U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Offshore Aviation LLC for an Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012

Petition for Exemption Filed under Section 333 of the FAA Reform Act and Part 11 of 

the Aviation Regulations.

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

Act) and 14 C.F.R. Part 11, Offshore Aviation LLC, a Maryland limited liability 

company, hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow it to operate a small Unmanned Aircraft System (UAS) under the 

conditions and limitations set forth in this Petition. The areas of aerial filming production 

include real estate marketing, feature films, television commercials, documentaries,

construction survey, 3-D mapping, and educational research & development.

This exemption is made based on information outlined in this petition (Appendix A), as 

well as the accompanying VulcanUAV and DJI Manuals (Appendix B), Offshore 

Aviation LLC’s Standard Operation Procedures (SOPs) (Appendix C), Pilot Checklists, 

Briefing Guide (Appendix D), and UAS photos and specifications (Appendix E).

Introduction

Offshore Aviation LLC is a professional production company specializing in aerial 

digital media. The company, which was founded by professional military and 

commercial aviators, intends to operate aerial camera systems for commercial 

photography and videography in the United States. 

Offshore Aviation LLC has years of experience demonstrating UAS technology and has a 

history of supporting academic research and development (R&D) projects. The 

company’s pilots and camera operators have participated in numerous student science 

and R&D projects in Maryland, Virginia, and Washington DC and are widely recognized 

as experts in UAS design and flight operations. 

Offshore Aviation LLC’s comprehensive operations and training programs are based on 

sound military techniques and procedures. We use professionally designed UAS(s) that 

are supported by technical manuals, military style maintenance programs, and operational 

standards designed to promote safe and effective operations. 

Our UAS pilots have FAA Commercial multi-engine ratings and hold current class II or 

higher medical certificates. In addition to these advanced ratings our Director of UAS 

Operations, Chief UAS Pilot and Instructor has accumulated over 2,500 military jet hours 

and over 2,000 military UAS hours. He has a Master’s Degree in Aerospace 

Engineering, is a graduate of United States Navy Test Pilot School, United States Naval
Aviation Safety School and has been flying in the radio control aircraft hobby for over 16 

years. He brings this wealth of knowledge and experience to our professional UAS

operations.

Specifically, the UASs are:

Two lightweight (< 30.0 lbs gross weight with all on-board equipment), battery operated 

6 and 8-motor rotorcraft in the form of a Hexacopter (Mantis) & Octocopter (Raven) that 

take-off and land vertically. The airframes are manufactured by VulcanUAV and

electronics are manufactured by DJI, with the following equipment:

 An on-board flight computer with GPS navigation and location ability that 

receives signals for flight controls from a ground-based transmitter/controller;

 An on-board camera capable of capturing imagery in the form of full color, high 

definition still photos and video;

 Onboard camera and gimbal is controlled by separate controller operated by 

dedicated Payload Operator (PO);

 An on-board telemetry system that delivers flight data from the on-board flight 

computer to the on-board radio transmitter including altitude AGL, horizontal and 

vertical speed, compass direction of flight and direction back to its launch site;

 A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the 

on-board camera plus all the flight data from the telemetry system described 

above;

The Ground Station Includes:

 A Pilot in Command (PIC) in operational control of a flight operation from 

beginning to end and who controls the UAS while in the air;

 A 500mW, 433MHz radio transmitter/controller operated by the PIC to control 

the UAS while in flight;

 A 100mW, 2.4GHz radio transmitter/controller operated by the PO to control the 

camera and gimbal while in flight;

 A radio receiver receiving live video and flight data from the on-board camera 

and computer projects it all together onto a screen for the PIC to view during 

flight if needed;

 A radio receiver receiving live video and flight data from the on-board camera 

and computer projects it all together into a pair of video goggles for the PO to 

view during flight.

Proposed Operations:

Offshore Aviation LLC intends to use the UASs in three general areas. First, Offshore 

Aviation LLC seeks an exemption to perform video filming and photographing by air for 

public and private use. Second, it will employ UAS’s to inspect land, residential 

commercial and industrial structures and property. Third, Offshore Aviation LLC seeks 

permission to use UASs to offer training to persons, from both private and public entities, 

which are interested in the safe operation of UAS.
Specifically, Offshore Aviation LLC will use UASs which are equipped with cameras 

and sensors, in order to engage in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, including: 

cinematography, educational research & development, feature films and documentaries.

(b) Video filming by air and photographing to support professional operations in 

engineering, land surveying, architecture, real estate and other related professional 

activities.

(c) Inspections by air of infrastructure such as bridges, highways, electrical installations, 

dams, aqueducts, photovoltaic power stations, wind farms and pipes. These inspections 

will only be done under contract with the owners or with any local government authority.

(d) Inspection by air of land and residential, commercial and industrial structures, only 

under contract with the owners or with any local government authority.

(e) Inspections by air to detect sources of pollution and gas emissions, under contract 

with the owners in the area or with any local government authority.

(f) Support provided to search and rescue operations and reconnaissance in cases of need, 

emergency or natural disasters and only when government authorities have requested it 

by contract or donation.

(g) Offshore Aviation LLC is avid believer that offering training to persons, private and 

public entities, which are interested in the safe use of UAS(s), will enhancing their skills 

and safety controls which make the NAS safer and further protects persons and property.

Relevant Statutory Authority:

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the 

FAA Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the 

FAA "to safely accelerate the integration of civil unmanned aircraft systems into the 

national airspace system." Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit unmanned aircraft systems to operate in the National Air 

Space ("NAS") where it is safe to do so based on the following considerations:

• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the 

authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 

44701(a), (b) and§§ 44702-44716,et seq.). A party requesting an exemption must explain

the reasons why the exemption: (1) would benefit the public as a whole, and (2) would 

not adversely affect safety (or how it would provide a level of safety at least equal to the 

existing rules). See 14 C.F.R. § 11.81 (petitions for exemption).

Offshore Aviation LLC proposed UAS Operations Meet the Requirements of Section 333 

of the Reform Act
Offshore Aviation LLC proposed operations in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory 

criteria and relevant factors are satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational 

Capability:

Offshore Aviation LLC will employ the UASs (Vulcan Mantis & Vulcan Raven) for the 

operations specified in this Petition for exemption. The Mantis UAS has a maximum 

take-off weight of 17 pounds; the Raven has a maximum take-off weight of 29 pounds. 

The flight speed will not exceed 30 miles per hour, and it will not be flown in controlled 

airspace without prior permission from the controlling agency or at an altitude that 

exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely 

terminated with a reserve battery power of 25% of the battery's maximum charge. The

Vulcan UASs do not carry any flammable propellant or fuel. They have an integrated 

GPS system that calculates the UAS’s position and height and relays that information via 

a secure connection to the operators. Additionally, the Vulcan UASs contain a failsafe 

mode which activates if its connection to the remote control is lost or can via a switch on 

the PICs transmitter/controller, and this system permits the UAS to return to a 

predetermined location and land without injury or damage. For added safety, the Vulcan 

Raven UAS is equipped with bright LED position lighting in the standard FAA 

configuration (red, green and white strobe). These can be easily seen during the day and 

give positional awareness to PIC and other aircraft.

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations 

Manual:

The Offshore Aviation LLC SOPs, Pilot Checklists and Briefing Guide, plus the 

VulcanUAV and DJI operator’s manuals contain all of the procedures and limitations 

necessary to successfully perform the operations specified in this Petition for Exemption. 

(Appendices B, C & E).

Public Interest:

The public interest will be served by granting Offshore Aviation LLC Petition for 

Exemption. Congress has established a national policy that favors early integration of 

UASs into the NAS in controlled, safe working environments such as those proposed in 

this Petition. In addition, the public also has an interest in reducing the hazards associated 

with alternate methods of conducting similar aerial photographic operations. Currently 

operations are conducted using teams that climb structures using ladders to position 

equipment, or low flying helicopters and aircraft. By using UAS, exposure to physical 

hazards will be reduced by conducting the operation while remaining safely on the 

ground.

Additionally, Offshore Aviation LLC’s intended uses for the UAS’s have identifiable 

safety benefits that include reducing the danger and emissions associated with full size 
aircraft, such as dangerous fuels, vastly lower noise pollution, vulnerable aircrew and 

public safety in general. If there is a mishap with the UAS the impact to persons and 

property is far less than if a full size aircraft is involved. 

Federal Register Summary:

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:

Offshore Aviation LLC seeks an exemption from the following rules:

Parts 21; §§ 45.23(b); 27; 61.113(a) and (b); 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 

91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with 

conventional aircraft, rotorcraft, or other methods.

Conclusion:

Offshore Aviation LLC Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity 

to airports and populated areas, operation within visual line of sight and national security. 

Additionally, the Petition provides more than adequate justification for the grant of the 

requested exemptions to permit Offshore Aviation LLC to operate the selected UASs for 

the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, 

including (1) significantly improving safety and reducing risk by alleviating human 

exposure to danger, and (2) improving the quality of services and decreasing operating 

costs compared with conventional flight operations.

Very Respectfully,

Kyle Matthew

Director, Offshore Aviation

14321 Sedwick ave

PO Box 1201

Solomons, MD 20688

Kyle.matthew@offshorepix.com
Appendix A

The regulations from which the exemptions is requested are listed below, underneath 

each are our proposed equivalent level of safety:

Parts 21,§§ 45.23(b); 27, 61.113(a) and (b) 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 

91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

Exemptions Requested:

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, including UASs, from its safety regulations and 

minimum standards when the Administrator decides a requested exemption is in the 

public interest.

Offshore Aviation LLC seeks an exemption from several interrelated provisions of 14 

C.F.R. Parts 21, 27, 45, 61 and 91 for purposes of conducting the requested operations 

using a UAS. Listed below are the specific sections of 14 C.F.R. for which exemption is 

sought:

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates:

The FAA has stated that no exemption is needed from this section if a finding is made 

under the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to aircraft normally used for the same application. (Regulatory Docket No. 

FAA-2014-0352). These criteria are met, and therefore no exemption is needed.

Equivalent Level of Safety:

The UASs selected by Offshore Aviation LLC are safe when taking into account their 

size, weight, speed, and operational capability. The UASs weigh less than 30 pounds and 

will be flown at less than 30 miles per hour and outside controlled airspace unless prior 

permission is granted by controlling agency. Additionally, the UASs carry neither pilots 

nor passengers, carry no explosive materials and or flammable liquid fuels, and operate 

exclusively within the parameters stated in the Operator’s Manuals and SOPs.

Operations under this exemption will be closely controlled and monitored by the operator 

and will be conducted in compliance with local public safety and security requirements. 

Offshore Aviation LLC will also provide the FAA with advance notice of all operations 

via NOTAMS and coordination with the local FSDO. In all cases, the UAS operated 

under the proposed conditions, will be at least as safe as, or safer than conventional 

rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions of the proposed UAS operations.
14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of 

normal category rotorcraft. To the extent the Offshore Aviation LLC UASs would 

otherwise require certification under Part 27, we seek an exemption from Part 27's 

airworthiness standards for the same reasons identified in the request for exemption from 

14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§45.23(b), Display of marks; general

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 2 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the 

cabin, cockpit, or pilot station. The UAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to 

it by the FAA.

Offshore Aviation LLC proposes to achieve an equivalent level of safety by including the 

word "EXPERIMENTAL" as large as practicable on the top of the aircraft, where the 

PIC, PO and others in the vicinity of the aircraft while it is preparing for launch will be 

able to see the designation. Finally, the ground station will display a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches 

high or greater. The banner should be visible to anyone that observes the aircraft and 

chooses to investigate its point of origin.

In a previous Grant of Exemption, Regulatory Docket No. FAA-2014-0352, the FAA 

determined that exemption from these requirements was warranted provided that the 

aircraft "have identification (N-Number) markings in accordance with 14 C.F.R part 45, 

Subpart C if the markings are as large as practicable."

14 CFR § 61.113 (a) and (b); 61.3 (c,2-v): Private Pilot Privileges and Limitations,

Medical Certificate:

Although all current Offshore Aviation LLC PICs hold a commercial pilot certificate and 

class II or high medical we seek exemption from 14 C.F.R § 61.113, which restricts 

private pilot certificate holders from flying aircraft for compensation or hire, and which 

would also require a second class medical certificate for possible future PICs. The 

purpose of this section is to ensure the skill and competency of any PIC where the aircraft 

is carrying passengers or cargo for hire. In this case, while the UAS will be operated as 

part of a commercial operation, it carries neither passengers nor cargo. In the Grant of 

Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the 

additional cost and restrictions attendant with requiring the PIC to have a commercial 

pilot certificate and class II medical certificate. Additionally, instead of having a second 

or third class medical, we suggest that the PIC exercise the privileges similar to that of a 

sport pilot, requiring only a valid US driver’s license.
Safety Mitigation:

Petitioner seeks to ensure safe operation by ensuring that any PIC is thoroughly versed in 

airspace and communication issues pertaining to all aircraft operators but also in the 

unique aspects of UAS flight. The owners and all current PICs of Offshore Aviation LLC 

have commercial pilot’s license, however, the experience obtained beyond a private pilot 

certificate in pursuit of a commercial pilot certificate in manned flight does not 

necessarily aid a pilot in the operational environment proposed. To that end, Offshore 

Aviation LLC will require a PIC to have at a minimum completed private pilot’s ground 

school, pass a FAA private pilot’s knowledge test and adhere to the SOPs listed in 

Appendix C.

We find that the combination of aeronautical knowledge, UAS airmanship skills, and 

verification through remaining current is a sufficient method to evaluate a pilot’s 

qualifications, given that operations will be conducted within the limitations outlined in 

this petition.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness:

Offshore Aviation LLC seeks an exemption from 14 C.F.R. § 91.7(a), which requires that 

a civil aircraft be in airworthy condition to be operated. The FAA has stated (Regulatory 

Docket No. FAA-2014-0352) that no exemption is required to the extent that the 

requirements of Part 21 are waived or found inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft:

Given its size, configuration, and load capacity, the Vulcan Mantis & Raven have no 

ability to carry such a manual on the aircraft, not only because there is no pilot on board, 

but because there is simply no room or capacity to carry such an item on the aircraft.

Safety Mitigation:

The safety related purpose of this manual requirement can be equally satisfied by 

maintaining the UAS Manuals at the ground control point where the crew flying the UAS

will have immediate access to it. Accordingly, we request an exemption from § 91.9(b) 

(2)'s flight manual requirements, on the condition that the Mantis & Raven flight manuals

be available at the control point during each operation.

14 C.F.R. § 91.103: Preflight Action

Offshore Aviation LLC seeks an exemption from 14 C.P.R.§ 91.103, which requires a 

PIC to become familiar with specific information before each flight, including 

information contained in the FAA-approved Flight Manual on board the aircraft. While 

the PIC will be familiar with all information necessary to safely conduct the flight, an 

exemption is requested to the extent that an FAA-approved Flight manual is required.
Safety Mitigation:

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required 

preflight actions- including performing all required checklists and reviewing weather, 

flight requirements, battery charge, landing and takeoff distance, aircraft performance 

data, and contingency landing areas - before initiation of flight. The Operators Manual 

and SOPs will be kept at the ground station with the operators at all times.

14 C.F.R. § 91.109(a): Flight Instruction

Offshore Aviation LLC seeks an exemption from 14 C.F.R. § 91.109(a), which provides 

that "no person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls." UAS 

and remotely piloted aircraft, by their design, do not have functional dual controls. 

Instead, flight control is accomplished through the use of a device that communicates 

with the aircraft via radio communications.

Safety Mitigation:

Given the size and speed of the UAS employed by Offshore Aviation LLC, an equivalent 

level of safe training can still be performed without dual controls because no pilot or

passengers are aboard the UAS and all persons will be at a safe distance away in the 

event that the UAS encounters any difficulties during flight instruction. In addition, we 

will conduct flight training at our Research and Development test sites, which are located 

on its own property. These training flights will be conducted in a sterile area and will 

otherwise comply with the provisions in the Operator’s Manual for flights at the R&D 

facility. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption 

is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

Offshore Aviation LLC requests an exemption from the minimum safe altitude 

requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe 

altitudes under which aircraft may not operate, including 500 feet above the surface and 

away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. 

§ 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA."

Safety Mitigation:

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with 
these operations is far less than those that presently exist with conventional aircraft. An 

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. In order to avoid any risk to aircraft, flight 

operations will be restricted to 400' AGL or below. Prior to conducting UAS operations, 

all persons not essential to flight operations (nonparticipating persons) shall remain at 

appropriate distances. In open areas, the UAS shall remain 500 feet from all persons other 

than essential flight personnel (i.e. PIC, PO, operator trainees or essential persons). If 

barriers or structures are present that can sufficiently protect nonparticipating persons 

from the UAS or debris in the event of an accident, then the UAS may operate closer than 

500 feet to persons afforded such protection. The UAS operator shall also ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UAS, flight 

operations shall cease immediately. When considering how to immediately cease 

operations, the primary concern is the safety of those nonparticipating persons. In the 

event that operations must be conducted closer than 500 feet to vessels, vehicles and 

structures the PIC shall receive permission from the owner/controller of any such vessels,

vehicles or structures and the PIC shall make a safety assessment of the risk of operating 

closer to those objects and determines that it does not present an undue hazard. 

14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an 

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required to the extent that the UASs do not have a barometric altimeter, but 

rather a GPS altitude read out.

Safety Mitigation:

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be 

operated at 400' AGL or below and within visual line-of-sight in addition to GPS based 

altitude information relayed in real time to the operator. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352. As the attached Operations Manual 

indicates, the chosen UAS meets these requirements, and a zero altitude initiation point 

will be obtained prior to flight.

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

Offshore Aviation LLC requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel 

requirements for flight in VFR conditions. Section 91.151 states:

(a) No person may begin 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.
Here, the technological limitations on UAS battery power means that no meaningful 

flight operations can be conducted while still maintaining a 30 minute reserve. Offshore 

Aviation LLC proposes that all flights comply with this requirement by mandating that 

the aircraft be safely landed with no less than 25% of battery life remaining.

Safety Mitigation:

The FAA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of 

Exemption to Astraeus Aerial, Docket No. PAA-2014-0352. The Operations Manual 

conforms to this limit, providing an equivalent level of safety.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

The regulation provides that an airworthiness certificate, with the registration number 

assigned to the aircraft and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew."

At a maximum gross weight of less than 30 pounds, the UASs are too small to carry 

documentation, do not have an entrance, and are not capable of carrying passengers or 

crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose 

that documents deemed appropriate for this aircraft by the FAA will be co-located with 

the crew at the ground control station and available for inspection upon request. The FAA 

has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) Maintenance 

Required

Offshore Aviation LLC seeks an exemption from the maintenance inspection 

requirements contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) 

and (b). These regulations specify maintenance and inspection standards in reference to 

14 C.P.R. Part 43. See, e.g., 14 C.P.R. § 91.405(a) (stating that each owner or operator of 

an aircraft "[s]hall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections...have discrepancies repaired as prescribed in part 43 

of this chapter"). An exemption from these regulations is needed because Part 43 and 

these sections only apply to aircraft with an airworthiness certificate, which the UASs 

will not have.

Safety Mitigation

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the Operators Manual. As provided in the Operators 

Manual, flights will not be conducted unless a flight operations checklist is performed 

that includes all of the aircraft's components.
Appendix B – UAS manuals (see attached)

Appendix C

Standard Operating Procedures (SOP):

1. The unmanned aircraft systems (UASs) will weigh less than 30 pounds, including 

energy source(s) and equipment.

2. The UAS will not be flown at a ground speed exceeding 30 MPH.

3. Flights will 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 UAS will be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses.

5. All operations will utilize a Payload Operator (PO). The PO may be used to satisfy the 

VLOS requirement, when not using video goggles, as long as the PIC always maintains 

VLOS capability. The PO and PIC must be able to communicate verbally at all times.

6. Prior to each flight the PIC will 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

(GCS), if utilized, will be included in the preflight inspection. All maintenance,

alterations and software upgrades will be properly documented in the aircraft records.

7. If the UAS has undergone maintenance, alterations or software upgrades that affect the 

UAS operation or flight characteristics, e.g. replacement or upgrade of a flight critical 

component, the UAS will undergo a functional test flight in accordance with the 

operator’s manual. The PIC who conducts the functional test flight will make an entry in 

the UAS aircraft records of the flight. The requirements and procedures for a functional 

test flight and aircraft record entry will be added to the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance 

requirements will be established and identified in the operator’s manual. At a minimum, 

requirements for the following will be included in the operator’s manual:

a. Actuators / Servos;

b. Powerplant (motors);

c. Propellers;

d. Electronic speed controller;

e. Batteries;

f. Remote command and control;

g. Ground control station (if used); and

h. Any other components as determined by the operator;
9. The Pilot-In-Command (PIC) will have passed a FAA private pilot’s knowledge test 

and have a valid driver’s license. The PIC will also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate, if applicable.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR § 61.51(b), a minimum of 200 flight cycles or 25 hours of total time as a 

UAS pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multi-rotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted to accomplish the required flight cycles 

and flight time.

11. Prior to operations the PIC will have accumulated and logged, in a manner consistent 

with 14 CFR § 61.51(b), a minimum of five hours as UAS pilot operating the make and 

model of UAS to be utilized for operations and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing 

currency flights can be conducted to accomplish the required flight cycles and flight time.

12. The UAS may not be operated directly over any person, except authorized and 

consenting personnel, or below an altitude that is hazardous to persons or property on the 

surface in the event of a UAS failure or emergency.

13 The operator will ensure that no persons are allowed within 500 feet of the area except 

those consenting. This provision may be reduced if barriers or structures are present that 

can sufficiently protect nonparticipating persons from the UAS or debris in the event of 

an accident. 

14. The UAS PIC will abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual.

15. Each UAS operation will be completed within 60 minutes flight time or with 25% 

battery power remaining, whichever occurs first.

16. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations. This COA will also 

require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation.

17. All aircraft operated in accordance with regulations will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable.

18. Each UAS operated will comply with all manufacturer Safety Bulletins.

19. The radio frequency spectrum used for operation and control of the UAS will comply 

with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

20. At least three days before scheduled flight, the operator will submit a written Plan of 

Activities to the local FSDO with jurisdiction over the area of proposed flight area. The 

3-day notification may be waived with the concurrence of the FSDO. The plan of 

activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N-number of UAS to be used;
d. Name of UAS PIC involved

e. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the flight operations; the list of those who gave permission must 

be made available to the inspector upon request;

f. Signature of exemption-holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which flights will be conducted and the altitudes essential to 

accomplish the operation.

22. The documents required under 14 CFR §§ 91.9 and 91.203 will be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating.

23. The UAS will remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, hang gliders, etc.).

24. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. Special authorization may be 

requested for night operations by government agencies in emergency situations on a case 

by case basis.

25. The UAS will not be operated by the PIC from any moving device or vehicle.

26. The UAS will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from cloud.

27. The UAS will not operate in Class B, C, or D airspace without written approval from 

the FAA. The UAS may not operate within 5 nautical miles of the geographic center of a 

non-towered 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 as required by the operator’s COA. The letter 

of agreement with the airport management must be made available to the Administrator 

upon request.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA’s UAS Integration Office (AFS-80) within 24 hours.

Appendix D - Pilot Checklists, Briefing Guide (see attached)

Appendix E - UAS photos and specifications (see attached)