Caddis Aerial, LLC Section 333 Petition for Exemption 

		 1

Submitted electronically

July 17, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590 

RE: Petition for Exemption from Certain Federal Aviation Regulations according 

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

Dear Sir or Madam: 

Caddis Aerial LLC (Caddis) is applying for an exemption from the Code of Federal 

Regulations as detailed below.

The exemption would permit commercial operation of a small unmanned aircraft 

system (UAS) in the national airspace (NAS) as regulated by the FAA for the 

following uses:

• Aerial survey

• Pipeline inspection

• Environmental mapping and monitoring of natural resources including forest 

and wetlands

• Resort and golf club inspection

• Rescue mission support including avalanche safety

• Any other commercial and government uses offered by Caddis to its clients

All operations performed by Caddis are cost effective and protect the public by reducing 

the size of the aircraft from one weighing up to several tons to one weighing less than 

55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates 

on high-energy batteries. The UA is flown in the lower strata of controlled and 

uncontrolled airspace at 400 ft. AGL and below. Caddis commercial operations will be 

performed according to FAA regulations or amended FAA regulations as permitted

under a Section 333 Grant of Exemption.
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 2

BACKGROUND AND REFERENCES

The Colorado Plateau covers more than 130,000 square miles. It is an arid, high-desert 

region with some forestland. It includes the southwestern corner of Colorado, 

northwestern corner of New Mexico, northeastern corner of Arizona, and southeastern 

corner of Utah. The sparsely populated area is used for many purposes, including 

mining for mineral resources, electricity generation, logging, grazing, agriculture and 

recreation. Federal, State and local governments must build and supply the 

infrastructure needed to access the local environment to manage wilderness areas, 

population growth, roadways, electricity and water delivery. 

The owners of Caddis have served their commercial clients and the government 

agencies in The Four Corners region by providing data collection and aerial 

photography services with a manned aircraft. The owners are submitting this 333 

exemption petition to increase the safety of their operations and remain competitive 

economically within the region.

In support of this petition and the FAA’s determination process, previously granted 333 

exemption petitions by the FAA with same or similar stated purposes using a UA are 

referenced below:

• Aerial survey: exemption no. 11436, Unmanned Experts, Inc.

• Pipeline inspection: exemption no. 11241, Phoenix Air UNMANNED, LLC

• Natural resource mapping and monitoring (Forestry and wildlife mapping); 

exemption no. 11291, Altavian, Inc. 

• Real estate, resort and golf club inspection: exemption no. 11403, Droneview, LLC

• Rescue mission support, first responders (avalanche safety): exemption no. 11282, 

Down East Emergency Medicine Institute

• Further commercial purposes for safety and public awareness of UA uses; 

exemption no. 11409, Wade Bell.
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 3

NAME OF AGENT FOR CADDIS

Steve McCormack

Caddis Aerial LLC

2 Sandstone Dr.

Durango, CO 81301

For technical and administrative questions on this petition, please contact: 

Mr. Brian Dyer

Remote Pilot Systems

Telephone 484-680-7310 

Email: Brian.Dyer@RemotePilotSystems.com

Submitted separately as confidential documents under 14 CFR Section 11.35 (b) are:

A – Aibot X-6 User Manual

B – Yuneec Typhoon Q500 User Manual

C – Caddis Flight Operations Manual (CFOM)

These documents contain proprietary information that is not available to the public and 

are protected from release under the Freedom of Information Act 5 USC 552 et.seq.

Thank you for your time and attention.

Sincerely,

Brian Dyer
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 4

DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM 

Caddis qualified personnel wish to fly the following aircraft:

• Aibot X-6

• Yuneec Typhoon Q500/Q500 +

The Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a hexacopter in a V-6 

designed for aerial survey and inspection. Aibotix in Germany has delivered more than 

200 aircraft since 2011. The flight control system used with the aircraft is designed and 

manufactured in Germany, has undergone continuous improvement and development, 

with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency 

failsafe to controlled descent or, if GPS signal is sufficient, to return to point 

of takeoff.

• The pilot may override waypoint programming with manual stick control in 

case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe 

announced by voice.

• The X6 is optimized for aerial survey with safety features to reduce pilot 

workload, such as attitude stabilization, GPS satellite-assisted navigation, 

return to home and auto land.

The aircraft is less 1.2 meters, in diameter, is made of carbon-fiber reinforced polymer in 

a high visibility color, with protective blade guards surrounding the six rotors, and is 

designed for a maximum takeoff weight of of less than 15 pounds and a flight time of 

about 20 minutes with its dual-battery power. Maximum speed is about 55 MPH, but 

GSI treats this limitation as an emergency reserve, and plans no flying at greater than 25 

MPH. The aircraft carries no flammable liquid fuel.

Radio control and video transmission systems meet FCC requirements for operation in 

the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 5

interference from devices operating at or near these frequencies or their harmonics are 

documented in the Caddis Flight Operations Manual (CFOM), along with procedures to 

ensure radio safety with the UAS. 

The Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of 

quadcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon 

Q500 has the world's first Smart Transmitter (the "ST-10 series Ground Station" with 

10 channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital 

video link. The series operates on a built-in Android touch screen. Safety features 

include Geo Fencing, Home Mode and Return Home. Geo Fencing prohibits the 

aircraft from exceeding a programmed permitted radius. When activated, Home Mode 

will automatically return the aircraft within a 10-foot radius of its starting point. 

Should the transmitter signal be lost or visual line of sight with the aircraft impaired, 

upon signal, Return Home will automatically take control of the aircraft and return it 

to the operator/base station. Takeoff weight with manufacture provided camera and 

gimbal payload and battery is 3.75 lbs.

The Typhoon Q500 dimensions are 16.5x16.5x8.3 inches with a diagonal of 22.2 

inches without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 

11.1V lithium polymer battery. Radio control and video transmission systems meet 

FCC requirements for operation in the unlicensed spectrum of 5.8 GHz ranges. The 

operating manual of the Typhoon Q500 warns against using the aircraft in areas 

where radio interference is possible, as does the CFOM.

EXTENT OF RELIEF SOUGHT AND WHY 

Caddis asks for relief from regulations tabled below, which the authority of the FAA 

has previously granted in exemption certificates number 11062 along with six others 

described as “in commonality”, and in number 11109, which are for use of electric 

rotorcraft. The CFOM) incorporates the conditions and limitations of these grants of 

exemption, and in some cases imposes stricter limits on its own operations. 

CFR CODE CITATIONS 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 6

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

61.113 (a) Private pilot 

privileges and 

limitations: pilot in 

command

Holder of private pilot 

certificate may not act as 

pilot in command (PIC) for 

compensation or hire. 

Flying for compensation on 

survey missions is central to 

purpose of exemption 

request. 

Characteristics of aircraft, VLOS, 

under 400 ft. AGL, trained visual 

observer in radio communication 

with pilot; controlled access site 

safety protocols enhanced by 

Caddis flight safety plan; PIC with 

airman’s certification, appropriate 

medical and vision qualification or 

valid U.S. driver’s license, currency 

in the aircraft per 61.56, pilot 

training, testing, proficiency with 

similar and same model UA; and 

inspection/maintenance are defined 

in the CFOM and will ensure 

equivalent levels of safety.

61.113 (b) Private pilot 

privileges and

limitations: Pilot in 

command

Holder of private pilot 

certificate may act as PIC 

for compensation or hire if 

flight is incidental to 

business or employment 

and does not carry 

passengers for 

compensation or hire. 

Flying for compensation on 

survey missions is central to 

purpose of exemption 

request, not incidental to 

business or employment. 

There is no passenger or pilot on 

board the UA, thus safety issues are 

different than a manned flight. 

Caddis’ aircraft has programmable 

automated safety features and 

emergency responses, has pre-flight 

checks for safety beyond 

commercial manned aircraft, can be 

geographically restricted by 

operator with programmable 

control points, has communications 

with the PIC regarding fuel loss and 

other flight hazards. PIC will have 

ground school training certificate 

and additional 25 hours logged 

flight time and 25 hours classroom 

and field instruction as stated in 

CFOM. 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 7

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.119 (c) Minimum safe 

altitudes over other 

than congested area 

Operating closer than 500 

feet to a person, vehicle, or 

structure may be necessary 

for survey and equipment 

inspection. 

People will not be allowed over, 

under or within 500 feet laterally of 

the aircraft in flight. Some flights 

may require the participation or 

guidance of industry personnel, 

positioned as close as 200 feet. 

Caddis will brief them on safety and 

obtain necessary consent. Industry 

site safety rules will be followed. 

91.121 Altimeter settings Procedures to set and 

confirm altitude do not 

provide for operation of 

remote telemetry to UAS

pilot. 

An onboard air pressure sensor and 

software resolve height differences 

as small as one centimeter. Altitude 

is controlled by measuring air 

pressure and the z-axis 

accelerometer/GPS values. The 

starting point is a relative height 

measurement calculated by the 

flight controller. Altitude above 

ground is displayed on the pilot's 

handheld controller by telemetry, 

and alarms can signal conditions of 

interest. 500 feet AGL is the 

maximum permissible in the 

CFOM, which describes altimeter 

procedures.
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 8

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.151 (b) Fuel requirements 

for flight in VFR 

conditions

Rotorcraft under VFR must 

carry enough fuel to reach 

first landing point and then 

another 20 minutes. The 

multirotor aircraft specified 

in this petition are designed 

to fly for a maximum flight 

duration of on more than 

30 minutes with its two

batteries. 

Battery voltage under load is 

displayed on the pilot's handheld 

controller during flight. The X6 

uses 2 lithium polymer batteries of 

a multi-­‐cell design, connected in 

parallel for redundancy and optimal 

current delivery. Battery chemistry 

does not support adequate current 

discharge below about 3 v per cell. 

Circuitry in the onboard flight 

controller measures voltage and will 

start a failsafe procedure to land 

before summed minimums are 

reached. In the event that one or 

more cells fail, these minimums 

may be reached sooner than 

expected, due to rapid current drain 

against a smaller number of 

functioning cells. Caddis pilots are 

trained to monitor voltage and 

recognize abnormal discharge in 

flight and to land sooner than 

forced. If 20 minutes of flight time

or 25% of reserve voltage under 

load is reached, pilot must 

commence landing. 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 9

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.405 (a) Maintenance 

required

Required inspections and 

discrepancies repaired 

between the required 

inspections pertain to 

certificated manned aircraft 

and procedures conducted 

by licensed maintenance 

personnel. In the absence of 

certification requirements 

for UAS and UAS

maintenance personnel, 

reasonable alternatives must 

be developed to maintain 

equivalent levels of safety. 

Caddis will document maintenance, 

overhaul, replacement and 

inspection requirements in the 

absence of manufacturer's 

requirements; will document and 

maintain maintenance records and 

technician qualification criteria in 

the CFOM. 

91.405 (b) Maintenance 

records

Qualifications for 

maintenance personnel for 

UAS were not 

contemplated by these 

regulations, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Qualifications, competence and 

testing for maintenance personnel 

are defined in the CFOM. Caddis

will also abide by USDOT FAA 

Notice N 8900.296

91.407 (a) 

(1) 

Operation after 

maintenance, 

preventive 

maintenance, 

rebuilding, or 

alteration

There is no authorization 

procedure for a person who 

can approve a return to 

service of an UAS, and a 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Procedures for the PIC to test then 

approve a return to service after 

maintenance are defined in the 

CFOM. 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 10

14 CFR 

PART 

SUMMARY OF 

REGULATION 

REASON FOR 

EXEMPTION 

REQUEST 

EQUIVALENT LEVEL OF 

SAFETY 

91.409 (a) 

(1) 

Inspections Annuals conducted by a 

qualified inspector require 

authorization criteria for 

that inspector, not yet 

defined for UAS. A 

reasonable alternative must 

be developed to maintain 

equivalent levels of safety. 

Schedules for inspection and 

responsibilities of the PIC and 

qualified technician are described in 

the CFOM. 

91.409 (a) 

(2) 

Inspections Issuance of airworthiness 

certificates for UAS under 

55 pounds operated VLOS 

is not contemplated by 

these regulations 

Airworthiness is the responsibility 

of the PIC and the technician as 

defined in the CFOM. 

91.417 (a) Maintenance 

records

Regulations do not 

contemplate requirements 

or approval processes for 

maintenance and inspection 

of uncertificated UAS, 

however a reasonable 

alternative must be 

developed to maintain 

equivalent levels of safety. 

The operator will maintain records 

according to the procedures as 

specified in the CFOM. 

91.417 (b) Maintenance

records

Retaining and transferring 

records of maintenance and 

defects according to 

standards prescribed for 

authorized maintenance and 

inspection is not 

contemplated in the 

regulations for UAS. A 

reasonable alternative is 

necessary to maintain 

equivalent levels of safety. 

Records and documentation will be 

kept for all maintenance performed, 

defects, and for all components 

specified in the CFOM. 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 11

PILOT IN COMMAND AND CREW 

The pilot in command (PIC) must hold an airman’s certification recognized by the FAA 

such as: an airline transport, commercial, private, recreational, sport pilot, or glider pilot 

(powered or non-powered) and must be in compliance with the training and testing 

specified in the CFOM. The PIC must hold a current FAA airman medical certificate as 

required by the class of airman certification. In the case of the sport pilot certification, 

the PIC must possess a valid U.S. driver’s license issued by a State, the District of 

Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must be in compliance with the training and testing specified in the operator’s manual. 

The PIC must remain in radio communication with a visual observer who is in 

compliance with the training and testing specified in the operator’s manual. The pilot 

must be able to acquire the aircraft with their own vision according to eye standards for a 

third class airman medical certificate or valid driver’s license according to the issuing 

State. The PIC must operate within visual line of sight only, and be able to see the 

attitude and orientation of the aircraft by themself. If GPS or magnetometer is 

compromised, certain safety features may not operate, and the pilot must understand by

their training and experience how to recover control. 

OPERATION OF THE UNMANNED AIRCRAFT 

The aircraft will be under the operational control of the petitioner.

1. The aircraft used for survey operations by Caddis will be the Aibot X6 and 

the Yuneec Typhoon Q500 series as described in the CFOM, unless the 

FAA approves a further amendment to this petition. 

2. The PIC will hold a transport, commercial, private, recreational, sport pilot 

or glider powered or non-powered certificate, a third-class medical certificate

or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government, and must 

meet flight review requirements in an aircraft in which the PIC is rated, 

according to 14 CFR § 61.56. 

3. Caddis pilots will operate at less than 400 feet AGL, in daylight hours only,
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 12

and within visual line of sight of the PIC, five (5) nautical miles or more 

away from an airport reference point as denoted in the current FAA Airport 

/ Facility Directory (AFD) or as denoted in the current FAA / facility 

directory published charts, and use a CFOM-qualified visual observer in 

radio communication with the PIC.

4. Manufacturer’s limitations of the aircraft will not be exceeded, and Caddis’

operations will adhere to power reserves and lower operational limits 

described in the CFOM. 

5. Preflight inspection by the PIC, and inspection and maintenance procedures 

will be followed according to the CFOM, and will be properly documented 

and signed for by an authorized technician who has completed training 

specified in the CFOM. 

6. Test flights by the PIC in connection with maintenance requirements will be 

documented. 

7. Manufacturer systems and safety bulletins will be followed, and flight critical 

components will be monitored and replaced when specified in the CFOM. 

8. Caddis maintenance personnel will document discrepancies discovered 

between inspections. 

9. If visibility is less than three (3) statute miles from the PIC, the aircraft may 

not be operated less than 500 feet below a cloud, or less than 2000 feet 

horizontally from a cloud

10. The PIC must follow emergency procedures as described in the CFOM in 

event of lost link, degraded navigation signals, or appearance of 

unauthorized persons within the secure flight perimeter.

11. A commercial Certificate of Authorization, if required by the FAA, will be 

obtained according to FAA’s designated procedure before any operations are 

conducted, and Notices to Airmen will be filed in accordance with FAA 

requirements. 

12. An N-Number will be obtained for all aircraft operated.

13. RF spectrum will be used in compliance with FCC requirements.

14. Documents required by 14 CFR 91.9 and 91.203 will be available to the PIC 

at the point of flight and control, and will be produced upon request by any 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 13

authority.

15. The aircraft will remain clear of and yield right of way to all manned aviation 

operations and activities at all times. 

16. The PIC will operate the aircraft from a stationary ground position and not 

from any moving device or vehicle. 

17. No operation over congested or densely populated areas is allowed, whether 

or not these areas are depicted on aeronautical charts.

18. The safety of people and property is paramount, and no operations may be 

conducted within 500 feet of non-participants or their property unless 

conducted according to safety procedures in the CFOM, which are approved 

by the FAA. 

19. All operations will be conducted over controlled access property for which 

permission has been obtained prior to flight, and for which safety briefings 

have been completed according to the CFOM. 

20. All incidents, accidents, and transgressions of allowed flight boundaries will 

be reported as required by FAA and NTSB. 

BENEFIT TO THE PUBLIC 

Approval of exemptions allowing Caddis commercial operations of UAs will enhance 

safety by reducing risk. By removing the use of conventional jet fueled aircraft 

weighing in tons for light-weight, battery operated UAs in restricted areas for aerial 

inspection, geo-mapping and image and film capture, is more environmentally sound 

and safe. The use of battery-powered UAs provides a smaller environmental

footprint, increases safety be decreasing manpower and separates the aircraft 

operators form the craft. It further protects the public by being used in restricted 

environments and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 14

The survey aircraft will be operated in accordance with safety protocols defined in the

CFOM, for which we request approval by the FAA according to its authority granted 

by Congress in Section 333 of the FAA Modernization and Reform Act of 2012. 

The survey aircraft carries no person, cargo, or flammable liquid fuel. Its size and 

weight are a small fraction of any manned aircraft, and its safety systems reflect best 

design practices in the UAS industry. 

In addition, Caddis will keep the approved CFOM at its ground control station. The PIC 

will have immediate access to it. Previous exemptions granted by the FAA concerning 

Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft 

Flight Manual is kept at the ground control station of a UAS, where it can be immediately 

accessed by the PIC.

When properly operated by trained pilots, a well-designed UAS can stay clear of 

people and property on the ground and in the air. Procedures, airmanship skills, 

training and testing requirements for UAS personnel in the CFOM will let the 

operator achieve safety levels in the NAS and on the ground that are equivalent to or 

greater than that in manned aviation

SUMMARY FOR PUBLICATION 

The following summary may be published in the Federal Register: 

Caddis requests an exemption from: 

14 CFR Parts 61.113 (a) and (b) 

14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 

(a) (1), 91.409 (a) (2), 91.417 (a) 

in order to operate a small unmanned aircraft system (UAS) for purposes of aerial 

inspections and monitoring, aerial geo-mapping, and aerial imaging and filming and 

aerial data collection. The PIC will be appropriately qualified with a current FAA 

approved pilot certificate for UAS operation and specialized training. 

Operations will include aerial survey, pipeline inspection, environmental mapping and 

monitoring of natural resources including forest and wetlands, resort and golf club 

inspection, rescue mission support and avalanche safety, cinematography, 

videography capture are conventionally done by manned aircraft operations which use 
Caddis Aerial, LLC Section 333 Petition for Exemption 

		 15

jet fuel and weigh upwards of 5,000 lbs. These operations must fly the aircraft to and 

from the operation’s location. 

The survey aircraft used are electric multirotor weighing less than 15 lbs., are less than 

four feet in diameter, are equipped with flight control and safety features that prevent 

flyaway and minimizes the risk to people and property allowed within and outside the 

zone of operations. 

Flight operations outside the secure areas are not allowed. There are no impacts to 

privacy.