Christopher Allen Aspra II

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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Christopher Allen Aspra II

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF  THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on February 25, 2016

Christopher Allen Aspra II

17 Deer Ridge Road

Wimberley, Texas 78676

bearaspra@gmail.com
Christopher Allen Aspra II

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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS   Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 

333

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle 

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
Christopher Allen Aspra II

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INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear Sir or Madam:

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

“Reform Act”) and 14 C.F.R. Part 11, Christopher Allen Aspra II, Operator of Small 

Unmanned Aircraft Systems (“sUAS’s”) equipped to offer on-demand commercial 

UAS operations for a host of industries and applications and to perform the 

purposes listed below, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so 

long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA in an exemption granted under either 

Section 333 or Section 49 U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

predetermined; and 3) would provide safety enhancements in the fields in which it 

will operate, which now depend upon conventional aircraft or humans climbing high 

on dangerous structures, walking in insect laden swamps, and working adjacent 

to treacherous infrastructure. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “... establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.1

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAVs makes and 

models as follows: 

1. 3D Robotics Aero – M 101. HexaCrafter HQ-850

2. 3D Robotics Fixed Wing 102. HexaCrafter HQ-1150

3. 3D Robotics Iris 103. HobbyKing Bixler 2

4. 3D Robotics Solo 104. Hoverfly – Livesky

5. 3D Robotics X8 105. HSE UAV – DRASS Q1000

6. 3D Robotics X8+ 106. Hubsan – X4 Microdrone

7. 3D Robotics X8-M 107. Inova Drone – Inova One

8. 3D Robotics Y6 108. Intuitive Aerial – Aerigon IAH 3

9. AeroCamera - SR 15 109. Kespry Drone Systems

10. Aerial Pixels - Fx8Pro Elite 110. KongCopter FQ700

11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump-15

12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump-20

13. AeroLogix – Geostar 113. Latitude HQ-20

 
Christopher Allen Aspra II

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14. Aeronavics SkyJib-8 Ti-QR 114. Latitude HQ-40

15. Aeronavics X4 Titanium 115. Latitude HQ-60

16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ

17. AeroVironment Puma 117. Leptron – Avenger

18. AeroVironment Qube 118. Lockheed Martin – Desert Hawk III

19. AeroVironment Shrike 119. Lockheed Martin – Indago

20. Aeryon Scout 120. Mavinci – Sirius Pro

21. Aeryon Sky Ranger 121. Microdrones MD4

22. AgEagle 122. Microdrones – MD4-200

23. Agribotix Enduro Quad 123. Microdrones – MD4-1000

24. Agribotix Hornet Drone 124. Microdrones – MD4-3000

25. Aibotix X – 6 125. MikroKopter – ARF OctoXL

26. AirCover ORT-825 126. MLB- Super-Bat UAV

27. AirCover QR-425 127. Multirotor G4

28. Airfield – Extreme Surfer Power Glider 128. MultiRotor – G4 Blackbird V2

29. AirRobot AR 100-B 129. MultiRotor – G4 Skycrane

30. AirRobot AR 100-C 130. Parrot – AR Drone 2

31. AirRobot AR 180 131. ParkZone – Radian RTF

32. AirRobot AR 200 132. Parrot – Bebop

33. Airwing UAV – Talon 133. PrecisionHawk – Lancaster

34. Align M690L Multicopter 134. Precision Drone – PaceSetter

35. Altavian Nova F6500 135. Prioria – Hex

36. Altus UAS Delta X-4 136. Prioria – Hex Mini

37. Altus UAS Delta X-8 137. Prioria – Maveric UAS

38. American Drones – Eagle 550 138. ProJet – RC Drone

39. American Drones – Falcon 450 139. ProJet – RQ-11 Raven

40. American Drones – Nighthawk 550 140. Pulse Aerospace – Scout B1-100

41. American Drones – Phoenix 650 141. Pulse Aerospace – Vapor

42. Arch Aerial – Atlas-1 142. RangeVideo – Jet

43. Arch Aerial – OCTO 143. RF70 Aircraft

44. ARRIS – M680 Hexa 144. RIEGL RiCopter

45. Ascending Technologies – AscTec Falcon 8 145. Ritewing - Drak

46. Birdseyeview – FireFly 6 146. Ritewing - Spade 70"

47. Blade 350 QX3 147. Ritewing - Zephyr 3 Spade

48. Blade Chroma 148. SenseFly eBee

49. Bormatec – Maja UAV 149. SenseFly – eXom

50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace – Magpie

51. CarbonCore – Cortex ARTF 151. Skycatch

52. CineStar – 6 MK Heavy Lift RTF 152. Skyhunter

53. Cinestar 8 Octo 153. Skywalker X-8

54. Cyber Technology – Cyber Quad 154. Splash Drone

55. Delair-Tech – DT – 18 155. SteadiDrone – Flare

56. DJI-F450 156. SteadiDrone – Mavrik

57. DJI-F550 157. SteadiDrone – Vader
Christopher Allen Aspra II

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58. DJI - Inspire 1 158. Swift Radioplanes – Lynx

59. DJI – Matrice 100 159. T-Rex 800E Pro

60. DJI - Phantom 2 160. Tactical Robotics – InstantEye Mk2

61. DJI - Phantom 3 161. Tarot – 450

62. DJI – Spreading Wings S800 162. Tarot – 690

63. DJI – Spreading Wings S900 163. Tarot – 960

64. DJI – Spreading Wings S1000 164. Tarot- 680 Pro

65. DJI – Spreading Wings S1000+ 165. Tarot – T18

66. DJI – Phantom 4 166. Tarot – T810

67. DJI – Inspire 2 167. Tayzu Robotics – Quadra

68. DraganFlyer - X4-ES 168. Tayzu Robotics – Titan X8

69. DraganFlyer - X4-P 169. TBS Caipirinha V2

70. DraganFlyer – X6 170. Trimble UX5

71. Event 38 - E384 171. Trimble UX5-HP

72. Finwing – Penguin 1720 172. Trimble ZX5

73. FlyPro PX400 173. Turbo Ace – Cinewing 6

74. FoxTech FPV – D130 X8 V2 174. Turbo Ace – Matrix G

75. FoxTech FPV – K130 V3 175. Turbo Ace – Matrix I

76. Freefly – Alta 176. Turbo Ace – Matrix E

77. GB-250z 177. Turbo Ace – Matrix S

78. GB-450z 178. Turnigy Talon Quad

79. Germap – G47-X8 179. UAV Solutions – Phoenix 30

80. Germap – G65-Y6 180. UAV Solutions – Phoenix 60

81. Germap – G180 181. UAV Solutions – Phoenix 60LE

82. Germap – G212 182. Vanguard Defense Industries ShadowHawk

83. Germap – SmartOneC 183. Viking UAS – Patriot X4

84. Gryphon Dynamics – Dodeca 184. Viking UAS – Patriot X8

85. Gryphon Dynamics – Hexa 185. Viking UAS – Ranger EX

86. Gryphon Dynamics – Octo 186. Viking UAS – VikingOne

87. Gryphon Dynamics – X8 187. Viking UAS - VK X6 Model 800

88. Gryphon Dynamics – Y6 188. Volt Aerial Robotics - Venture

89. Hawkeye 1700 189. Vulcan – Black Widow

90. Hawk UAS – Silex Systems F15 190. Vulcan – Mantis

91. Helipal - Storm Drone AntiGravity 191. Vulcan – Raven

92. Helipal - Storm Drone 4 192. Walkera – QR X350PRO

93. Helipal - Storm Drone 4 Mini 193. Walkera – QR X800

94. Helipal - Storm Drone 4 Naza 194. Walkera – QR X900

95. Helipal - Storm Drone 6 Naza 195. Walkera – Scout X4

96. Helipal - Storm Drone 8 Naza V2 196. Walkera – Tali H500

97. HexaCrafter HC-650 197. Walkera – Voyager 3

98. HexaCrafter HC-800 198. Yamaha RMAX

99. HexaCrafter HC-1100 199. Yuneec - Tornado H920

100. HexaCrafter HO-1250 200. Yuneec - Typhoon Q500
Christopher Allen Aspra II

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Each separately weighs 55 lbs. or less, with imaging payload and applicable 

equipment.

Equipment operation manuals for each sUAV are included for your reference and 

are considered confidential information for each respective company’s UAS and 

are affixed separately in these documents labeled Appendix.

Commercial (Mission, Operation) Purpose: 

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct 

bridge Inspections, flare stack inspection, utility-power generation system 

inspections and patrolling, aerial inspection, photography and videography of 

residential and commercial real estate, weddings, athletic events such as races,

aerial inspection, photography and videography of utility infrastructure including 

but not limited to electrical power lines, wind turbines and cell towers, well pads, 

lease roads, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site 

inspection and monitoring, public entity support operations, Aerial imaging for 

safety, monitoring and comparing work efforts and completion percentages, and 

security of controlled environment of various sites, aerial video and live video feed 

to assist with search and rescue operations under the authority and support of local 

authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future 

UAS operations within the NAS, special events: including high schools, colleges, 

professional sports, open air events and fairs, research, risk management and 

assessment, surface mining, disaster and catastrophe events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)
Christopher Allen Aspra II

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The name and address of the Petitioner:

Christopher Allen Aspra II

17 Deer Ridge Road

Wimberley, Texas 78676

bearaspra@gmail.com

Background

The Petitioner is Christopher Allen Aspra II. Christopher is a highly accomplished, 

capable, experienced and trusted professional.

Christopher is a highly accomplished, capable and experienced quad copter 

aviator, a trusted professional and proven aviator. Christopher is in the process of 

obtaining a FAA Recreational or sport pilots License. Christopher also has access 

to multiple Licensed FFA Single Engine Land Pilots, which he will be utilized for 

operation of UASs. These Pilots hold specializations and experience in aviation 

safety, instruction, flight operations, contracting and maintenance.

Commitment to Safety

As part of its commitment to safety and innovation, Christopher Allen Aspra II is

asking for this exemption in part, to reduce the risk of injury to any employees or

contractors who participate in the proposed activities the petitioner requests, 

including but not limited to damage to agriculture, natural habitat, buildings and 

other structures within the United States. 

Expertise & Experience

Christopher Allen Aspra II, has professional experience as a trusted sUAV pilot 

and is extremely qualified and is considered an up and coming subject matter 

expert in the local area for UAS of all types, models and makes. 
Christopher Allen Aspra II

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The Exemption Request

Christopher Allen Aspra II proposes the use of the sUAVs will be for capture of 

high resolution imagery and video of residential or commercial applications and 

purposes to a level of quality that allows the Petitioner to use the imagery to 

identify, record, memorialize events and objects according to the purposes noted. 

The imagery and video will be used to identify the condition of landscapes, 

agriculture, events, disasters and infrastructure to conduct bridge inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection, photography and videography of residential and commercial real 

estate, weddings, athletic events such as races, aerial inspection, photography 

and videography of utility infrastructure including but not limited to electrical power 

lines, wind turbines and cell towers, well pads, lease roads, pipeline inspection and 

patrolling, filmmaking, cinematography, and videography, precision agriculture 

with on board sensors, wildlife and forestry monitoring and mosquito and insect 

control, aerial surveying, construction site inspection and monitoring, public entity 

support operations, aerial imaging for safety, monitoring and comparing work 

efforts and completion percentages, and security of controlled environment of 

various sites, aerial video and live video feed to assist with search and rescue 

operations under the authority and support of local authority officials, aerial video 

and photography for public and private use including television, public events, and 

cinematography live feed and live newsgathering, training to persons individually 

or belonging to both private and public organizations to increase awareness and 

improve safety for current and future UAS operations within the NAS, special 

events: including high schools, colleges, professional sports, open air events and 

fairs research, risk management and assessment, surface mining, disaster and 

catastrophe events.

The UAS will be operated by a Christopher Allen Aspra II and or contracting 

operators on occasion to capture high-resolution imagery/video of large structures 

(wide and tall) such as warehouses, high rise buildings, bridges, and construction 

sites, as well as “bird’s eye” views of fire and explosion sites. Given the small size 

of the sUAVs involved, no more than 55 lbs., majority of the speed of operation be 

between 5-15 mph and the restricted environment within which they will operate, 

the Petitioner falls squarely within that zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing 

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems 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 UASs do not 
Christopher Allen Aspra II

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create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following:

• 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.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “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.” Id. §333(c) (emphasis added).2

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil aircraft, 

as the term is defined under §40101 of the Act: The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant 

exemptions reaches such issues as authorization of commercial operation of 

aircraft without an FAA issued pilot’s license.

Christopher Allen Aspra II, in filing this application is requesting that the FAA 

combine the grant of the Section 333 exemption with a standard Certificate of 

Operation (COA) that will allow commercial operations of his sUAV without the 

necessity of filing for a COA for each flight, unless such flight is to be conducted in 

an area not approved in the exemption. Compliance with the conditions agreed to 

herein and that may be imposed by the FAA, as set forth in prior Section 333 

exemptions, provide the separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no 

closer than 5 nautical miles of the geographic center of an airport as denoted on a 

current FAA published aeronautical chart, unless a letter of agreement with that 

airport’s management is obtained, Christopher requests that operations over 

congested or densely populated areas be allowed. The new sUAVs do have GPS 

geo-fencing, it will operate at a very low altitude, within confined areas, at low 

speed and weighs no more than 55 lbs. Such operations will only be under-taken 

with the approval of the land or home owner, as set forth herein, and will comply 

with the requirements that operations be no closer than 500 feet to the adjacent 

 

2 Applicant interprets this provision to place a duty on the Administrator to not only 

process applications for exemptions under section 333, but for the Administrator to 

craft conditions for the safe operation of the UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval.
Christopher Allen Aspra II

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building unless the land owner has provided permission, and the Operator has 

made a safety assessment of the risk from such operations. 

Operator Requirements

Given the sUAV proposed by Christopher Allen Aspra II, Operators should not be 

required to hold a private pilot license. Christopher believes that 1) the operator, 

instead of understanding how to operate a passenger carrying aircraft, should have 

knowledge and experience that enables the safe operation of a small, remotely 

piloted sUAV should understand airspace restrictions and know how to ensure 

separation from other aircraft as well as non-participants and property; 2) the sUAV 

has built-in technical capabilities that limit the potential for unsafe operation and 3) 

there are other security screening mechanisms already in existence that 

Christopher will utilize to ensure the operators are acting consistently with national 

security interests. 

Given the sUAV safety features outlined below, Christopher Allen Aspra II

proposes that his operations under this Exemption request should not be required 

to hold a commercial or private pilot certification. Instead, Operators should be 

required to: have successfully completed, at a minimum, FAA private pilot ground 

instruction and passed the FAA Private Pilot written examination or FAArecognized equivalents; have completed Christopher Allen Aspra II’s training 

program for operation of the UAS.

Christopher Allen Aspra II notes that 1) the FAA has found that safety factors 

permitted operation of sUAVs by Operators with these qualifications in the case of 

operations pursuant to public COAs when the mandatory operating conditions 

specified above were present; and 2) that the Notice of Proposed Rulemaking 

entitled Operation and Certification of Small Unmanned Aircraft Systems, 80 F.R. 

9544 (February 23, 2015) (“NPRM”), does not require the operator to hold a private 

pilot license or a third class medical.

Advanced sUAVs have a navigation and control system and auto-pilot that allows 

it to execute very accurate pre-programed flights. Flights are pre-programmed with 

GPS waypoint to establish perimeters beyond which the aircraft will not operate. 

Flights under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from 

the control unit, and the autopilot executes those maneuvers. Pre-programmed 

Operator interventions include: initiation of holding at present position; suspension 

of mission; fly back to launch point; abort mission and land immediately; and 

emergency power cut off and land (flight termination system). Additional 

automated safety functions and safety enhancing features of the advanced sUAVs 

may include the following:
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1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing, 

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 

10% levels. Low power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down 

in flight in the event of a loss of control or un-commanded deviation from 

the flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximum of 400 feet AGL. 

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has 

determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), 

in comparing the requirements for private pilot knowledge and the knowledge 

required for a commercial pilot, that knowledge associated with a private pilot 

license, and therefore private pilot ground school, was sufficient to allow private 

pilots to operate sUAVs under those exemptions. 

Based upon that analysis, Christopher Allen Aspra II believes successful 

completion of FAA private pilot ground school is a suitable predicate to operating 

the sUAV under this exemption. Christopher Allen Aspra II proposes that the 

Operator accumulate required sUAV flight training hours through the operation of 

sUAVs rather than flight hours in conventional aircraft. Those hours are more 

relevant to the operations proposed herein than hours gained in obtaining a private 

pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of 

magnitude heavier than the sUAS and carry not only the pilot himself, but also 

passengers and fuel, none of which is carried in the sUAS. These conventional 

aircraft fly over all sorts of airspace without the permission or knowledge of the 

landowner. 

A handheld radio controller controls the sUAV and the vehicle is operated within 

the line of sight. The requirements of Part 61.127 (commercial flight proficiency) 

and §61.107 (private flight proficiency), to the extent they are relevant to UAS 

operations, can be taught in the training proposed herein. As a review of the 

requirements of part 61.127 and 107 demonstrate, the issues presented as they 

relate to a 55-pound aircraft, operating at less than 30 mph during filming 

operations are those taught in ground school and in flight training with the particular 

UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas 

or jet A powered aircraft completing cross country flights and take offs and landings 

at controlled and uncontrolled airports.
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As to national security review of pilots, each of Christopher Allen Aspra II’s 

pilots/operators will obtain internally provided certified training (Ground and 

Practical) from Christopher Allen Aspra II to operate the sUAV. This review and 

certification could reasonably vet the Operators against any known terrorist or no 

fly listings that are relevant and publically available.

Christopher Allen Aspra II additionally asks that the exemption be issued without 

the requirement for a visual observer. As set forth herein, an equivalent level of 

safety is provided by the size, speed and control capabilities of the aircraft, as well 

as the operational procedures that will be applicable to all flight hereunder. These 

obviate the need for the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she 

will walk and follow the aircraft around the inspection area so that while it is flying 

its pre-programed and at times, manual flight path, the UAS will always be directly 

in his or her line of sight. The Operator will not be distracted by viewing the pictures 

taken during the flight. Rather, once the sUAV is launched, the Operator’s only 

duty will be to watch the flight of the UAS over the structure and intervene to 

address flight path deviations or other issues that arise during the flight. The 

functions that an observer performs where the aircraft is flown at long distances 

from the launch area will not be necessary as the Operator will always have the 

aircraft in his or her direct sight. The observer also will not be necessary because 

the Operator will conduct a pre-flight inspection of the area, will and if needed, 

cordon off the area and will perform frequent visual scans of the area while the 

vehicle is operating.

Christopher Allen Aspra II again notes that the NPRM does not require the use of 

a visual observer. Given the clear direction in Section 333 of the Reform Act; the 

authority contained in the Federal Aviation Act, as amended; the strong equivalent 

level of safety surrounding the proposed operations, and the significant public 

benefit, including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing battery powered sUAVs for these 

functions instead of turbine or gas power aircraft/rotorcraft and operations with 

pilots having at least a private pilot license, the grant of the requested exemptions 

is in the public interest. 3

 

3 Should the FAA determine that it cannot grant such an exemption for operations 

without a FAA licensed private pilot, despite the showing made herein, under the 

statutory authority the FAA already has, the Petitioner listed above will operate its 

aircraft with pilots holding at least a private pilot certificate issued by the FAA. In that 

event, the Petitioner requests that the exemption be granted with conditions similar 

to those contained in numbered paragraphs 14-15 in Exemption 11136
Christopher Allen Aspra II

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Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety 

to operations under the current regulatory structure because the proposed 

operations represent a safety enhancement to the operations conducted with 

conventional aircraft or with humans climbing up and around structures. These 

conditions are drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 

11062, 11109, 11112, and 11213 and as recent as 11857.

These limitations and conditions to which Christopher Allen Aspra II (referred to as 

“Operator”) agrees to be bound when conducting commercial operations under an 

FAA issued exemption include:

1) Operations authorized by this grant of exemption are limited to 

the aircraft described in the Operator’s manual, which is a multirotor weighing up to 55 pounds. Proposed operations of any 

other aircraft will require a new petition or a petition to amend 

this grant. 

2) The UA may not be flown at an indicated airspeed exceeding 

30 mph (10 mph during inspections). 

3) The UA must be operated at an altitude of no more than 400 

feet above ground level (AGL), as indicated by the procedures 

specified in the Operator’s manual. All altitudes reported to ATC 

must be in feet AGL. 

4) The UA must be operated within visual line of sight (VLOS) of 

the Aircraft Operator at all times. This requires the Aircraft 

Operator to be able to use human vision unaided by any device 

other than corrective lenses. 

5) The Exemption Holder’s Manuals must be amended to include 

all conditions and limitations required by the FAA. The Manuals 

must be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions 

and limitations in the exemption and the procedures outlined in 

the Exemption Holder’s Operator’s manual, the conditions and 

limitations in the exemption take precedence and must be 

followed. Otherwise, the Aircraft Operator must follow the 

procedures as outlined in its Aircraft’s manual. The Exemption 

Holder may update or revise its Manuals. It is the Exemption 

Holder’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon 

request. The Exemption Holder must also present updated and 
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revised documents if it petitions for an extension or amendment 

of this exemption. If the Exemption Holder determines that any 

update or revision would affect the basis upon which the FAA 

granted this exemption, then the Exemption Holder must 

petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS 

to ensure it is in a condition for safe flight. If the inspection 

reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary 

maintenance has been performed, and the UAS is found to be 

in a condition for safe flight. The Ground Control Station must 

be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

7) Any UAS that has undergone maintenance or alterations that 

affect the UAS operation or flight characteristics, e.g., 

replacement of a flight critical component, must undergo a 

functional test flight in accordance with the Exemption Holder’s 

Manuals. The Aircraft Operator who conducts the functional test 

flight must make an entry in the UAS aircraft records of the 

flight. The requirements and procedures for a functional test 

flight and aircraft record entry must be added to the Exemption 

Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements, with particular attention 

to flight critical components that may not be addressed in the 

manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, 

inspections, and record keeping requirements in accordance 

with the Operator’s Manuals. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total 

flight hours, description of work accomplished, and the 

signature of the authorized technician returning the UAS to 

service.

10) The authorized technicians must receive and document training 

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a 

record entry in the UAS logbook or equivalent document of the 
Christopher Allen Aspra II

Page 15

corrective action taken against discrepancies discovered 

between inspections.

13) Prior to commencing operations, the Aircraft Operator shall 

have logged at least 25 hours of total time as a UA rotorcraft 

pilot and at least ten hours logged as a UA pilot with a similar 

UA type and 5 hours in the make and model.

14) If the UAS loses communications or loses its GPS signal, the 

UA must return to a pre-determined location within the private 

or controlled-access property and land or be recovered in 

accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the flight in the event of 

unpredicted obstacles or emergencies, including unauthorized 

people entering the flight area, in accordance with the 

Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight 

unless (considering wind and forecast weather conditions) 

there is enough power to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 

10 minutes.

17) All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 

CFR part 47, and have identification (N- Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.

18) Before conducting operations, the radio frequency spectrum 

used for operation and control of the UA must comply with the 

Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must 

be available to the Operator at the Ground Control Station of 

the UAS any time the aircraft is operating. These documents 

must be made available to the Administrator or any law 

enforcement official upon request. 

20) The UA must remain clear and yield the right of way to all other 

manned operations and activities at all times (including, but not 

limited to, ultra-light vehicles, parachute activities, parasailing 

activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any 

moving device or vehicle.
Christopher Allen Aspra II

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22) UAS operations may not be conducted during night, as defined 

in 14 CFR 1.1.

23) All operations must be conducted under visual meteorological 

conditions (VMC). The UA may not be operated less than 500 

feet below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the Operator.

24) During operations the UA may not operate within 5 nautical 

miles of the geographic center of an airport as denoted on a 

current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the 

operation is conducted in accordance with a NOTAM, if as 

required by the Operator’s COA. The letter of agreement with 

the airport management must be made available to the 

Administrator upon request.

25) The UA may not be operated over congested or densely 

populated areas unless the conditions set for in #26 are 

satisfied. These populated areas include but are not limited to 

the yellow areas depicted on World Aeronautical Charts (WAC), 

Sectional Aeronautical Charts (Sectionals), or Terminal Area 

Charts (TAC). However, aeronautical charts may not reflect 

pertinent local information. Ultimately, it is the Operator’s 

responsibility to maintain the minimum safe altitudes required 

by § 91.119 (d) (1). 

26) Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from debris in the event of an 

accident. The Aircraft Operator must ensure that 

nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave 

such protection and are within 30 feet of the UA, flight 

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or 

structures where the land owner/controller has granted 

permission and/or the Aircraft Operator has made a safety 

assessment of the risk of operating closer to those objects 

and;

c. Operations near the Aircraft Operator do not present an 

undue hazard to the Operator per § 91.119(a).
Christopher Allen Aspra II

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27) All operations shall be conducted over private or controlledaccess property with permission from the land owner/controller 

or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained 

for each flight to be conducted.

28) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined 

by the applicable COA must be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

Specific Uses Public Benefits 

Christopher Allen Aspra II proposes use of his sUAV provided equivalent or 

augmented levels of safety for each of the uses proposed herein: 

The present systems of photography and videography and mapping of inspecting 

the roofs, agriculture land, buildings and large structures site surveys, wild life 

monitoring, mosquito and insect control are now conducted by either a person 

wading through swamps, climbing on the roofs and structures that are steep, tall, 

slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must 

climb on the roofs or require the use of aircraft that are orders of magnitude greater 

in size than the sUAV. Either method, manual inspection or large conventional 

aircraft, results in increased risk of injury due to personnel falling off roofs or 

ladders, carrying heavy ladders and dealing with confined and dangerous spaces, 

or increased risk from low altitude flyovers with helicopters or fixed wing aircraft 

inspecting buildings after damage from storms or other disasters, such as 

earthquakes or fires. Such flights are, of course, significantly more expensive than 

those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, 

but those who are along the path of flight associated with the arrival and departure 

of the conventional aircraft at the inspection site because the aircraft must be flown 

to and from the site. By contrast, the sUAV is carried to the site and transits no 

other property. Conventional aircraft carry flammable fuels that are not carried by 

the UAS and emit pollutants associated with internal combustion engines. The 

sUAVs proposed herein are battery powered and have no emissions.
Christopher Allen Aspra II

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Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in 

Command; 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, Christopher Allen 

Aspra II’s sUAV is remotely controlled with no passengers or property of others on 

board. Section 61.133(a) requires an individual with a commercial pilot’s license to 

be pilot in command of an aircraft for compensation or hire. 

Christopher Allen Aspra II respectfully proposes that Operator requirements 

should take into account the characteristics of the particular UAS. Christopher 

Allen Aspra II’s sUAV has a high degree of pre-programmed control and various 

built-in technical capabilities that strictly limit the potential for operation outside of 

the operating conditions set forth in the exemption application. Christopher Allen 

Aspra II’s sUAV has navigation and control system comprised of a Ground Control 

Station (GCS) and auto-pilot system that can be pre-programmed to set 

operational boundaries. All flights are pre-programmed with precision GPS 

guidance. In the case of unplanned events, the Operator may input preprogrammed evasive maneuvers from the control unit, and the onboard autopilot 

executes those maneuvers. Pre-programmed Operator interventions include 

initiation of holding at present position; suspension of mission; fly back to launch 

point; abort mission and land immediately; and emergency power cut off and land 

(Flight Termination System). 

Additional automated safety functions and safety enhancing features of

Christopher Allen Aspra II’s sUAVs may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% 

and 10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will 

hold position at its current location for 5 seconds and if the signal is 

not restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft 

down in flight in the event of a loss of control or un-commanded 

deviation from the flight path. 

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog 

signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph 

(while imaging) nor above 200 feet above the structure (imaging

altitude) or a maximum of 400 AGL. 
Christopher Allen Aspra II

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Given these safety features, Christopher Allen Aspra II proposes that Operators of

Christopher Allen Aspra II’s sUAV should not be required to hold a commercial or 

private pilot certification. 

Instead, Operators should be required to: have successfully completed, at a 

minimum, FAA private pilot ground instruction and passed the FAA Private Pilot 

written examination or FAA-recognized equivalents; have completed the 

manufacturer’s or Christopher Allen Aspra II’s training program for operation of the 

UAS.

Christopher Allen Aspra II notes that the FAA has found that safety factors 

permitted operation of UASs by Operators with these qualifications in the case of 

operations pursuant to public COAs where the mandatory operating conditions 

specified above were present. See, Federal Aviation Administration, Notice N8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20-21 (July 

30, 2013). Likewise, Christopher Allen Aspra II notes that the NPRM does not 

require that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be 

provided by allowing operation of Christopher Allen Aspra II’s sUAV without a 

private pilot’s certificate or a commercial pilot’s certificate, under the conditions set 

forth herein.

The risks associated with the operation of Christopher Allen Aspra II’s sUAV (given 

its size, speed, operational capabilities, and lack of combustible fuel) are so 

diminished from the level of risk associated with private pilot operations or 

commercial operations contemplated by Part 61 with conventional aircraft (fixed 

wing or rotorcraft), that allowing operations of the UAS as set forth above meets or 

exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) 

and does not rise to the level of requiring a commercial pilot to operate the aircraft 

under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial 

operation of the UAS without an airworthiness certificate, no standard will exist for 

airworthiness of the UA. Given the size of the aircraft and the requirements that 

the Operator has agreed to as it relates to airworthiness, as contained in the 

manual, an equivalent level of safety will be achieved by insuring compliance with 

the manuals prior to each flight. The FAA has granted exemptions to conduct 

similar operations in Exemptions 11062 through 11067, 11080 and 11110.
Christopher Allen Aspra II

Page 20

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed 

of the UAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner, facility owner, and/or local officials. 

Because of the advance notice to the property owner and participants, all affected 

individuals will be aware of the planned flight operations as set forth in the Manuals. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the 

maximum 55 lbs. and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented by conventional aircraft 

operating at or below 500 AGL in the aerial photography industry. In addition, the 

low-altitude operations of the sUAS will ensure separation between these smallUAS operations and the operations of conventional aircraft that must comply with 

Section 91.119. The FAA has granted exemptions to conduct similar operations in 

Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As the 

Christopher Allen Aspra II’s sUAV, in manual or emergency mode, will not have a 

barometric altimeter display, but instead a GPS altitude display, an exemption will 

be needed. The Operator, pursuant to the procedures set forth in the Manuals as 

indicated before flight, will achieve an equivalent level of safety. The FAA has 

granted exemptions to conduct similar operations in Exemptions 11062 through 

11067, 11080 and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; 

or (2) At night, to fly after that for at least 45 minutes.” 
Christopher Allen Aspra II

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The battery powering the sUAS provides approximately 40 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights 

would be limited to approximately 10 minutes in length. Given the limitations on 

the UAS’ proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight is reasonable. 

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the 

small UAS, in a tightly controlled area where only people and property owners or 

official representatives who have signed waivers will be allowed, with less than 30 

minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) 

was intended to alleviate given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of remaining battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, 

10808 and Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): 

Maintenance Inspections

These regulations require that an aircraft Operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall 

inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits 

an equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in defined areas for 

limited periods of time. If mechanical issues arise, the UAS can land immediately 

and will be operating from no higher than 400 feet AGL. As provided in the Aircraft 

Flight Operations Manual the Operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the Operator and manufacturer are most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. The FAA has granted 

exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 

11110.
Christopher Allen Aspra II

Page 22

*********

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site 

inspection and monitoring, public entity support operations, aerial video and live 

video feed to assist with search and rescue operations under the authority and 

support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS, special events: including high schools, 

colleges, professional sports, open air events and fairs, research, risk 

management and assessment, surface mining, disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Inspection will be of inanimate objects in 

areas where the owners will have consented to the inspections or otherwise have

agreed to allow the UAS and the Operator to be in the area where operations will 

take place. 

The size of the UAS, its speed and restricted area of operation do not raise 

national security issues.
Christopher Allen Aspra II

Page 23

Summary

Approval of exemptions allowing commercial operations of sUAVs for petitioner to 

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection and photography of residential and commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial video and live video feed to 

assist with search and rescue operations under the authority and support of local 

authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future 

UAS operations within the NAS, special events: including high schools. colleges, 

professional sports, open air events and fairs, research, risk management and 

assessment, surface mining, disaster and catastrophe events, will enhance safety 

by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing 

people in swamps, on roofs or tall, hazardous or weakened structures, exposes 

them to higher risks than those created by use of a sUAVs. Conventional aircraft 

that operate at extremely low altitudes just feet from the subject being inspected 

and in extreme proximity to people and structures present the risks associated with 

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other 

fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project 

location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible 

fuel carried on board. The sUAV is carried to the target area and not flown. The 

sUAV will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein. These lightweight aircraft operate at 

slow speeds, close to the ground, and in areas that are under the control of the 

customer for the operations and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the 

ground and people or the use of individuals to climb the structures to conduct the 

operations.
Christopher Allen Aspra II

Page 24

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas 

and operation within visual line of sight and national security – provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial operation of Petitioner’s UAS for the Purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions number 11171 

through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 

11857.

Sincerely,

Christopher Allen Aspra II

17 Deer Ridge Road

Wimberley, Texas 78676

bearaspra@gmail.com