UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043

UAV-Assistance LLC

Attn: Michael Tranchitella

3181 Burgess Mill Way Unit D

Ellicott City, MD 21043

March 3, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 

61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & 

(b). Sections 44703 and 44711 of title 49

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, UAV-ASSISTANCE LLC (“the applicant”), solo 

developer and operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to 

conduct Airborne Photographic, Video, Inspection and Sensor Data Collection services, 

hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) 

to allow commercial operation of its sUASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

A special exemption from sections 44703 and 44711 of title 49 is also requested 

due to the applicant’s extensive specialized sUAS pilot training and experience.

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

operation of small, unmanned, and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 

4) would provide safety enhancements to the already safe operations in the filming, 

photographing and sensor data collection presently using conventional aircraft. 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.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 2

The name and address of the applicant is:

UAV-ASSISTANCE LLC

Attn: Michael Tranchitella

Ph: 301-752-7519

Email: uav-assistance@verizon.net.

3181 Burgess Mill Way Unit D Ellicott City, MD 21043.

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

Sections 44703 and 44711 of title 49

This exemption application is expressly submitted to fulfill Congress’ goal in 

passing Section 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 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’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 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
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 3

for the safe operation of such aircraft in the national airspace system.” Id. §333(c) 

(emphasis added).1

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, which includes sUASs, from the requirement that all 

civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) 

and 49 U.S. Code § 44703 See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

§91.203 (a) (1).

The applicant’s sUAS (Appendix 1) are Fixed Wing and Rotorcraft, weighing 55 or 

fewer lbs. including payload. They operate under normal conditions at a speed of no more 

than 15 to 35 knots and have the capability to hover and move in the vertical and 

horizontal plane simultaneously and move in the horizontal plane. They will operate only 

in line of sight and will operate only within the sterile area described in the Unmanned 

Aircraft Systems Operations Manual, attached as Appendix 2 (hereinafter “the Manual”). 

Such operations insure that the sUAS does “not create a hazard to users of the national 

airspace system or the public.”

2

Given the small size of the sUASs involved and the restricted sterile environment 

within which they will operate, the applicant 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. Also due 

to the size of the UASs and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. 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 UASs for Airborne 

Photographic, Video, Inspection and Sensor Data Collection services and , the granting of 

the requested exemptions is in the public interest. Accordingly, the applicant respectfully 

requests that the FAA grant the requested exemption without delay.

Background Information

The applicant is in the business of providing Airborne Photographic, Video, 

Inspection and Sensor Data Collection services. The applicant operates on a solo basis 

 

1

Applicant interprets this provision to place the 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.

2

Reform Act Section 333 (b).
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 4

and will be the only person piloting the aircraft although a trained observer will always 

be present. The applicant’s clients look to the applicant for safe operations of sUAS. The 

applicant has developed specific safe UAV operational procedures. Increasingly, the 

applicant has clients looking for sUAS services for Airborne Photographic, Video, 

Inspection and Sensor Data Collection services. The applicant’s knowledge, specialized 

training, and experience of sUAS and their operation is a benefit to the applicant’s clients 

and should be considered a valuable asset to the safe operation of sUASs.

Operations performed by the applicant include:

 Video and still photography 

 Three dimensional Mapping/Imaging

 Airborne Sensor Data Collection

 Utility Inspection

 Railroad Inspection

 Pipeline Inspection

 Oil-Field Inspection

 Petro/Chemical/Manufacturing Inspection

 Construction Site Inspection

 Agriculture Inspection

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

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

have the characteristics and that operate within 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 already safe Airborne Photographic, Video, Inspection and Sensor 

Data Collection services conducted with conventional aircraft.

The aircraft to be used are the DJI Inspire 1, DJI Inspire Pro + RAW, DJI Phantom 3, 

DJI Phantom 4, and Event38 E384.

These limitations and conditions to which the applicant agrees to be bound when 

conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 30 minutes (rotor 

craft) and 60 minutes (fixed wing). Flights will be terminated at 25% battery 

power reserve should that occur prior to the 30 minute (rotorcraft) and 60 minute

(fixed wing) limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more 

than 200 feet above an elevated platform from which flight is planned.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 5

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer.

6. The sUAS pilot-in-command (PIC) will have the following specific 

qualifications:

 Received FAA approved Private Pilot ground training and 

passed FAA approved testing that meets 14 CFR 61.105 -

Aeronautical knowledge.

 Possess a minimum of 14 years of professional sUAS piloting 

experience 

 Amassed a minimum of 1000 hours flying sUAS.

 Has acted as sUAS PIC under FAA granted Certificate Of 

Authorization/s.

 Has acted as sUAS PIC, ground crew, and observer instructor 

for FAA COAs and employer/customer sUAS.

 Has created sUAS flight and ground operations safety 

guidelines, documentation, and maintenance procedures for 

employer/customer sUAS.

 Has been approved and acted as a civilian sUAS PIC under the 

United States Department of Defense Test Range safety 

regulations for Aberdeen Test Center, White Sands Missile 

Range, Fort Pickett, Fort Hunter Liggett, Red Stone Arsenal, 

AFRL Eglin AFB,and Dugway Proving Grounds.

 Has operated a sUAS from a tower controlled international 

airport with full coordination of the Costa Rican Aviation 

authority for a NASA sponsored demonstration. 

 Has experience interacting with Air Traffic Control (ATC), 

Terminal Radar Approach Control Facilities (TRACON), 

Common traffic advisory frequency (CTAF) and Military 

Range Safety Control as sUAS PIC.

 Has acted as sUAS PIC under NATO and Italian Military UAS 

safety guidelines.

 Has piloted manned aircraft in a student capacity. 

 Possesses 20/20 vision 

 Has a valid driver’s license

 No medical condition/s which could affect sUAS flight 

performance.

 Have of experience with military and commercial sUAS 

program management, design, construction, and production. 

Including (4) commercially available sUAS professional 

products.

 Has been granted United States Department of Defense 

security clearance/s.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 6

 Will strictly adhere to the applicant’s sUAS Operating Manual 

(see attached)

7. If a sUAS pilot other than the PIC described in item 6, who is a Pilot Certificate 

Holder and meets the sUAS PIC qualifications including knowledge of the 

applicant’s operation’s manual, is also present on site, that person can also be 

designated as PIC.

8. The sUAS will only operate within defined boundaries as outlined in Section 8.4

of the Manual.

9. A briefing will be conducted in regard to the planned sUAS operations prior to 

each mission. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be present for this briefing.

10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light 

of the requested exemption, with the appropriate Flight Standards District Office

(FSDO).

11. The operator will obtain the consent of all persons involved in the mission and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and this radius may be reduced to 30 feet based upon an equivalent 

level of safety determination, as required by Section 8.4 of the Manual. With the 

advanced permission of the relevant FSDO, operations at closer range can be 

approved.

12. The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed mission as required in Section 8.1 of the Manual. Items will 

include:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS mission conducted 

under this petition of exemption;

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

d. Name and certificate number of UAS PICs involved in the mission;

e. A statement that the operator has obtained permission from property

owners and/or local officials to conduct the mission;

f. The list of those who gave permission made available to the inspector

upon request;

g. Signature of exemption-holder or representative; and

h. A description of the flight activity, including maps or diagrams of any 

area, city, town, county, and/or state over which the mission will be

conducted and the altitudes essential to accomplish the operation.

13. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as required 

in Sections 7.4 and 7.5 of the Manual.

14. Observer and pilot will at all times be able to communicate by voice.

15. Written and/or oral permission from the relevant property holders will be 

obtained.

16. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 7

17. If the sUAS loses communications or loses its GPS signal, the UAS will have the

capability to return to a pre-determined location within the Security Perimeter and

land.

18. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 

(a) (1). Given the size and limited operating area associated with the aircraft to be utilized 

by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, 

and operates exclusively within a secured area as set out in the Manual. Unlike other civil 

aircraft, operations under this exemption will be tightly controlled and monitored by both 

the operator and observer, pursuant to the Manual’s policies, and under and in 

compliance with local public safety requirements, to provide security for the area of 

operation as is now done with conventional Airborne Photographic, Video, Inspection 

and Sensor Data Collection services. The FAA will have advance notice of all operations. 

These safety enhancements, which already apply to civil aircraft operated in connection 

with Airborne Photographic, Video, Inspection and Sensor Data Collection services, 

provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location 

of operation, lack of explosive materials or flammable liquid fuels, and inability to carry

a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft 

or experimental or provisionally certificated aircraft, the operator must 
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 8

also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, 

the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the 

word “Experimental” can be placed. Given the size of the sUAV, two-inch lettering will 

be impossible. The word “Experimental” will be placed on the fuselage in compliance 

with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAV will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A.

Sections 44703 and 44711 of Title 49 of the United States Code (49 USC): Airman 

Certificate Requirements

Pilot certification requirements for petitions for exemption under Section 333 are 

evaluated on a case-by-case basis. There are no standards for either Private or 

Commercial sUAS pilot certificates. The safe operation and control of the sUAS/s as 

described in this application does not depend on the type of FAA license held by the PIC. 

Given the restricted and controlled airspace within which operations will take place, the 

key factors needed by the PIC are knowledge of the airspace within which the operation 

will take place and how that airspace fits into the National Airspace System (NAS). That 

knowledge can be and is gained primarily through ground school and not through flight 

training in fixed wing or rotor aircraft, nor is it dependent on the acquisition of a 

commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the 

factors and skills needed for the safe operation of those types of aircraft (fixed wing or 

rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter 

or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial 

vehicle, operating at 400 AGL or lower, within strictly controlled pre-approved airspace. 

Besides knowledge of airspace regulations, dexterity in the control and operation of the 

sUAS acquired from actual operation of the aircraft is the most important factor in 

establishing an equivalent level of safety. If the PIC has acquired the necessary 

knowledge of airspace requirements, the relevant issues are (1) where the aircraft will be 

flown, (2) the size of the aircraft relative to what is being used today to accomplish the 

same mission, and (3) what precautions will be taken to ensure the safety of those in the 

area of operation. 
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 9

For the safe operation of the sUAS described in this document the applicant proposes that

the PIC meet the following qualifications:

 Received FAA approved Private Pilot ground training and passed FAA 

approved testing that meets 14 CFR 61.105 - Aeronautical knowledge.

 Possess a minimum of 14 years of professional sUAS piloting experience 

 Amassed a minimum of 1000 hours flying sUAS.

 Has acted as sUAS PIC under FAA granted Certificate Of Authorizations.

 Has acted as sUAS PIC, ground crew, and observer instructor for FAA 

COAs and employer/customer sUAS.

 Has created sUAS flight and ground operations safety guidelines, 

documentation, and maintenance procedures for employer/customer 

sUAS.

 Has been approved and acted as a civilian sUAS PIC under the United 

States Department of Defense Test Range safety regulations for Aberdeen 

Test Center, White Sands Missile Range, Fort Pickett, Fort Hunter 

Liggett, Red Stone Arsenal, AFRL Eglin AFB,and Dugway Proving 

Grounds.

 Has operated a sUAS from a tower controlled international airport with 

full coordination of the Costa Rican Aviation authority for a NASA 

sponsored demonstration. 

 Has experience interacting with Air Traffic Control (ATC), Terminal 

Radar Approach Control Facilities (TRACON), Common traffic advisory 

frequency (CTAF) and Military Range Safety Control as sUAS PIC.

 Has acted as sUAS PIC under NATO and Italian Military UAS safety 

guidelines.

 Has piloted manned aircraft in a student capacity. 

 Possesses 20/20 vision 

 Has a valid driver’s license

 No medical condition/s which could affect sUAS flight performance.

 Have of experience with military and commercial sUAS program 

management, design, construction, and production. Including (4) 

commercially available sUAS professional products.

 Has been granted prior United States Department of Defense security 

clearance/s.

 Will strictly adhere to the applicant’s sUAS Operating Manual (see 

attached)

Should there be a mishap, the sUAS being flown pose significantly less of a threat than 

the helicopters and fixed wing aircraft now being employed because they are a fraction of 

the size, carry no flammable fuel, do not carry crew or passengers, and pose an 

infinitesimal risk to others. This is in stark contrast to conventional aircraft that are flown 

to the site, carry explosive fuel, carry passengers and crew, and operate in a much larger 

area. From a practical standpoint, there are relatively few licensed (Private, Sport) aircraft 

pilots who are also qualified to fly the type of sUAS that are utilized for Airborne 
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 10

Photographic, Video, Inspection and Sensor Data Collection operations. There are even 

fewer commercial pilots that can fly these sUAS – to the point that to do both is 

considered rare. Assuming that it is unlikely for a company to find a pilot that has both 

qualifications, that company would either have to source a qualified sUAS pilot to train 

and obtain a commercial or private certificate, or find a commercial certificated pilot who 

would be willing to learn to fly a sUAS to the competency level required for professional 

use. Based on the size and income of the applicant’s business, the requirement of an 

Airman’s certificate or the hiring of a person possessing an airman’s certificate is cost 

prohibitive and, as described above does not increase safety when compared to the 

proposed sUAS PIC qualifications. 

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

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by the applicant operating the aircraft 

based on the proposed sUAS PIC qualifications. This information is described above in 

the section titled “AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY” item 6 and 

in the section titled “SECTIONS 44703 AND 44711 OF TITLE 49 OF THE UNITED 

STATES CODE (49 USC): AIRMAN CERTIFICATE REQUIREMENTS”. Unlike a

conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the 

Manual. The level of safety provided by the requirements included in the Manual exceeds 

that provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the operation of the sUAS are so 

diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the sUAS as requested by the applicant

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

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

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

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the Manual 

for maintenance and use of safety checklists prior to each flight, as set forth in Sections 

9.1 and 9.6, an equivalent level of safety will be provided.

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

Section 91.9 (b) (2) provides:
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 11

No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane 

or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because 

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

The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft, an exemption will be needed. An equivalent level of safety will 

be provided as set forth in Sections 8 and 9 of the Manual. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances,

and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction

Section 91.103 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.

sUASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 

9862A. The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft.

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, or 

not more than 200 above an elevated platform from which operation is planned, an 
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 12

exemption may be needed to allow such operations. As set forth herein, except for the 

limited conditions stated in the Manual, the UAS will never operate at higher than 400 

AGL. It will, however, be operated in a restricted area with a security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained 

consent.

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 or local officials. Because of the advance notice to 

the property owner and participants in the mission, all affected individuals will be aware 

of the planned flight operations as set forth in Section 6.2, 8.1, and 8.2 of the Manual. 

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

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

these operations is far less than those presently presented with conventional aircraft 

operating at or below 500 AGL in the Airborne Photographic, Video, Inspection and 

Sensor Data Collection services capacity. In addition, the low-altitude operations of the 

sUAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119.

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 sUAS may not 

have a barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and safety checklist, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

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.”

The battery powering the sUAS provides approximately 30 minutes (rotorcraft) 

and 60 minutes (fixed wing) of powered flight. To meet the 30-minute reserve 

requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10

minutes (rotorcraft) and 30 minutes (fixed wing) in length. Given the limitations on the 

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

predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 13

Applicant 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. Additionally, limiting sUAS flights 

based on 30 minutes reserve would greatly reduce the utility for which the exemption will 

be granted.

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

flights to 20 minutes (rotorcraft) and 60 minutes (fixed wing) or 25% of 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, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to them, 

to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 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 
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 14

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 applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and operating handbook as 

referenced in the Manual (See Sections 8.6 and 9). 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 restricted 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 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 is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

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:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

(b);91.7 (a); 91.9 (b) (2);91.103(b);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); 91.409 (a) (2) and 91.417 (a) & 

(b) to operate commercially a small unmanned vehicle (55lbs or less) in motion 

picture and television operations.

Approval of exemptions allowing commercial operations of sUASs in the 

Airborne Photographic, Video, Inspection and Sensor Data Collection services and will 

enhance safety by reducing risk. Conventional Airborne Photographic, Video, Inspection 

and Sensor Data Collection services, using jet or piston power aircraft, operate at 

extremely low altitudes just feet from the infrastructure being inspected and in extreme 

proximity to people and structures; and present the risks associated with vehicles that 

weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. 

Such aircraft must fly to and from the work location. In contrast, a sUAS 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 sUAS is carried to the 

worksite and not flown. The sUAS will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights.
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 15

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

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

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people.

Privacy

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

prior consent and knowledge. Airborne Photographic, Video, Inspection and Sensor Data 

Collection services will be performed for people who have also consented for work to be 

performed or otherwise have agreed to be in the area where UAS flight will take place.

Conclusion

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 

applicant’s UAS in the Airborne Photographic, Video, Inspection and Sensor Data 

Collection services and capacity pursuant to the Manual appended hereto.

Sincerely,

Michael Tranchitella

CEO UAV-Assistance LLC
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 i

Appendix 1

1.1 – DJI Inspire 1 

Due to their file size, all Manuals and all technical information can be found at:

http://www.dji.com/product/inspire-1/download

1.2 – DJI Inspire 1 Pro and RAW

Due to their file size, all Manuals and all technical information can be found at:

http://www.dji.com/product/inspire-1-pro-and-raw/info#downloads

1.3 – DJI Phantom 3 and 4

Due to their file size, all Manuals and all technical information can be found at:

http://www.dji.com/product/phantom-3-pro/info#downloads

http://www.dji.com/product/phantom-4/info#downloads
UAV-Assistance LLC / Michael Tranchitella 3181 Burgess Mill Way Unit D Ellicott City, MD 21043 ii

1.4 – Event38 E384 

See Attached Flight Manual: 

E384 Manual

Appendix 2

Please see the attached:

sUAS Operating Manual

sUAS Pre-Flight Safety Checklist