UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Section 333 Exemption Petition for: 

MANTIS, LLC

For a petition seeking relief from the requirements of

Title 14 of the following Sections of the Code of Federal Regulations:

14 CFR Part 21 - 14 CFR 45.23(b) - 14 CFR 61.113(a) & (b) - 14 CFR 91.7(a) - 14 

CFR 91.9(b)(2) - 14 CFR 91.103 - 14 CFR 91.109 - 14 CFR 91.119 - 14 CFR 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) and 14 CFR 417(a) & (b)

Concerning Commercial Operation of sUAS listed in Appendix A

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

Submitted on February 16, 2016

By: Christian Rath, Co-Founder Mantis, LLC

Tel: (219) 671-5450 Email: chrath61@gmail.com
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Table of Content

Page 

 Abbreviations: ........................................................................................................3

 Summary:.................................................................................................................4

 Contact information of Petitioner: ......................................................................5

 Regulations from which the exemption is requested: ......................................5

 Authority for exemption: .......................................................................................5

 Introduction of petitioner:.....................................................................................6

 sUAS and Operational Description:.....................................................................6

 Description of Specific Regulations:..................................................................11

 Public interest: ......................................................................................................15

 Equivalent level of safety:...................................................................................15

 National Security:.................................................................................................16

 Federal Register Summary:.................................................................................16

 Petition:..................................................................................................................16

 Appendix A:..........................................................................................................17
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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 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

UASs Unmanned Aircraft Systems

VFR Visual Flight Rules 

VLOS Visual Line of Sight 

VMC Visual Meteorological Conditions 

VO Visual Observer 

VTOL Vertical Takeoff and Landing 

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

referred to as the Reform Act) and 14 CFR Part 11, Mantis, LLC (herein referred to 

as the "Petitioner") hereby applies for an exemption from the be Federal Aviation 

Regulations (FARs) listed on the cover page to allow commercial operation of 

Mantis for the purpose of aerial data collection.

Aerial data collection will include any remote sensing and measuring by 

instrument(s) aboard the UAS. This includes, for example, imagery 

(photography, video, infrared, etc.), electronic measurement (precision 

surveying, RF analysis, etc.), chemical measurement (particulate measurement, 

etc.), or any other gathering of data by instruments aboard the UAS. All such 

operations will be conducted within and under the conditions outlined herein or 

as may be established by the FAA.

The FAA has issued grants of exemption in circumstances similar in all material 

respects to those presented in this petition. 

See following Grants of Exemption:

 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 

 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), 

 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), 

 12646 to Measure, LLC (see Docket No. FAA−2015−1602). 

Each of the UAS platforms listed in the attached Appendix A has been previously 

approved by the FAA for commercial operations in the United States. Using an 

UAS with the specifications described by the petitioner and carrying no 

passengers or crew -- rather than a manned aircraft of significantly greater 

proportions, carrying crew in addition to flammable fuel -- gives the FAA good 

cause to find that the UAS operation sought by this petition is in the public 

interest.

Approval of this exemption would enhance safety and fulfill the Secretary of 

Transportation's responsibilities to "...establish requirements for the safe operation 

of such aircraft systems in the national airspace system." Section 333(c), Reform 

Act.
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Name, address and other contact information for the Petitioner:

Mantis, LLC

1112 US-41

Suite 201

Schererville, IN 46375

Point of Contact:

Christian Rath, 

9920 Mathews Street

Crown Point, IN 46307

Tel: (219) 671-5450 

Email: chrath61@gmail.com

Regulations from which the exemption is requested:

 14 CFR Part 21

 14 CFR 45.23(b)

 14 CFR 61.113(a) & (b)

 14 CFR 91.7(a)

 14 CFR 91.9(b)(2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119

 14 CFR 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)

Authority for Exemption

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

This statutory authority includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, including UAS, 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 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR 

91.203(a)(1). 
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Section 333(b) of the Reform Act assists the Secretary in determining whether UAS 

may operate in the national airspace system without creating a hazard to the 

user, the public, or a threat to national security. In making this determination, 

the Secretary must consider:

 The UAS' size, weight, speed and operational capability;

 Whether the UAS operates within the visual line of sight of the operator;

 Whether the UAS operates outside of highly populated areas and away 

from close proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS "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).

Introduction of Petitioner 

Mantis, LLC is a business dedicated to providing professional services hinged on 

aerial data collection provided by any remote sensor and measures by 

instrument(s) aboard the UAS. This includes, for example, imagery 

(photography, video, infrared, etc.), electronic measurement (precision 

surveying, RF analysis, etc.), chemical measurement (particulate measurement, 

etc.), or any other gathering of data by instruments aboard the UAS. While the 

main space is structures’ inspection, data collection also include conducting

aerial photography, videography, infrastructure inspections, surveying, precision 

agriculture, mapping and other flight operations that could be performed safely 

and more cost effectively than a traditional manned aircraft within the United 

States.

Mantis, LLC is staffed with an experienced team of professionals with engineering 

and aviation background. Christian Rath, the company co-founder and CEO 

holds a P.E. license and a Private Pilot License with multi endorsements in single 

engine airplanes. Jim Moore has a 15+ experience in the real estate space 

combined with 10+ year experience in RC off-road racing cars models. Sandro 

Berchiolli holds a P.E. License and brings a 20+ year experience in conditioning 

monitoring, and Simone Berchiolli brings20+ year experience in professional 

services in the loss adjusting space.

sUAS and Operational Description

The Petitioner seeks to commercially operate a variety of sUAS weighing less than 

55 pounds including payload in the United States for the purpose of acquiring 

aerial data. Appendix A, attached to this exemption petition, lists the aircrafts

that the Petitioner contemplates operating. In prior similar exemptions the 
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Secretary has approved every sUAS platform included in the above mentioned 

Appendix. 

As the operator of these aircrafts, the Petitioner is committed to the following 

conditions and limitations on its operations. It understands that failure to comply 

will be grounds for the immediate suspension or rescission of any exemption 

granted. 

1. The UAS weighs 55 pounds or less.

2. Operations for the purpose of closed-set motion picture and television 

filming are not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per 

hour). The exemption holder may use either groundspeed or calibrated 

airspeed to determine compliance with the 87 knot speed restriction. In no 

case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL. 

5. The UA must 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, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate 

verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct 

its operations in accordance with the conditions and limitations stated in this 

grant of exemption, are hereinafter referred to as the operating documents. 

The operating documents must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and 

limitations herein take precedence and must be followed. Otherwise, the 
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operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator or any law enforcement official 

upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The 

FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise 

regarding updates or revisions to the operating documents. 

8. 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 prior to conducting further 

operations under this exemption. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight must be conducted in such a manner so as 

to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation.

10.Prior to each flight, the PIC must conduct a pre-flight inspection and 

determine the UAS is in a condition for safe flight. The pre-flight inspection 

must account for all potential discrepancies, e.g., non-operable 

components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12.Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13.Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also 

hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight 

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

14. The operator may not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles, and structures. PIC qualification flight hours and 

currency must be logged in a manner consistent with 14CFR §61.51(b). 

Flights for the purposes of training the operator’s PICs and VOs (training, 

proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption are permitted under the terms of this 

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14CFR 

§91.119.

15.UAS operations may not be conducted during night, as defined in 14CFR 

§1.1. All operations must be conducted under visual meteorological 

conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as 

denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator 

or any law enforcement official upon request.

17. 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 

PIC.

18.For tethered UAS operations, the tether line must have colored pennants or 

streamers attached at not more than 50 foot intervals beginning at 150 feet 

above the surface of the earth and visible from at least one mile. This 

requirement for pennants or streamers is not applicable when operating 

exclusively below the top of and within 250 feet of any structure, so long as 

the UA operation does not obscure the lighting of the structure.
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19.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.

20. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies.

21. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA to 

conduct the intended operation and to operate after that for at least 5 

minutes or with the reserve power recommended by the manufacturer if 

greater.

22.Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). 

All operations shall be conducted in accordance with an ATO-issued COA. 

The exemption holder may apply for a new or amended COA if it intends to 

conduct operations that cannot be conducted under the terms of the 

enclosed COA.

23.All aircraft operated in accordance with this 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.

24.Documents used by the operator to ensure the safe operation and flight of 

the UAS and any documents required under 14 CFR §§91.9 and 91.203 must 

be available to the PIC 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.

25. The UA must remain clear and give way to all manned aviation operations 

and activities at all times.

26. The UAS may not be operated by the PIC from any moving device or 

vehicle.

27.All 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 the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and 
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are within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles, or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. The PIC, VO, operator 

trainees or essential persons are not considered nonparticipating persons 

under this exemption.

28.All operations shall be conducted over private or controlled-access property 

with permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

29.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.

Description of Specific Regulations

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203(a)(l). Given the size and 

limited operating area associated with the aircraft to be utilized by the Petitioner, 

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 USC §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 operating 

with an airworthiness certificate without the restrictions and conditions proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, 

or light- sport category aircraft to be marked with letters between 2 inches and 6 

inches high "limited", "restricted," "light-sport," "experimental," or "provisional," near 

each entrance to a cabin, cockpit or pilot station. Even though the UAS will 

have no airworthiness certificate, an exemption may be needed as the UAS will 
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have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the UAS, 2-inch lettering may 

be impossible. The Petitioner will mark the UAS as practicable.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (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 requiring the 

pilot operating the aircraft to have completed a UAS flight-training course. 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is 

remotely controlled. The area of operation is controlled and restricted, and all 

flights are planned and coordinated in advance. The risks associated with the 

operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing 

operations of the UAS as requested exceeds the present level of safety achieved 

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

14 CFR 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 the Petitioner contemplates operating, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the operational restrictions put on the aircraft, 

an equivalent level of safety will be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The UAS, 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 Operating Manuals 

at the ground control point where the pilot flying the UAS will have immediate 

access to it.

14 CFR 91.103: Preflight action

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

to ensure the safety of flight. An exemption is needed from this requirement, as 

the pilot will take separate preflight actions, including checking for weather 

conditions, checking flight battery or fuel requirements, checking takeoff and 

landing distances, and all other actions in the Operating Manual and safety 

checklists. These actions will provide an equivalent level of safety.

14 CFR 91.109: Flight instruction
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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. By design, UAS 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 equivalent 

level of safety is provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft, the ability to control the UAS via radio signals from the 

controller and by the size and speed of the aircraft.

14 CFR 91.119: Minimum safe altitudes

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

will never operate at altitude higher than 400 AGL and all operations will occur 

during daylight hours under Visual Meteorological Conditions (VMC) only.

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. Because advance notice to the 

property owner and any onsite personnel, as well as the precautions outlined 

below, all affected individuals will be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating 

persons (persons other than the pilot in command (PIC) or visual observer (VO)), 

vessels, vehicles and structures, unless operations do not present an undue 

hazard.

The UAS will remain within visual line of sight of the PIC or VO. Flight operations 

will be conducted at least 5 miles from an airport. The PIC or VO will provide 

notification to the local Flight Standards District Office and airport controller of all 

operations within 5 miles of an airport. The FAA will have advance notice of all 

operations through the filing of notices-to-airmen.

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

the UAS proposed herein, any risk associated with our operations is far less than 

those presently presented with helicopters and other conventional aircraft 

operating at or below 500 feet AGL. In addition, the low-altitude operations of 

the UAS will ensure separation between these UAS operations and the operations 

of conventional aircraft that must comply with Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the 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 UAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety 
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will be achieved by the PIC confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR 

conditions. Relief from Section 91.151(a)(1) is requested to the extent required 

to allow flights of a variety of UAS during daylight hours in visual flight rules (VFR) 

conditions to continue until 90 percent of remaining battery power or fuel 

reserves remain. The Petitioner seeks the requested relief because without an 

exemption from Section 91.151(a)(1), the flight time duration of the selected 

aircraft will be reduced and severely constrain the practicality of any aerial 

acquisition of data that it proposes to conduct pursuant to this Petition.

The technical specifications of the proposed UAS, their Operations Manuals, and 

the Petitioner's proposed operating limitations, ensure that it will safely operate 

the selected aircraft during daylight hours in VFR conditions until 90 percent of 

remaining battery power or fuel reserves remain.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an 

onboard pilot. Therefore, there is no ability or place to carry certification and 

registration documents or to display them on the UAS. An equivalent level of 

safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will have immediate access to them, to the extent 

they are applicable to the UAS.

14 CFR 91.405(a); 407(a)(l); 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 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 pursuant to the User Guide or Operating Manual. An equivalent 

level of safety will be achieved because these UASs are 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. The PIC 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 PIC is the person most 
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familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety.

Public Interest. 

Approval of exemptions allowing commercial operations of UASs for aerial 

acquisition of data enhances safety while reducing risk. Manned aircraft in 

certain application such as pipeline monitoring create a greater risk because the 

aircraft are much larger and carry an onboard human pilot. In contrast, a UAS 

weighing 55 pounds or less will carry no passengers or crew and, therefore, will 

not expose them to the risks associated with manned aircraft flights. In addition, 

streams of aerial data will allow large commercial entities to make decisions 

about how to best deploy ground resources and ensure the safety and 

cost-effectiveness of their operations. Finally, the use of UAS for public safety, 

search and rescue and disaster response purposes can reduce costs and 

increase capabilities of public services. 

Equivalent level of Safety. 

The Petitioner 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 and proposed regulatory structure.

The equivalent level of safety established by Section 91.121 will be maintained 

because all the UAS Mantis, LLC proposes to operate are equipped with a 

digitally encoded barometric altimeter and GPS triangulation equipment, with a 

zero altitude initiation point being established prior to each flight. As such, the PIC 

on the UAS is provided the altitude of the UA above ground level (AGL) via a 

heads-up display of the ground control station (GCS

Additionally, the FAA has previously granted relief from Section 91.7(a), specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138). In seeking this exemption, Mantis, LLC submits that an 

equivalent level of safety with regard to the regulatory maintenance and 

alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a) (2), And 91.417(a) & (b) will be met because Mantis, LLC and 

the manufacturers of each aircraft, will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the manufacturer’s 

maintenance manual. Furthermore, Mantis LLC will document and maintain all 

maintenance records for each of the individual aircraft. 
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National Security

Given the small size of the UAS involved and the restricted environment within 

which they will operate, our petition presents no national security issue.

Federal Register Summary. 

Docket No.: No. FAA-2016-______________

Petitioner: Mantis, LLC

Part 21 and§§ 45.23(b), 61.113(a) and (b), 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), 407(a)(1), 409(a)(2), 

417(a) and (b) of Title 14, Code of the Federal Regulations (14 CFR

Description of Relief Sought: The Petitioner is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems.

Petition

Based upon the foregoing, the Petitioner requests that the FAA grant it the 

necessary exemptions under Section 333 of the FAA Reform Act as requested 

herein to allow for commercial operations of UAS within the United States.

Dated: February 16, 2016

Respectfully submitted, 

___________________________

Mantis, LLC

Christian Rath

Co-Founder and CEO

Attachments: Appendix A
Mantis, LLC – petition for FAA 333 Exemption 2016

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Appendix A

Brand & Model

1. 3D Robotics Aero-M

2. 3D Robotics Iris

3. 3D Robotics Iris+

4. 3D Robotics X8

5. 3DRobotics Fixed Wing

6. 3DRobotics Multirotor

7. 3DRobotics Quadrotor

8. 3DR Solo

9. 3DR Spektre

10. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

11. 3D Robotics Solo

12. 3DRobotics X8+

13. 3D Robotics X8-M

14. 3D Robotics Y6

15. Aerial Mob Heavy Lifter

16. Aerial Mob Light Lifter

17. Aerial Remote Mineral Detection System (ARMDS)

18. Aerialtronics Zenith with intergrated Airware system

19. Aerialtronics Altura Zenith ATX8

20. Aerigon

21. Aerobo

22. AeroCine Kopterworx Hammer X12

23. Aeromao AeroMapper 300

24. Aeromao Talon

25. Aeromao Aeromapper 300

26. Aeromao Aeromapper EV-2

27. AeroVironment Shrike

28. AeroVironment Puma

29. Aeronavics X4 Titanium

30. Aeryon Sky Ranger

31. Aervonics Sky Jib frame with a DJI A2 flight system

32. Aero-M

33. Aeryon Scout

34. Aeryon SkyRanger

35. AgEagle

36. AgEagle Robotic

37. AgScout

38. AgScout Mini

39. Agribotix Hornet Drone
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

40. Agribotix Enduro Quad

41. AgriView VK Ranger EX

42. Aibot

43. Aibotix X-6

44. Air Rover R-3000

45. AirCover QR-425s

46. AirRobot AR 180

47. AirRobot AR 100

48. AirRobot AR200

49. Air-X

50. Align M690

51. Altavian Nova

52. Altavian Nova F6500

53. Altavian Nova R8400

54. Altus X-4

55. Altus X-8

56. American Drones, LLC Eagle

57. Apprentice

58. Arch Aerial OCTO multi-rotor UAS

59. Arris hexacoper

60. AR-960 Hex Rotor

61. AR-540 Quad Rotor

62. ARF-MikroKopter OktoXL

63. ARF-MikroKopter OktoXL +

64. ArrowLite

65. AscTec Falcon

66. AscTec Falcon 8

67. Astraeus Aerial Cinema System V.3CS

68. Atlantic RC Aircraft LC04

69. Auburn Trimble UX5

70. Auburn War Eagle

71. Auburn EasyStar

72. Auburn

73. AV44

74. Bixler 3DR Plane

75. Blade 350QX

76. Bixler 2

77. Boomerang Carbon Fiber Frame (The Identified System)

78. Bormatec Maja UAV

79. BOSH Technologies Super Swiper

80. Bumblebee-S

81. C-Astral Bramor gEO
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

82. CarbonCore Octocopter 1000

83. Carbon Core Cortex Quadcopter

84. CCOw/WkmM

85. Chameleon Pro

86. CinesStar

87. Cinestar 6

88. Cinestar X8

89. Cinestar 8

90. Cinestar 8 HL

91. Cinestar 8 Okto XL

92. Coaxial Quad Multirotor VA01-V1

93. Coaxial Quad Multirotor VA02-V2

94. CopelandRED LLC Delta Wing Aircraft

95. CyberQuad Maxi

96. DJI Flame Wheel F450

97. DJI Flame Wheel F550

98. DAx8

99. DJI Inspire

100. DJI Inspire 1

101. DJI Inspire 2

102. DJIM P330z

103. DJIPhantom

104. DJI Phantom 1

105. DJI Phantom 2

106. DJI Phantom 2+

107. DJI Phantom 2 Vision

108. DJI Phantom 2 Vision+

109. DJI Phantom Vision +

110. DJI Phantom 3

111. DJI Phantom FC40

112. DJI Spreading Wings S900

113. DJI Spreading Wings S1000

114. DJI Spreading Wings S1000+

115. DJI S800

116. DJI S800 EVO

117. DJI T600

118. Draganflyer Guardian

119. Draganflyer X4ES

120. Draganflyer X4P

121. Draganflyer X6

122. DT-18

123. DYS D800-X8
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

124. Eagle VTOL

125. Eagle V2

126. E-Flite Apprentice

127. Event 38 E384

128. F-450

129. Falcon VTOL

130. Fire Fly 6

131. First Aerial Responder UAV

132. Flame Wheel G4 7.8 Skycrane

133. Flying-Cam 3.0 SARAH

134. Foxtech Kraken 130 V2

135. FreeFly Systems ALTA RTF

136. FreeFly Systems Octocopter Airframe (Legacy)

137. G4

138. G4 models

139. GeoStar

140. GerMAP G220

141. GerMAP G180

142. goFarm GF-1

143. Gryphon Dynamics X8

144. GT80X

145. Harris 18 HL

146. HEFF

147. Helicopters West DJI Inspire

148. Helicopters West SkyJib 8

149. Helios 960

150. Hawkeye Mk-III

151. HexaCrafter HC-1100 85.

152. HexaCrafter H0-1250

153. HH Blade 350QX2 AP

154. Hobbyking "Bixler" Fixed Wing Trainer

155. HoneyComb AgDrone

156. Horizon Hobby Blade 350 Qx2 quadcopter

157. Hoverfly LiveSky, BigSky 60 and H-Frame

158. Hubsan X4 micro drone

159. HVP 14301 Multi Rotor

160. Identified System

161. IMT Global xFold Cinema

162. Indago

163. InovalDrone:Inova One

164. InstantEye Mk-2

165. InstantEye Mk-2 Gen2
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

166. Intuitive Aerial Aeragon

167. K130 Octocopter

168. KongCopter X8

169. Kopterworx Hammer X12

170. Latitude HQ-4 Hybrid Multirotor

171. LB700

172. Leading Edge Precision Vision 10

173. Leptron Avenger

174. Lewis Realty Associates Hexacopter 650

175. Liberty 1

176. Lockheed Martin Desert Hawk III

177. Lockheed Martin Indago

178. Matrix quad copter

179. MaxFlight

180. MD4-200

181. MD4-1000

182. Mikrokopter 2.5

183. MLB Company Super Bat

184. MU-1H

185. Multirotor G4 7.8 Skycrane

186. Nighthawk

187. Nighthawk VTOL

188. OktoXL 6S12

189. PAGX4

190. Parksone Radian RTF

191. Parrot Bebop drone

192. Parrot PF 725100 Bebop Drone 14MP

193. Parrot Skycontroller

194. Patriot X4

195. Patriot X8

196. Finwing Penguin V2

197. Birdseyeview FireFly 6

198. Phoenix

199. Phoenix VTOL

200. Phoenix 60

201. Phoenix 60LE

202. Pixhawk

203. Precision Drone Pacesetter

204. PrecisionHawk

205. PrecisionHawk Hawkeye Mk-III

206. PrecisionHawk Lancaster

207. Precision Lancaster MK3
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

208. Prioria Hex

209. Prioria's Maveric

210. Pulse Aerospace, PA 01 Vapor

211. Pulse Aerospace Pulse Vapor 35

212. Pulse Vapor

213. PumaAEDDL

214. PV 14817 Multi Rotor

215. PVHLI

216. PVHL2

217. Q1

218. Quadcopter LLC MikroKopter

219. Quiet UAV

220. Qube

221. RIC Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & Octo 

Heavy Lift Prof. Multi Rotor

222. Frame Ronin Edition Microdrones:MD4-1000

223. RCTimer Hexacopter

224. RDASS

225. REHawk 500

226. REHawk 680

227. RF-70

228. Riegl RiCopter

229. RITEWING Z3 Spade 47"

230. Ritewing Drake 60"

231. RITEWING Z3 Spade 70"

232. RITEWING Z4 Spade 52"

233. RMAX

234. Roboflight

235. Rotomotion SR-15

236. RV Jet

237. Scout X4

238. SD02

239. Seahawk 1.2

240. SelectTech Geospacial's EH-4

241. SenseFly eBee

242. SenseFly eBee RTK

243. SenseFly eXom

244. Sensurion Magpie MP-1

245. Service-Drone Recon One

246. Service-Drone Blackbird

247. SH 900

248. ShadowHawk
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

249. Shrike

250. Sirius

251. SkyCatch

252. SkyJib 8 v.2 Heavy Lifter

253. SkyPhilly MI

254. Skywalker Aero

255. Skywalker Flying Wing X8

256. SnapRoll Media SUAS

257. Solutions Phoenix 30

258. SteadiDrone

259. Steadidrone Quad

260. Steadydrone QU4D

261. Steadidrone Mavik

262. SuperX/P2 Multirotor

263. Swift Radioplanes Lynx

264. Tali 500

265. Talon 120LE

266. Tarot FY690S Hexacopter

267. Tarot quadcopter

268. Tarot 680pro

269. Tarot 690

270. Tarot 900

271. Tarot 960

272. Tarot T-15

273. Tarot T15 C/F Folding Octocopter

274. Tarot T18 UAV

275. Tarot T690

276. Tarot T810

277. Tarot T960

278. Tarsier Systems MoAC

279. Tayzu Robotics Titan X8

280. TBS Discovery Pro

281. Team Black Sheep Discovery Pro Tarot T15

282. T-Rex 700E F3C

283. TREX 800E DFC PRO

284. Trimble UX5

285. Trimble UX5 hp

286. Trimble ZX5

287. Turningy Talon 500

288. TUP X8-800

289. Turbo Ace CINEWING 6

290. TurboAce Matrix-G quadcopter
Mantis, LLC – petition for FAA 333 Exemption 2016

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Brand & Model

291. Turbo Ace matrix-E

292. Turbo Ace MATRIX-1

293. UAV Solutions Phoenix 60

294. Universeye Penguin

295. Unmanned Flying Rolling Orb "UFRO"

296. US2 GreenHawk

297. UtiliCopter ITX8

298. VA03-v1

299. VA04-v1

300. VA07-v1

301. Viking UAS Multicopter (VTOL)

302. Viking UAS FF-X4/X8

303. VK-Patriot X4/X8

304. Viking UAS Patriot X4/X8 Multirotor

305. Viking UAS X6 Model 800

306. Viking UAS Viking ONE

307. VK-450

308. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

309. Viking VK-FF-X4

310. VK- Ranger EX- SAR Fixed Wing UAS

311. VolantexRaptorTarotT-18

312. Volt Aerial Robotics Octane

313. Vulcan frame controlled by a DJI A2 flight controller

314. Vulcan Mantis

315. Vulcan Octocopter

316. VulcanRaven

317. Vulcan UAV

318. Walkera TALI H500

319. Walkera Scout X4

320. Wookong DJI 5800

321. xCel Drones XD550CDR

322. XFold Rig with four configurations: Quadcopter, Hexcopter, 

Octocopter and x12 Copter

323. X8-M