U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12B140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial 

Use of Unmanned Aircraft Systems

Petitioner:

Rincon Research Corporation

David L. Haycock, Ph.D.

101 N Wilmot

Tucson, AZ 85711

Tel.: 520.519.4600

To Whom It May Concern,

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

and 14 C.F.R. Part 11.81, Rincon Research Corporation hereby applies for an exemption from 

the following Federal Aviation Regulations. This application is substantially based on the FAA's 

findings in Exemptions 11062, 11109, 11213 and specifically 11351 granted to bizUAS Corp on 

April 17, 2015, and in reliance on the analysis provided therein.

1. Sections from which exemptions are sought: Application is hereby made for exemption 

from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief sought:

a. Rincon Research Corporation wishes to operate small Unmanned Aircraft Systems 

(sUAS) for commercial purposes for aerial data collection. This relief is sought 

because commercial use of sUAS is currently prohibited by law unless performed 

under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh

substantially less than 55 pounds including payload and energy sources:

i. 3D Robotics X8+
ii. 3D Robotics Solo

iii. Tarot 680 Pro

iv. Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently obtained 

by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., 

power line inspections) and due to other dangerous activities that can be avoided 

(e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and the 

economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions 

from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 

and Part 45, Subpart C. The size of the markings and the word “Experimental” will be 

dependent on the size of the aircraft being used and in most cases be smaller than 2 

inches in height.

b. Aircraft will comply with maintenance and inspection requirements of the

manufacturer. All repair and maintenance work will be conducted or approved by

qualified personnel, and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each aircraft.

c. All flight operations will be conducted by at least two individuals (PIC and observer) 

who will maintain verbal communication capability with each other at all times 

during the flight, and who will remain stationary on the ground during the flight 

operations:

i. A Pilot In Command (PIC) who possess the following credentials:

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened 

by the TSA

2. A Third Class medical certificate issued under 14 CFR 67 or a valid state 

driver’s license.

3. A bi-annual flight review under 14 CFR 61.56

4. At least 5 hours of flight experience and 3 takeoffs and landings in make and 

model being flown in the prior 90 days. Such cycles and hours may be gained 

during flights under this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119.

ii. A Visual Observer.

iii.A Sensor Operator as necessary.

d. All flight operations will be conducted in accordance with valid Certificates of

Authorization.

e. All flight operations will comply with the following:

i. The manufacturers' Aircraft Flight Manuals and Operation Guidelines 

ii. Rincon Research Corporation flight operations policies including lost 

communication, emergency, and safety procedures.

iii. Conducted in VMC conditions during daylight hours.

iv. PIC and VO will maintain VLOS at all times.
v. Pre-flight inspections (including ground control station, if any) and safety risk 

assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet above ground level.

vii. Flight ground speeds will not exceed 50 knots.

viii. Not intrude into Class B, C, or D airspace, or published approach, SID or

STAR, or take place within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons 

on the ground without their prior permission.

x. Each flight will be logged in both the PIC's logbook and the aircraft logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first.

xii. Any incidents will be reported to NTSB within 24 hours of occurrence.

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use frequencies of 915 MHz and 2.4 GHz for control of the aircraft and 

for sending data with well-defined and tested lost link procedures.

Please advise us of any additional information or changes that may be required.

Sincerely,

David L. Haycock, Ph.D.

Rincon Research Corporation

07/28/2015