positioned next to the PIC) at an altitude 400 ft. AGL or less. The Safety Observer 

will be responsible for ensuring that the E384 remains within VLOS at all times 

and will also assist in spotting potential hazards. 

3. Other Relevant Factors 

a. Operational Limitations

DirtPrep Solutions has established the following operational limitations for

E384 flights over designated sites. 

 E384 flights are only permitted over designated sites 

 The E384 will operate at or below 400 ft. AGL
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 The E384 will operate within 1 NM and within VLOS of the PIC and 

Safety Observer 

 The Safety Observer will be located next to the PIC and will ensure the 

aircraft remains within VLOS and assist in spotting potential hazards 

 The E384 will operate in accordance with Day Visual Flight Rules and 

only in Visual Meteorological Conditions during daylight hours

 The duration of each E384 flight shall not exceed 100 minutes

 All take-off and landings will occur on-site in accordance with the E384 

Operations Manual (Reference Appendix A) 

 E384 flights will avoid direct overflight of any office or maintenance 

buildings located on-site 

 All employees working on-site will be thoroughly briefed on E384 

operations prior to operations commencing

 E384 operations will be conducted by pilots, who have at a minimum, a 

private pilot certificate and completed Event 38’s Training Program 

(Reference Appendix C) 

 E384 flights will be cancelled in the event that any aircraft or ground 

control station equipment is inoperative or not fully functional 

 If the PIC or Safety Observer spot a potential hazard, such as a manned 

aircraft within close proximity to the designated flight area, the PIC will 
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immediately land the E384 and operations will only resume after the 

hazard is clear of the area 

 All E384 maintenance will be accomplished in accordance with theE384 

Maintenance Manual (Reference Appendix B)

 Only one E384 will be airborne at any given time for each designated site

 The PIC will file a NOTAM for E384 flights at each site, providing at a 

minimum radial/DME, radius, and a date/time group

DirtPrep Solutions will be bound by these limitations for commercial flights after 

FAA approval of the exemptions laid forth in this petition. DirtPrep Solutions will 

also follow any guidance from the FAA in accordance with Sec 333 (c) which 

states that after determining if a UAS meets the criteria for safe operation that the 

FAA “shall [also] establish requirements for the safe operation of the” UAS in the 

NAS. 

D. Basis for Petition

1. Name and Address of the Petitioner

Jason Lambrich, Managing Partner 

DirtPrep Solutions, LLC

9227 Reseda Blvd #180

Northridge, CA 91324 

Phone: 415-975-1615

Email: jason@DirtPrep.com
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2. Specific Sections of 14 CFR from which DirtPrep Solutions Seeks Exemption

Below are the sections from which DirtPrep Solutions seeks exemption, with 

specifics on the extent of relief sought, reason for relief, and why exemption would not 

adversely affect safety. 

a. Part 21 Subpart H – Airworthiness Certification

Part 21 Subpart H establishes the requirements for the issuance of an 

airworthiness certificate. DirtPrep Solutions seeks complete exemption from Part 

21 Subpart H pursuant with Section 333, which authorizes the FAA to exempt a 

UAS from the requirements of an airworthiness certificate based on consideration 

of the following: size, weigh, speed, operational capability, proximity to airports 

and populated areas, and operation within VLOS. 

An equal level of safety will be achieved with the operational limitations 

established in this document (Reference A.3.a) for all DirtPrep Solutions E384 

flights. Specifically that all flights will occur within VLOS of the PIC and Safety 

Observer, at an altitude of 400 ft. AGL or less, and only over designated areas. As 

a result the E384 can safely operate without creating a hazard to any other aircraft, 

people, or structures on the ground. The combination of the E384’s safe 

operational history overseas and small, lightweight airframe, in conjunction with 

DirtPrep Solutions’s pilot requirements and operating limitations result in a safer 

alternative for aerial imagery collection. 

b. 45.23 (b) – Marking Requirements

45.23 (b) requires aircraft to display the roman capital letter “N” with 

registration number and the words “restricted”, “light-sport”, “experimental”, or 
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“provisional”, as applicable, on the entrance to the cabin, cockpit, or pilot station 

in lettering that is between 2 in. and 6 in. in height. The E384 is unmanned and 

thus has no cabin, cockpit, pilot station, or entrance on which these required 

markings could be displayed. DirtPrep Solutions will, to the maximum extent 

possible, comply with the location requirements of 45.27 (a) and the size 

requirements of 45.29 (f). DirtPrep Solutions specifically proposes to put the “N” 

number and the word “EXPERIMENTAL” in the largest lettering possible on the 

fuselage of the aircraft in accordance with 45.29 (f) “if no surface authorized to be 

marked by 45.27 is large enough for full-size marks, marks as large as practicable 

must be placed on the largest of the authorized surfaces”. 

DirtPrep Solutions also proposes placing a flag at the ground control station with 

the words “EXPERIMENTAL UAS” in 3 in. lettering. An equal level of safety 

would be maintained by displaying the word “EXPERIMENTAL” on the fuselage 

of the aircraft and by placing a flag at the ground control station with the words 

“EXPERIMENTAL UAS”. Since the E384 will always be within VLOS of the 

PIC (positioned at the ground control station) and flown at a low altitude (400 ft. 

AGL or less) the markings on the airframe and the flag located at the ground 

control station would allow all parties to visually be informed of the UAS’ 

operating status. 

c. 91.7 (a) – Civil Aircraft Airworthiness

91.7 (a) states that “no person may operate a civil aircraft unless it is in an 

airworthy condition”. DirtPrep Solutions is already seeking exemption for 

airworthiness Certification (Reference D.2.a.) and thus no FAA standard will exist 
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for determining airworthiness. As a result DirtPrep Solutions seeks full exemption 

from this regulation. 

DirtPrep Solutions will achieve an equal level of safety by using E384 

Operations Manual and Maintenance Manual (Appendix A and B) which contain 

pre-flight protocol for each flight, safety checks, and comprehensive maintenance 

procedures. In addition the E384 has already demonstrated the ability to fly safely 

in the NAS at the Cleveland Airshow, and thus is airworthy. 

d. 91.9 (b) – Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a 

current approved flight manual for the aircraft onboard. The E384’s small and 

lightweight airframe is not physically capable of carrying an aircraft flight manual 

onboard. In addition to this the E384 is unmanned, and the PIC is located at the 

ground control station. DirtPrep Solutions thus seeks exemption from the 

requirement to carry the aircraft flight manual onboard. DirtPrep Solutions instead 

proposes that the E384 Operations Manual (Reference Appendix A), which 

contains information normally found in an aircraft flight manual, be kept at the 

ground control station where is readily assessable to the PIC and Safety Observer 

for reference. 

If it were physically possible for these required documents to be placed 

onboard the aircraft, the PIC and Safety Observer would have no means of 

accessing the information due to the fact that E384 is unmanned with no aircrew 

onboard. Therefore an equal level of safety will be meet by keeping the E384 

Operations Manual at the ground control station where it will be readily accessible 
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(within arm’s reach) to the PIC who is operating the aircraft, thus meeting the 

intent of the regulation. 

e. 91.103 – Preflight Action

91.103 requires that the PIC be familiar with specific information before 

each flight such as weather, forecast, and fuel requirements. In addition to this the 

PIC must be familiar with information found within the approved flight manual 

relating to aircraft performance and take-off and landing distances. Due to the fact 

that the E384 has no FAA-approved flight manual DirtPrep Solutions seeks 

exemption from this regulation. DirtPrep Solutions proposes to use the E384 

Operations Manual (Reference Appendix A) in lieu of an FAA-approved flight 

manual. This publication has extensive pre-flight checklists that include reviewing 

weather, battery requirements, take-off and landing distances, and aircraft 

performance data. 

The information found in the E384 Operations Manual is comparable to 

the information found in a FAA-approved flight manual, to include a 

comprehensive step-by-step pre-flight checklist. As a result an equal level of 

safety will be maintained by the PIC using this publication, which addresses the 

items listed in 91.103. 

f. 91.109 – Flight Instruction

91.109 states that “no person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls”. The 

E384 is operated by the PIC through a ground control station that communicates 

with the aircraft via line of sight (LOS) transmissions. The E384 by design does 
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not have fully functioning dual controls and as a result DirtPrep Solutions seeks 

exemption from this regulation. 

Exemption from this regulation requiring dual controls will not create a 

safety hazard because the E384 is unmanned and does not carry a pilot or 

passengers on board. In addition the E384’s small size and foam airframe is 

significantly less hazardous to persons and structures on the ground than a 

manned, fixed-wing aircraft. Because the E384 ground control station consist of a 

RX9 controller and PC computer, it will be accessible to both the Instructor and 

Student at all times. The “controls” can in essence be passed back and forth 

between the Instructor and Student, achieving an equivalent level of safety as 

having two sets of controls.

g. 91.119 – Minimum Safe Altitude

91.119 establishes the minimum altitude that civil aircraft may safely 

operate at. 91.119 (c) specifically states that over “other than congested areas” a 

civil aircraft cannot operate below an “altitude of 500 feet above the surface, 

except over open water or sparsely populated areas (and) in those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure”. The sole function of the E384 is to fly at low altitudes over mapping 

zones, which can be categorized as “other than congested areas”. Small UAS’, 

like the E384, by design are typically flown at altitudes of less than 500 ft. AGL 

and in close proximity to the PIC and Safety Observer to maintain VLOS. 
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DirtPrep Solutions has established operating limitations to achieve the highest 

level of safety, specifically that the E384 will not operate above 400 ft. AGL and 

that the E384 will remain within VLOS of the PIC and Safety Observer. For these 

reasons DirtPrep Solutions seeks exemption from this regulation. 

An equivalent level of safety will be maintained by only operating the 

E384 over designated sites (Reference 3.C.b). In addition the E384’s small size 

and foam airframe is significantly less hazardous to persons and structures on the 

ground than a manned, fixed-wing aircraft providing the same service. Also by 

operating at an altitude of 400 ft. AGL or less the E384 will be laterally 

deconflicted from manned aircraft that are subject to this minimum safe altitude 

regulation and thus an equal if not greater level of safety will be maintained. 

h. 91.121 – Altimeter Settings

91.121 requires aircraft to maintain a cruising level or flight level in 

reference to a current reported altimeter setting. The E384 is not equipped with a 

programmable altimeter but rather determines location and altitude via an onboard 

GPS. Also since the E384 will be operating at or below 400 ft. AGL, there is no 

need to maintain hemispherical cruising altitudes for de-confliction with manned 

aircraft. For these reasons DirtPrep Solutions seeks exemption from this 

regulation. 

An equal level of safety will be achieved through the E384’s GPS, which 

provides altitude and location data to the PIC via the ground control station. The 

E384 Operations Manual specifically addresses checking the GPS read-out to 
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ensure that it’s within tolerance prior to commencing flight operations. This, 

combined with the fact that the aircraft’s altitude will be visually monitored by the 

PIC and Safety Observer, ensures an equal level of safety is attained in lieu of 

referencing an altimeter setting. Furthermore by operating at or below 400 ft. 

AGL the E384 will not create a hazard to any manned aircraft maintaining 

hemispheric cruising altitudes based on a current altimeter setting. 

i. 91.151 (a) – Fuel Requirements for Flight in VFR Conditions

91.151 (a) states that no person may begin a flight in Day VFR conditions 

unless there is enough fuel to fly to the intended landing point and fly for 30 

minutes after that point is reached. The E384 is battery operated and does not 

carry fuel. It has a maximum flight time of 100 minutes on fully charged batteries. 

Compliance with the regulation would leave the E384 with 70 minutes of flight 

time. 70 minutes of flight time would be sufficient enough to accomplish the task 

of imaging the designate mapping zone but this restriction is not necessary due to 

the fact E384 has the ability to land anywhere. Therefore DirtPrep Solutions seeks 

full exemption from this regulation because the risk or danger associated with 

failing to reach a safe landing point with 30 minutes of extra “fuel” does not exist. 

The E384 does not have to return to a “landing point” but rather can be safely put 

down within the mapping zone.

An equal level of safety will be maintained simply by the fact that the 

E384 is designed to safely land within the mapping zone in the event that the 

battery is exhausted. Any risk associated with battery duration (fuel) in 
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relationship to flight time is mitigated by the fact that E384 has the ability to land 

anywhere and at any given time. 

j. 91.203 (a) & (b) – Civil Aircraft: Certifications Requirements

91.203 requires all civil aircraft to have “within it...an appropriate and 

current airworthiness certificate” that must be “displayed at the cabin or cockpit 

entrance so that is legible to passengers or crew”. DirtPrep Solutions is already 

seeking exemption from the airworthiness certificate regulation and thus requires 

an exemption from this regulation. In addition the E384 due to its size and design 

has no cabin or cockpit and therefore does not have the ability to affix or carry 

certification or registration documents. Furthermore the E384 does not carry any 

passengers or crew for whom the certificate is required to be displayed. DirtPrep 

Solutions proposes that any FAA-required documents be kept at the ground 

control station and that a small placard be affixed to the E384 airframe with 

manufacture, registration, and contact information. 

An equal level of safety will be achieved by having any FAA required 

documents located at the ground control station where it will be readily accessible 

to the PIC and any other agencies that may require the information. Having a 

placard attached to the E384 airframe will also allow any person or agencies to be 

informed of the UAS’ origin and status. 

k. Part 91 Subpart E (91.401-91.417) – Maintenance, Preventative

Maintenance, and Alterations

These regulations provided the maintenance and inspections requirements 

in reference to Part 39 and Part 43. 91.405 (a) specifically states that “no person 
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may perform maintenance, preventive maintenance, and alterations on an aircraft 

other than as prescribed in this subpart and other applicable regulations, including 

part 43 of this chapter”. DirtPrep Solutions seeks full exemption from these 

regulations due to the fact that these sections apply to an aircraft with an 

airworthiness certificate for which DirtPrep Solutions is already seeking 

exemption. 

An equal level of safety will be achieved by using the E384 Operations 

Manual (Reference Appendix A) and E384 Maintenance Manual (Reference 

Appendix B) which provide step-by-step instructions on regular and corrective 

maintenance. The PIC will be responsible for conducting maintenance in 

accordance with these procedures. Any E384 maintenance that is not covered in 

these procedures will be performed by the manufacturer. DirtPrep Solutions will 

ensure that all maintenance performed on the E384 by the PIC and manufacturer 

is documented in accordance with 91.407 (a) (1). Specifically that the records will 

include “a description of the work performed; and the date of completion of the 

work performed; and the signature...of the person approving the aircraft for return 

to service”. The PIC will authorize the E384 for return to service for all 

maintenance covered in the E384 Operations Manual and Maintenance Manual 

and the manufacturer will authorize the E384 for return to service for all 

maintenance that is outside the scope of these two documents. DirtPrep Solutions

will also ensure that no modifications or alterations are made to the airframe that 

affect the flight operating characteristics of the E384. 
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3. How request benefits public as a whole

The E384 is a safe, efficient, and an economical alternative to manned, fixed wing 

aircraft that are currently being used to conduct aerial imaging of mapping zones. There 

are a three major reasons why the public would benefit from granting DirtPrep Solutions

exemptions from these regulations. Authorizing E384 flights over designated sites would 

1) reduce the number of manned aircraft in the NAS, 2) reduce air and noise pollution 

and 3) reduce the risk to life and property on the ground. Utilizing the E384 in lieu of a 

traditional manned, fixed wing aircraft will result in the overall reduction of manned 

aircraft in the NAS. Thus there will be less aircraft that require control and coordination 

with Air Traffic Controllers (ATC). Because the E384 can take-off and land on-site and 

operate at an altitude of 400 ft. AGL (or less) within VLOS of the PIC there is no need 

for ATC to provide coordination during ground, takeoff, departure, transit, arrival, and 

landing phases of flight. As the skies over the United States get busier and busier, any 

small effort to lighten the load of the Air Traffic Controllers would be of great benefit to 

the public. 

At 5.9 lbs. the battery operated E384 with an electric motor provides a much 

quieter alternative to manned, fixed-wing aircraft. Traditionally a manned aircraft would 

have to transit from the departure airport to the desired site and fly at low altitudes to 

achieve high-resolution imagery. The E384 will require no transit time, and the electric 

motor will be exponentially quieter than a twin-engine combustion motor on passenger 

aircraft that is typically used to conduct aerial imaging. In addition the E384 requires no 

fuel since it is battery operated. A manned aircraft on the other hand typically burns 2030 

gallons of aviation fuel per hour which is polluting the air not only over the site but over 
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the path of transit and around the airport. Conducting aerial imaging with the E384 in lieu 

of a manned aircraft would thus greatly reduce both air pollution and noise pollution 

which is of great benefit to the public. 

Using the E384 would also greatly reduce if not completely eliminate the risk to 

life and property on the ground. The E384’s incredibly small size, reduced weight, and 

foam airframe pose no hazard to people or structures on the ground as opposed to a 

manned twin engine-passenger aircraft which has a much greater potential for collateral 

damage. In addition the E384 is unmanned and as a result the risk associated with 

piloting this aircraft is non-existent. Overall the E384 provides a much safer alternative to 

manned, fixed-wing aircraft operations for the purpose of collecting aerial imagery. 

4. Additional information, views, and arguments

The following documents have been included as Appendices to this Petition. 

Appendix A, B, and C have been submitted confidentially for proprietary reasons and 

will not be available to the public.

• E384 Operations Manual (Appendix A)

• E384 Maintenance Manual (Appendix B)

• Event 38 Training Syllabus (Appendix C)

5. Summary for Federal Register

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, 

DirtPrep Solutions, LLC requests exemption from the following Federal Aviation 

Regulations that are found under Title 14 of the Code of Federal Regulations: Part 21 

Subpart H, 45.23 (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 

91.203 (a) (b), Part 91 Subpart E (91.401-91.417). Exemption from these regulations 
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would allow DirtPrep Solutions, LLC to operate the E384 Unmanned Aerial System over 

quarries and construction sites for the purpose of providing high-resolution aerial imagery 

of mapping zones.