ALEX MIROT PRESIDENT

386.866.0471 Alex.Mirot@UnmannedSafetyInstitute.Org

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

July 1, 2015

Re: Petition of UNMANNED SAFETY INSTITUTE, LLC for Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Sir and/or Madam: 

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

Act") and 14 C.F.R. Part 11, UNMANNED SAFETY INSTITUTE, LLC (“USI”), hereby 

applies for an exemption from Federal Aviation Regulations ("FARs") identified below, to 

allow commercial operations of small unmanned aerial vehicles (i.e., "small unmanned 

aircraft" or "sUAS"). 

This exemption is made based on the information in this petition, as well as the 

accompanying UAS Operations Manual (''Operations Manual") and Emergency 

Response Plan. Petitioner submits the Operations Manual and Emergency Response 

Plan, and as Confidential documents under 14 C.F.R. § 11.35(b), as the entire 

Operations Manual and Emergency Response Plan contain confidential commercial and 

proprietary information that the Petitioner has not and will not share with others. The 

documents contain operating conditions and procedures that are not available to the 

public and are protected from release under the Freedom of Information Act, 5 U.S.C. §

552 et seq., and any other requirements established by the FAA pursuant to Section 

333 of the FAA Reform Act. 

For your convenience, the petition is organized as follows: 

I. Description of Petitioner 

II. Relevant Statutory Authority 

III. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

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

§ 91.203 
b. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category 

Rotorcraft

c. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and 

Limitations: Pilot in Command. Commercial Pilot Privileges and 

Limitations.

d. 14 C.F.R. § § 91.9(c), and 45.23(b): Aircraft Marking and Identification 

Requirements 

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

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

Registration 

f. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness F. 14 C.F.R. § 91.103: 

Preflight Action 

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

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

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

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

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

Maintenance Inspections 

VI. Advanced UAS Flight Safety Training 

VII. Drug and Alcohol Program 

VIII. Public Interest

IX. Privacy 

X. Federal Registry Summary 

XI. Conclusion 

I. DESCRIPTION OF PETITIONER 

USI is a professional organization dedicated to UAS flight safety for individuals and 

proponent organizations. USI accomplishes its mission through the adoption and 

modification of time-honored aviation safety and training practices. USI maintains its 

core focus is in three key areas: human factors training, technology reliability, and 

building safe organizations. More specifically, USI conducts pilot training, flight test and 

evaluation, and promotes a strong safety culture and implements Safety Management 

Systems for proponent organizations where necessary. 

USI staff are widely recognized as having developed one of the first nationallyaccredited UAS education programs at Embry-Riddle Aeronautical University in 

Daytona Beach, Florida. USI is also the only UAS flight safety organization that has 

been approved by the State of Florida to provide training and certification to Florida’s 

growing STEM programs in high schools located throughout the state. 

As a result of its strong safety culture and vast experience in both manned and 

unmanned aviation, USI has been recognized by some of the world’s leading insurance 

brokerage firms and underwriting companies as a leader in UAS operations, risk 

mitigation, and flight safety. In fact, as a result of its industry-recognized expertise, USI 

was selected by Global Aerospace among a pool of competitors to become the 
exclusive UAS flight safety partner to Global Aerospace’s industry-leading SM4 Safety 

Program.

Global Aerospace, a leading provider of insurance and risk management solutions for 

the aviation and aerospace industries, recognizes USI as a highly competent training 

organization dedicated to aviation safety and the highest standards of excellence. 

Global Aerospace, with more than 90 years of experience, and over 14 offices around 

the world, has placed immense trust and confidence into USI as the sole provider of 

flight safety training and education to its worldwide portfolio of clients.

USI staff have provided a variety of flight safety training programs to both individuals 

and proponent organizations around the world, as part of USI’s role in the SM4 Safety 

Program, as well as through other independent channels. These include:

• A workshop on unmanned aviation safety to a major Part 135 operator 

providing unique air services to government and private industry, including 

international air ambulance services and transportation of unique cargo such 

as explosives. The local FSDO participated in this training workshop.

• UAS safety training to one of the largest multinational oil and gas corporations 

in the world.

• Flight safety and UAS training consultations to one of the largest electric 

utilities companies in the world, and a leading utilities company in the United 

States.

• UAS flight safety education and curriculum development for Embry-Riddle 

Aeronautical University, one of the world’s most prestigious aviation 

universities. 

USI seeks the requested exemptions and a Certificate of Authorization to permit it to 

offer flight safety education and live fly training to individuals and proponent 

organizations in the following industries:

• Precision agriculture

• Flare stack inspection,

• Utility-power generation system inspections and patrolling,

• Pipeline inspection and patrolling,

• Wildlife and forestry monitoring,

• Aerial surveying,

• Construction site inspection and monitoring, and

• Public entity support operations.

USI has adopted a philosophy that recognizes that UAS operations are a part of 

complex, interconnected systems that make up the NAS. As a result, USI has instituted 

for its UAS operations in the NAS, a strict policy on flight safety. USI’s instructor cadre 

all maintain at least FAA private pilots licenses, valid medical certificates, and are 

trained to USI’s Professional System Operator© (PSO©) certification. The PSO©
certification requires advanced flight safety training as documented in Section VI of this 

petition.

As set forth in more detail in the attached Confidential documents, USI will provide a 

mission capable UAS, FAA-credentialed PIC who is trained to USI’s Professional 

System Operator© (PSO©), visual observer, sensor operator (if needed), and any 

additional flight crew members needed for the specific flight operation. USI will retain 

operational control of all UASs, and each operation will be performed pursuant to a set 

of general procedures applicable to all flights, as well as additional flight procedures 

developed as suitable for each defined area of work. 

The contact information for Petitioner is as follows: 

UNMANNED SAFETY INSTITUTE, LLC.

Attn: Alex Mirot

146 Orange Place, Maitland Florida 32751

Phone: (386) 866-0471

E-mail: Alex.Mirot@UnmannedSafetyInstitute.org

II. RELEVANT STATUTORY AUTHORITY 

This petition for exemption is submitted in accordance with the Section 333(a) through 

(c) of the FAA Modernization and Reform Act of 2012. 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 Airspace System 

("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.1

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

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 44701(±) (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). 

																																																												 1 Id. at § 333(b)(1).
III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM 

ACT 

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive UAS 

under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) 

controlled as to access; and that (4) provides an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose. In 

addition many of these operations, such as flare stack, power line and construction 

inspection would be alternately accomplished by sending an individual up into a 

structure to manually conduct a visual inspection, or by flying a conventional rotorcraft 

dangerously close to the infrastructure to accomplish the task. Such operations carry a

much higher risk of serious bodily injury or death compared with conducing a 

photographic or video inspection from a small UAS.

Given the small size of the sUASs involved and the restricted environment within which 

they will operate, this petition exemption falls within the zone of safety, i.e., an 

equivalent level of safety, in which Congress desired the FAA to permit commercial 

UAS operations by exemption pending completion of formal rulemaking. Also, due to 

the size of the sUASs, and the restricted area in which the sUASs will operate, approval 

of the application presents no national security issue.

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, the grant of the requested 

exemptions is also in the public interest. 

Accordingly, Petitioner respectfully requests the FAA grant the requested exemption 

without delay. 

IV. DESCRIPTION OF PROPOSED OPERATIONS 

A. Scope of Operations.

USI will draw upon its vast aviation and flight safety experience to provide UAS flight 

training and scenario-based training to individuals and proponent organizations who 

intend to service a wide host of industries. Detailed procedures have been created and 

are set forth in the accompanying Confidential documents to ensure safe operation for 

the potential UAS application. To assist the FAA in its safety assessment of Petitioner's 

proposed sUAS operations, below is a summary of operational limitations and 

conditions, which will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines: 
1. The UAS will weigh less than 55 pounds. 

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

3. Maximum total flight time for each operational flight will be limited to the 

amount of time the UAS can be flown and still maintain a reserve battery 

power of no less than 25%. 

4. Flights will be operated at an altitude of no more than 400 feet above ground

level ("AGL"). As a result, the UAS flight will not be conducted within 

navigable airspace. 

5. Flights will take place in highly controlled environments at training locations 

either owned or operated by Petitioner or its customers. These locations will 

be privately owned property.

6. Flights will be operated at a lateral distance of least 100 feet from any 

inhabited structures, buildings, vehicles, vessels, or people not associated 

with the operation or who have not signed a waiver in advance of the 

operation. 

7. The petitioner will file a Notice to Airman ("NOTAM") with an appropriate air 

traffic control ("ATC") facility between 72 and 48 hours before the flight.

8. A Certificate of Authorization ("COA'') will be obtained prior to flight.

9. The petitioner will coordinate operations with the appropriate Flight Standards 

District Office ("FSDO").

10.Minimum crew for each operation will consist of the UAS Pilot, one or more 

Visual Observers as necessary to safely conduct the mission, and a Sensor 

Operator if required. 

11.The UAS Pilot will hold an FAA private pilot's license with class III medical 

certificate.

12.The observer designated for any operation will have at least a class II medical 

certificate. 

13.The UAS Pilot will be Pilot in Command ("PIC"). If a pilot certificate holder 

other than the UAS Pilot, who possesses the necessary PIC qualifications, is 

also present, that person can be designated as PIC. 

14.The UAS will operate in accordance with the safety and operational 

requirements of the Operations Manual. 
15.Prior to the operation, a Safety Risk Analysis Plan (SRAP) will be created 

which includes all safety and operational information necessary to safely carry 

out the flight. 

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

each day's missions. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for 

this briefing. 

17.Pilot, Visual Observer and Sensor Operator will at all times be able to 

communicate by voice. 

18.The UAS PIC will be a USI instructor who has undergone advanced flight 

safety training to the Professional System Operator© (“PSO©”) level. To 

obtain the PSO credential, the UAS PIC must possess an FAA Private Pilots 

License, obtain an Initial Qualification Training (“IQT”) provided by the 

Original Equipment Manufacturer (“OEM”) on training specific to the air 

vehicle, and attend an Unmanned Aviation Safety workshop presented by the 

Unmanned Safety Institute. The PSO credential, outlined further below, will 

address critical components of safe flight for UAS operators.

19.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. 

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

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

("FSDO"). 

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

the capability to return to a pre-determined location within the operational 

area and land. 

22.An Emergency Response Plan will be developed to safely terminate flight if

there is a loss of communication between the pilot and the observer. 

23.The UAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

V. REGULATIONS FROM WHICH EXEMPTION IS 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 sUASs, from its safety regulations and 
minimum standards when the Administrator decides a requested exemption is in the 

public interest.2

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. 

Listed below are (1) the specific sections of 14 C.F .R. for which exemption is sought, 

and (2) the operating procedures and safeguards that Petitioner has established which 

will ensure a level of safety better than or equal to the rules from which exemption is 

sought.3

A. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 

91.203(a)(1) 

Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the 

procedural requirements for the issuance of airworthiness certificates as required by 14 

C.F .R. § 91.203(a)(1). The Federal Aviation Act 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. 

All UAS operated by USI will meet the requirements of a small UAS, i.e., have a gross 

take-off weight of less than 55 pounds. Given the size and limited operating area 

associated with the UAS operations, 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. 

In all cases, an analysis of these criteria demonstrates that the sUAS operated without 

an airworthiness certificate, in the restricted environment and under the conditions 

proposed, will be at least as safe as, or safer than, a conventional aircraft operating with 

an airworthiness certificate without the restrictions and conditions of the proposed sUAS 

operations. 

Equivalent Level of Safety 

The sUASs to be operated hereunder weigh less than 55 pounds with payload, carry 

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

operate exclusively within a secured and sterile area. Unlike other civil aircraft, the 

proposed operations will be controlled and monitored by the operator, as well as an 

observer and sensor operator, pursuant to the Manual's requirements. Moreover, the 

FAA will have advance notice of all operations conducted under this exemption. 

																																																												 2 2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations 

prescribed pursuant to Sections 44701(a) and (b) and Sections 44702- 44716)
These safety enhancements, which already apply to civil aircraft operated in connection 

with existing inspection operations, provide a greater degree of safety to the Petitioner's 

employees, members of 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 sUAS, due to its size, speed of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial external 

load. 

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

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

of normal category rotorcraft. To the extent the Petitioner's sUAS would otherwise 

require certification under Part 27, Petitioner seeks an exemption from Part 27's 

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

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

C. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: 

Pilot in Command. Commercial Pilot Privileges and Limitations.

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire.

USI’s proposed operations meet the requirements of 8900.227 para 16(c)(2)(c) 

"Operations without a pilot certificate" in which the PIC is required to complete "FAA 

private pilot ground instruction" and pass "the FAA Private Pilot written examination." 

Since there are currently no means available for the pilot of a UAS to gain the 

experience in an equivalent category and class in order to apply for a commercial pilot's 

license, the proposed operations can achieve the equivalent level of safety by requiring 

our pilots to complete an advanced flight safety training program as outlined in Section 

VI of this petition whereby all instructors employed by USI will undergo extensive UAS 

training by USI and each be certified as a Professional System Operator©. 

Equivalent Level of Safety 

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 PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s 

license to operate this small UAS, as well as an advanced UAS flight safety training as 

documented in Section VI of this petition. Unlike a conventional aircraft that carries the 

pilot and passengers, the sUAS is remotely controlled with no person on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated 

in advance as set forth in the Operations Manual. The level of safety provided by the 
requirements included in the Operations 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 with a private pilot who holds advanced 

UAS flight safety training exceeds the present level of safety achieved by 14 C.F.R. 

§61.113 (a) & (b).

D. 14 C.F.R. § § 91.9(c) and 45.23(b): Aircraft Marking and Identification 

Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. § § 91.9(c), and 45.23(b).

• 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this chapter. 

• 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

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 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. 

• 14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on 

both surfaces of the cabin, fuselage, boom, or tail the marks required by § 

45.23.

Exemption from 14 C.F.R. § 45.23(b) is warranted because the sUAS has no entrance 

to the cabin, cockpit, or pilot station on which the word "Experimental" can be placed. 

Moreover, given the size of the sUAS, two-inch lettering will be impossible. The word 

"Experimental" will be placed on the fuselage in compliance with 14 C.F.R. § 45.29(f). 

Given the nature of the specific relief sought by this exemption request, Petitioner

requires relief from the associated marking and identification requirements of§ 45.27(a) 

and § 91.9(c), which would require compliance with§ 45.23(b).
Equivalent Level of Safety 

The equivalent level of safety for exemptions to the aircraft marking and identification

requirements of§§ 91.9(c), 45.23(b) and 45.27(a) will be provided by having the sUAS 

marked on its fuselage as required by § 45.29(f).

The FAA has previously issued the following exemptions to the aircraft marking 

requirements of§ 45.23(b): Exemption Nos. 10700, 10167 and 10167A. 

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

91.203(a) and (b): Carrying Civil Aircraft Certification and Registration 

Pursuant to 14 C.F.R. § 91.9(b)(2): 

(b) 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. 

Pursuant to 14 C.F.R. § 91.203(a) and (b): 

(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. 

USI does not request an exemption from this section but instead notifies the FAA that, 

in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the 

UAS flight manual, registration certificate and other documentation will be kept at the 

control station with the PIC during flight. The Chief Counsel's Office has held that for all 

UAS operations, this alternate method constitutes full compliance with the regulations. 

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

Petitioner seeks an exemption from 14 C.P.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness 
certificate issued for the sUAS, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. 

Equivalent Level of Safety 

The UASs will be fully maintained and operated in accordance with all specifications 

and requirements identified by the manufacturer. USI will only operate sUAS that have a 

proven track record of reliability and safety. Further, given that no UAS will be operated 

by USI with a weight of over 55 pounds, and no UAS will be flown unless it has been 

maintained and prepared for flight in accordance with the manufacturer's requirements, 

an equivalent level of safety will be provided. 

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. 

G. 14 C.F.R. § 91.103: Preflight Action 

Petitioner 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. 

Equivalent Level of Safety 

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 reviewing weather, flight battery requirements, landing and takeoff 

distance, and aircraft performance data - before initiation of flight. The Aircraft 

Operations Manual and manufacturer's flight manual will be kept at the ground station 

with the operator at all times. 

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

Petitioner seeks an exemption from 14 C.P.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." sUASs and 

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

flight control is accomplished through the use of a box that communicates with the 

aircraft via radio communications. 

Equivalent Level of Safety 

Given the size and speed of the sUAS, an equivalent level of safety can still be 

achieved without dual controls because no pilot or passengers are aboard the sUAS, 
and all persons will be a safe distance away in the event that the sUAS experiences any 

difficulties during flight instruction. 

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. 

Exemptions include: Nos. 5778K and 9862A.

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

Petitioner 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."

To provide the intended services, the sUAS is normally operated below 400 feet AGL. 

Additionally, the sUAS will maintain a lateral distance of at least 100 feet from inhabited 

structures, buildings, vehicles, and vessels, and from people not associated with the 

operation. 

Equivalent Level of Safety 

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

sUAS weight 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. As set forth in the Manual, the 

sUAS will be operated in a restricted area. Furthermore, by operating at such lower 

altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum 

safe altitude regulations. 

J. 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 sUAS does not have a barometric altimeter, 

but rather a GPS altitude read out. 
Equivalent Level of Safety 

An equivalent level of safety will be achieved by following the procedures set forth in the 

Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch 

site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the 

GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring operation 

at safe altitudes. 

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

Petitioner requests an exemption from 14 C.F.R. § 91.151(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 sUAS battery power means that no meaningful 

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

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. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted 

on-site without significant transit time by the sUAS. All flights will be planned to be 

terminated with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to the ground and its planned 

landing zone from anywhere in its limited operating area even in the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve 

fuel does not include the type of risks that Section 91.151 (a) was intended to alleviate 

given the size and speed of the small UAS, and the proximity of the flight operation to 

the landing zone. Moreover, operation will be limited to controlled areas where only 

people and property owners, or official representatives who have signed waivers, will be 

allowed.

This request for exemption falls within the scope of prior exemptions, including 

Exemption Nos. 10673, 2689F, 5745, 10673, and 10808.
L. 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections 

Petitioner also seeks an exemption from the maintenance inspection requirements 

contained in 14 C.P.R. § 91.405(a), 91.407(a)(l), 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 to these regulations is needed because Part 43 and 

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

will not have. 

Equivalent Level of Safety 

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

be performed in accordance with the UAS Manufacturer's Manual, as referenced in the 

Aircraft Operations Manual. As provided in the Operations Manual, the operator will 

ensure that the sUAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. 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. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during 

daylight hours, creates less risk than that associated with conventional rotorcraft 

performing the same operation. 

VI. ADVANCED UAS FLIGHT SAFETY TRAINING

USI recognizes that UAS present a significant and complex flight safety challenge within

the NAS. USI is committed to the highest standards of excellence in flight safety and 

safety risk management. As a result, any PIC employed by USI will not only possess a 

valid Private Pilot’s License issued by the FAA but will also be trained and certified as a 

Professional System Operator© (PSO©) by USI. 

To become certified as a PSO©, the student must have a valid Private Pilot’s License 

issued by the FAA. After presenting this credential the candidate must attend and pass 

the Small Unmanned Aircraft System Safety workshop at the Unmanned Safety 

Institute. This workshop focuses on eight specific flight safety modules.
Area one: Unmanned Aircraft Systems 

1. Small unmanned aircraft system loading and performance

2. Basic unmanned aircraft systems

3. Dealing with common UAS Emergencies 

Area two: Operations Planning 

1. Field site survey and preparation

2. Safety zones and sterile area concept

3. Energy planning 

Area three: Weather

1. Official sources of weather and effects of weather on performance

2. Field weather measurements

Area four: Airspace

1. Rules and Regulations

2. Airspace classification, control authority, and operating requirements 

3. Procedures for safely operating near airports

Area five: Crew Resource Management 

1. Human factors and Crew resource management

2. Physiological effects of drugs and alcohol

3. Six core Crew Resource Management concepts

4. The crew concept

Area six: Hazard Identification and Mitigation 

1. Four hazard domains

2. Risk mitigation strategies 

Area seven: Aeronautical Decision Making 

1. Decision processes 

2. Limitations and external pressures 

Area eight: Safety Management Systems

1. Safety Procedures and Policy

2. Assessing risks

3. Safety Assurance practices

4. Safety promotion

Upon completion of the Small UAS Safety Workshop, the candidate must participate in 

Unmanned Aircraft (“UA”) specific training and demonstrate proficiency in UAS type. 

This UA training must include all areas listed below per USI guidelines:
Area 1: Syllabus and Instruction Administration

1. Clearly defined objectives for each block of training

2. Training plan defining the number and sequence of events

3. Each training event has a completion standard and has identified items that must 

be covered in order to be considered complete

4. Training may include a combination of CBT, classroom, simulation, and live fly 

however, the program must include the greater of 5 hours or 10 flight training 

cycles

5. The training plan has standardized grade sheets for each block of training and is 

“signed off” by both the trainee and the instructor

6. The training record is kept for one year after training (digital versions okay)

7. The training operator has an instructor upgrade and qualification program

8. All trainees are required to pass a standardized practical and written test 

administered by an impartial party (check airman, chief of training, evaluator, 

etc.)

9. Trainees participate in operations as part of a team conducting full scale 

operations, not just part tasks as individual crew positions

10.Safety program and records of data

Area 2: Vehicle Specification

1. Is capable of waypoint navigation

2. Has stabilization and stability augmented by automation

3. Has a human machine interface other than just a controller

Area 3: Unmanned Aircraft Vehicle Specific Module

1. Systems components and functions

2. Flight controls, aerodynamics and modes of control

3. Telemetry and displays

4. Payloads and use

5. Data link equipment, operational bands, and limitations

6. Mission/operation planning software

7. Performance and limitations

8. UAS flight manual and documents review

Area 4: Pre-flight Procedures Module

1. Certificates, logs and documents

2. Preflight inspection

3. Control station and antenna equipment setup (if applicable)

4. Launch and recovery equipment, operational use, service limits, setup and 

teardown

5. Engine/motor starting

6. Before takeoff check

7. Radio/communications with ATC or CTAF
Area 5: Launch and Recovery Procedures Module

1. Normal and crosswind launch and recovery

2. Normal and crosswind approach

3. Confined area operations (if applicable to UAS)

4. Go-around

5. Controlling rate of descent (if applicable to UAS)

Area 6: Hover/Orbit Maneuvers Module

1. GPS fixed position hold

2. Hover 

3. Station keeping to maintain a fixed orbit around a point

Area 7: Operational Maneuvers Module

1. Departure climb outs

2. Level off/routine checks

3. Establishing and maintaining alt.

4. Straight and level flight

5. Airspeed change, straight-and-level

6. Clearing turns with aircraft or payload (if applicable)

7. Climbs

8. Systems monitoring during turns

9. Inflight change of waypoints or flight path

10.Descends or arrival profiles

11.Edge of visual range operations

12.In-flight checks of the system

13.Proper checklist usage (if applicable)

Area 8: Navigation Module

1. Use of local area map for orientation

2. Map reading (aeronautical charts)

3. Correlation of aircraft position with map

4. Maneuvering within assigned airspace

5. Using visual landmarks in flight

6. Waypoint placement and selection(if applicable)

7. Switching autopilot modes of control (if applicable)

8. Data link management

9. Use of fail safes or “geo fences” to limit UAS operations (if applicable)

10.Calculation of actual fuel/energy consumption

11.In-flight navigation or flight path planning

12.Calculation/compensation for in flight winds

13.Calculation of estimated time of arrival (eta)

Area 9: Airmanship Module

1. GCS and flight line safety procedures

2. Flight line and air discipline

3. Airmanship, judgment, & decision making and situation awareness
Area 10: Abnormal and Emergency Module

1. Loss of data link

2. Systems and equipment malfunction

3. Aircraft runaway

4. Flight termination

5. Uncontrolled flight into an obstacle

6. Airspace violation

7. Stalls or abnormal flight recovery procedures

Area 11: Crew Interaction Module

1. Collision awareness using a visual observer

2. Crew communication and coordination

3. Briefing and debriefing

4. Recovering from loss of situation awareness

5. Identifying lapses in flight safety

Area 13: Post-Flight Module

1. After landing checks

2. Post landing procedures

3. Engine shutdown checks

4. Equipment tear down (if applicable)

5. Servicing or minor repairs to the systems

6. Completion of flight time logs

7. Completion of maintenance logs

8. Safety procedures for securing UAS components

This course of study and practice comprise the advanced flight safety training provided 

by USI and is widely recognized by the world’s leading aviation insurance underwriting 

organizations and brokerage firms. This training, in conjunction with the additional 

requirements for UAS PIC noted above, will ensure the operator conducts flight safety 

practices of the highest standards.

VII. DRUG AND ALCOHOL PROGRAM 

As set forth in the Manual, USI is committed to a drug-free work place and the right of 

the flying public it serves to safe and efficient flight service. All employees of USI who 

perform safety sensitive and/or security related functions are prohibited from performing 

work if they have alcohol or a prohibited drug in their system. 

VIII. PUBLIC INTEREST 

Granting USI’s exemption request furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working 

environments such as those proposed in this petition. In addition, maintaining industrial 

safety has been a priority of state and local governments for decades. By its nature, the 
proposed use of sUAS offers superior safety to performing the same tasks with 

conventional aircraft or rotorcraft. 

In addition, granting the exemption will help advance the knowledge base for conducting 

commercial UAS operations. USI is committed to working with the local FSDO to share 

data from its operations. 

This additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the 

hazards and emissions associated with alternate use of conventional aircraft to conduct 

similar operations. The UAS in question is very light weight and does not carry any 

flammable fuel, further reducing the risk from any potential accident. 

IX. PRIVACY 

All flights will occur in accordance with any state or local laws regarding privacy. 

X. FEDERAL REGISTRY 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: 

USI seeks an exemption from the following rules: 

• 14 CFR Part 21, Subpart H

• 14 CFR Part 27

• 14 CFR 45.23(b)

• 14 CFR 61.113 (a) & (b)

• 14 CFR Part 61.133 (a)

• 14 CFR 91.7(a)

• 14 CFR 91.9(b)(2)

• 14 CFR 91.103

• 14 CFR 91.109(a)

• 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 91.407(a)(1)

• 14 CFR 91.409(a)(2)

• 14 CFR 91.417 (a) & (b)

Approval of these exemptions will allow USI to offer flight safety training for a number of 

customers in the industries and applications noted above. 
The exemptions will enhance safety by reducing risk to the general public and property 

owners from the hazards associated with performing equivalent work with conventional 

aircraft and rotorcraft. 

XI. 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, 

operation within visual line of sight, and national security-provides more than adequate 

justification for the grant of the requested exemptions to permit USI to operate sUASs 

and provide on-demand UAS services to private entities. 

Granting the requested exemption will benefit the public interest as a whole in many 

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. 

If you have any questions or require any additional information, please do not hesitate 

to call. 

UNMANNED SAFETY INSTITUTE, LLC

________________________________

Alex Mirot, President

(386) 866-0471

Attachments: Operations Manual and Emergency Response Plan (submitted as a 

Confidential Documents under 14 C.F.R. § 11.35(b) and exempt from disclosure under 

the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements 

established by the FAA pursuant to Section 333 of the Reform Act).