11 December 2015

Docket Operations, M-30

U.S. Department of Transportation

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Insitu formally submits a request for a Section 333 exemption as defined in the Federal Aviation 

Modernization and Reform Act of 212, Public Law 112-95. This request is for a specific set of 

unmanned aircraft to be operated specifically for aerial surveillance (data acquisition), research 

and development, and training. 

All operations will be executed with safety to other manned aircraft or person and property on 

the ground as the most important factor. Therefore, Insitu will apply its well developed and 

constantly improved flight safety processes for all unmanned aircraft operations. Some of those 

features include: pre-flight; use of certificated personnel (both FAA and Insitu certified); 

inspections to assure that the aircraft and system is airworthy and safe for flight; use of a pilot-incommand along with a visual observer; etc. Insitu has a well-documented safety management 

system that includes a flight safety office that constantly assesses overall flight operations while 

each specific flight operation includes a risk assessment action prior to each flight.

For any questions regarding this Section 333 exemption request, please contact:

Paul Allen

Commercial/Civil Program Manager

Insitu, Inc.

118 East Columbia River Way, Bingen, WA 98605

Phone: 541-399-6547

Email: paul.allen@insitu.com
Insitu Section 333 exemption request per the FAA Modernization and Reform Act of 2012 

1. This request is focused on a set of small unmanned aircraft systems

2. This request is for aerial surveillance, research and development, and training.
Table of Contents

Acronyms ......................................................................................................................................................4

Executive Summary ......................................................................................................................................5

Introduction ...................................................................................................................................................5

Background regarding Insitu .........................................................................................................................5

Regulatory Provisions from which Insitu seeks an Exemption.....................................................................6

The Extent of Requested Relief and the Reason Relief is Needed............................................................6

Operational Considerations and Establishing an Equivalent Level of Safety .............................................10

Granting Exemption is in the Public Interest ..............................................................................................12

Privacy.........................................................................................................................................................12

National Security.........................................................................................................................................12

Federal Registry Summary..........................................................................................................................13

Appendix A: List of sUAS aircraft proposed for this exemption request ...................................................14
Acronyms

AGL Above Ground Level

ATC Air Traffic Control

ATO Air Traffic Organization

C2 Command/Control (usually associated with radio link between 

the aircraft and GCS)

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCF Functional Check Flights

ft feet

GCS Ground Control Station

lbs Pounds

NAS National Airspace System

PIC Pilot-in-Command

Section 333 FAA Modernization and Reform Act of 2012 (referred to as 

Modernization Act) Section 333

sUAS Small Unmanned Aircraft System

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line-of-Sight

VMC Visual Meteorological Conditions

VO Visual Observer
Executive Summary

Insitu will use a set of aircraft (listed in Appendix A) to perform aerial surveillance (data 

acquisition), research and development, and training. All of the aircraft listed are less than 55 lbs. 

Operations will always occur at altitudes 500 ft Above Ground Level or lower, per Visual Flight 

Rules, and with a set of limitations to promote operational safety for other manned aircraft as 

well as persons, or property, on the ground. Insitu has operated unmanned aircraft systems for 

more than 20 years, and Insitu will utilize its experience to assure that all operations are 

conducted with an appropriate level of safety.

Introduction

Insitu respectfully requests an exemption from several provisions of Title 14 of the Code of 

Federal Regulations (CFR) to permit the use of a set of small Unmanned Aircraft Systems 

(sUAS) to conduct aerial surveillance (data acquisition), research and development, and training 

within the National Airspace System (NAS). The set of sUASs is listed in Appendix A, and all of the 

aircraft associated with each sUAS listed weigh less than 55 lbs. Henceforth, the entire set of sUASs 

will be represented by “sUAS.”

Accordingly, the grant of an exemption is consistent with Congress’ intent, reflected in Section 

333 of the FAA Modernization and Reform Act of 2012 (Modernization Act), that unmanned 

aircraft systems used for commercial purposes be permitted in the National Airspace System 

(NAS) prior to the issuance of final regulations governing general use of these systems if the 

petitioner can show that these systems are safe, will not adversely affect aircraft operations in the 

NAS, will not pose a risk to bystanders, will operate in a manner that benefits the public, and

will not pose any risk to National Security. This petition demonstrates that Insitu’s operations 

for this set of sUASs will meet the requirements and intent of the Modernization Act by 

requesting relief to select Federal Aviation Regulations (FARs) through exemption, establishing 

operational considerations that will establish at least an equivalent level of safety as the 

exempted FARs, and establishing that granting an exemption is in the best interest of the public.

Background regarding Insitu

Since 1994 Insitu has established itself as a leader in the Unmanned Aircraft (UA) industry, 

especially in terms of operational capability, safety practices, and working with regulatory 

agencies such as the FAA to move the UA industry forward in a safe manner. Insitu has worked 

with the FAA on Pathfinder projects in the Arctic where we operated the first Type Certified 

sUAS (ScanEagle) integrated in the NAS. Furthermore, Insitu recently conducted the first 

commercial Beyond Visual Line-of-Sight operations in the continental USA for BNSF railroad 

in Central, Eastern New Mexico. These efforts continue and operations under FAA granted 

exemptions from this petition will include the same dedication to safety. 

Insitu has more than 860,000 flight hours for its unmanned aircraft wherein no harm has 

occurred to any person, whether an operational participant or a non-participant.
Regulatory Provisions from which Insitu seeks an Exemption

Insitu requests an exemption from the following provisions to conduct the aerial surveying (data 

acquisition), research and development, and training. In some instances, relief is needed because 

relief from another provision renders compliance with the regulation at hand infeasible.

14 CFR Part 21, subpart H

14 CFR 45.23(b)

14 CFR §61.113(a) (b)

14 CFR §61.133 (a)

14 CFR §91.7(a)

14 CFR §91.9(b) (2)

14 CFR §91.105 (a) (1) (2)

14 CFR §91.107

14 CFR §91.109 

14 CFR §91.119 (b) (c) (d)

14 CFR §91.121

14 CFR §91.151 (a) (1)

14 CFR §91.203(a) (b)

14 CFR §91.405(a)

14 CFR §91.407(a) (1)

14 CFR §91.409(a) (1) (2)

14 CFR §91.417 (a) (b)

The Extent of Requested Relief and the Reason Relief is Needed

14 CFR 21, Subpart H Airworthiness Certificates

Subpart H details the requirements for issuing airworthiness certificates, as defined in FAR 

91.203(a)(1). The sUAS aircraft intended for this exemption request, listed in Appendix A, do 

not fit within the requirements cited for Part 21, Subpart H: lack of a type certificate or features 

that would fit within the airworthiness certificate applicability, as defined in FAR 21.175. 

However, per Part 11 and Section 333 of the Modernization Act, the size, weight, speed, and 

limited operating area associated with the set of sUASs, an exemption from Subpart H meets the 

requirements of an equivalent level of safety. The intended aircraft are less than 55 pounds, will 

always be operated by Insitu personnel within VLOS, will include an aircraft identification, will 

be operated in a manner so as to avoid flight over or near non-participants, and will be operated 

below 500 ft with both the PIC and visual observer constantly monitoring the airspace so as to 

avoid any encounters with manned or other unmanned aircraft in the vicinity. Furthermore, the 

aircraft will be operated per the manufacturers’ recommendations, and service and safety 

bulletins. In addition, Insitu personnel will always perform a pre-flight assessment to assure that 

the unmanned aircraft system is airworthy and safe for flight.

14 CFR 45.23(b): Marking of the sUAS aircraft

This regulation requires that specified experimental, provisionally certified aircraft, or light-sport

category aircraft to be marked with letters between two (2) inches and six (6) inches high

“limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance

to a cabin, cockpit or pilot station. The sUAS aircraft do not possess a cabin, cockpit or pilot 

station; therefore, an exemption is needed since there is no location for a word such as 

“experimental.” Given the size of the UAS, two (2) inch lettering may be infeasible. Insitu will 
mark the sUAS aircraft where feasible; however, the lettering may be less than the required two 

(2) inches.

14 CFR 61.113(a) (b): Private pilot privileges and limitations; Pilot in Command

14 CFR 61.133(a): Commercial Pilot Privileges and Limitations

Insitu will use specially trained staff to conduct UAS operations. These individuals will hold an 

FAA Sports Pilot Certification or greater. The sUASs will not carry property for compensation 

or hire since the aircraft will be used solely to perform aerial surveillance (data acquisition), 

research and development, and training. However, the employees’ operation of the sUASs will 

not be incidental to their employment with Insitu, and the Insitu employees will be compensated 

for such work. Without an exemption, the pilot/operator would be required to hold a Commercial 

Pilot Certificate under §61.133. In addition, the risk associated with the planned sUAS flight 

operations is substantially less than the risk posed by a traditional aircraft. Personnel will 

operate the sUAS at or below 500 ft Above Ground Level (AGL) and 500 ft from any nonparticipating individuals. (Non-participating individuals are those persons who are not affiliated 

with the sUAS operation and are sometimes referred to as the “innocent bystander.”)

Additionally, personnel will abide by all operational considerations in the section of this petition 

titled Operational Considerations and Establishing an Equivalent Level of Safety and any 

additional operational stipulations the FAA appends to this exemption request. Accordingly any 

inherent risk, such as the sUAS striking a person, would be limited to Insitu personnel who will 

be appropriately outfitted in safety gear and trained in the operation of the sUASs, performing

their role as either Pilot in Command (PIC) or Visual Observer (VO). Participating personnel 

will be fully aware of ongoing operations, safety procedures, and standard operating procedures. 

Requiring a commercial pilot certificate would provide no appreciable safety benefit and would 

impose additional cost on Insitu with no safety benefit. Given that Insitu will use individuals who 

hold at least a sports pilot license, Insitu personnel will be well aware of the FAA rules and 

requirements for aircraft operations and will be security screened by the TSA. Through 

providing appropriate training suited to the operation of the set of sUAS, including preflight 

planning, checklist usage, Crew Resource Management (CRM), Single Pilot Resource 

Management (SRM), and considering the sUAS size, weight, and the restricted operating area, 

Insitu believes that an equivalent level of safety will be established and an exemption should be 

granted for these regulations. 

14 CFR §91.7 (a): Civil aircraft airworthiness.

Since none of the sUASs possess a Type Certificate (TC), it is impossible for an individual 

aircraft to conform to an approved Type Certificate. In all instances, it appears that airworthiness 

includes a requirement that the airplane 1) conform to the aircraft’s type design or its type 

certificate (or, as modified by supplemental type certificates and any airworthiness directives), 

and 2) be in condition for safe operations. The types of operations contemplated by Insitu will 

not qualify the sUAS for an experimental airworthiness certificate. Accordingly, relief from 

§91.7(a) is requested through exemption. Insitu believes that it can meet the requirements of 

§91.7(b) and is not requesting an exemption from that provision insofar as this part applies to 

keeping the sUAS in a safe for flight condition. Insitu has demonstrated an industry leading 

capability of operating sUAS’s around the world in a safe manner using similar operating 

procedures as manned flight operations. These practices will be applied to our use of the sUAS 

and will include the use of manufacturer and/or Insitu produced checklists (whichever is more 

stringent) and procedures for pre-flight, post-flight, takeoff, approach, landing, emergency 

procedures, and maintenance checks. Furthermore, Insitu will follow all manufacturer 
maintenance and preventative maintenance procedures, and the sUAS will not be returned to 

service until it has been deemed airworthy/safe for flight. To the extent that the manufacturer’s 

published maintenance procedures do not meet the standards of Insitu UAS operations, Insitu 

will develop more stringent requirements.

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

The sUAS comes with access to online or paper manuals that provide instructions for the safe 

operation and maintenance of the aircraft. Compliance with this regulatory provision is not 

possible since the sUAS is too small to carry a printed manual. Since, by definition, there will 

never be a person aboard the sUAS, Insitu submits that there is no need to require the manual to 

be placed on the sUAS and an exemption is requested. An equivalent level of safety will be

maintained by keeping the flight manual at the ground control point where the PIC will have 

immediate access to it. All operations of the sUAS will occur with a Pilot-in-Command (PIC). 

The PIC will always have immediate access to the relevant sUAS manuals. A paper copy of the 

manual will always be available to the PIC as well as an electronic copy. 

14 CFR §91.105 (a) (1) (2): Flight crewmembers at stations

14 CFR §91.107: Use of safety belts, shoulder harnesses, and child restraint systems 

Due to their small size and the nature of unmanned aircraft, it is not possible to comply with this 

rule. Insitu requests relief through an exemption from the above regulations because 

crewmembers will be unable to enter and fly inside the aircraft. The same level of safety will be 

achieved by requiring the PIC to be at the Ground Control Stations (GCS) at all times with 

positive control of the aircraft while maintaining Visual Line of Sight (VSOL) with the sUAS.

14 CFR §91.109 (a): Flight instruction; simulated instrument flight and certain flight tests.

Small Unmanned Aircraft (sUA), by their design, do not have fully functional dual controls. 

Video and Flight control are accomplished through the use of a controller that communicates 

with the aircraft (command and control link, or C2) via selectable radio communications. Insitu 

requests relief from the above regulation and will establish an equivalent level of safety by 

operating training events in the following manner. Instruction, proficiency, internal certification, 

and time building flights will be conducted as dedicated training events. Any personnel not 

essential for flight operations will be considered nonparticipants and will be kept clear of flight 

operations in accordance with 14 CFR § 91.119 concerning appropriate distance from 

nonparticipants. The PIC and Trainee will be located next to each other and the GCS (within one 

arms distance) during these dedicated training sessions and a VO will be used at all times. When 

appropriate, Insitu personnel will train with the included flight simulator to further reduce risk 

and increase safety and proficiency before flight operations are conducted. 
14 CFR §91.119 (b) (c) (d): Minimum safe altitudes: General

Insitu requests relief and exemption from §91.119 (b) (c) (d). Relief from this part is required 

for multiple reasons. First, the requirement in this regulation would require Insitu to operate the 

sUAS at a higher altitude that will make it impossible to accomplish the intended purpose of 

aerial surveying, research and development, and training due to distance from the ground and 

camera resolution. Second, flying at higher altitudes required in this regulation would create 

safety concerns as it would put the sUAS in airspace with manned aircraft required to comply 

with §91.119 in the NAS. Since operations at this altitude also pose a heightened risk of 

collision with another aircraft, equivalent safety can only be assured through the grant of an 

exemption. As noted in the explanation of why an exemption will not adversely affect safety, 

Insitu will obtain exclusive use/permissions of the land over which the sUAS will be operated, 

and public access will be restricted. We will control access to the operating area and have the 

ability to assure that nonparticipants maintain appropriate separation from the aircraft as required 

by 14 CFR § 91.119. Insitu personnel are required to wear safety equipment, including hard 

hats, safety glasses and steel-toe boots whenever dispatched to a work site. As such, the risk of 

injury is mitigated. Granting this relief through exemption is in the best interest of the public,

because the sUAS can accomplish the tasks without the use of a manned aircraft that use more 

resources, requires personnel onboard to fly, hold flammable fuel, and weighs significantly more 

than the sUAS. These factors pose greater risk to the public for a manned aircraft flying at the 

limits of 14 CFR § 91.119 conducting the same mission since a catastrophic event of the 

aforementioned manned aircraft would more likely involve loss of life and more property 

damage than a catastrophic event of the sUAS while abiding by the proposed part 107 rules, i.e. 

not overflying or coming within 500 ft of nonparticipant personnel, vessels, or buildings and 

maintaining an altitude at or below 500 ft AGL. 

 

14 CFR §91.121: Altimeter settings

Section §91.121 requires aircraft operators to maintain cruising altitude or flight level by 

reference to an altimeter. As most sUAS utilize a Global Positioning System, altitude will be 

determined using this type of instrumentation. Insitu believes exemption from 14 CFR 91.121 

should be granted, as the regulation is not applicable. To ensure an equivalent level of safety, 

Insitu personnel will conduct proper preflight checks of the onboard GPS system and will 

incorporate a RAIM check into the preflight planning checklist. This check will be done at 

http://www.sapt.faa.gov or appropriate resource as directed by the FAA.

14 CFR §91.151 (a) (1): Fuel requirements for flight in VFR conditions

The sUAS is battery operated and requires no fuel. Insitu does not intend to use the sUAS for 

point-to-point flights and will not operate the sUAS beyond visual line of sight. The sUAS will 

not require an airport in order to land. Rather, Insitu will operate the sUAS using pre-planned 

flight paths (taking into account weather conditions) designed to allow the sUAS to fly to the 

point of intended landing, which will always be in the immediate vicinity of the PIC and/or VO 

except in case of emergencies or nonparticipant intrusion. Accordingly, there is no need for a 

time-based excess fuel requirement. 

Insitu requests relief from these regulations through exemption due to the above reasons as an 

equal or higher level (lack of fuel used in flight operations) of safety will be achieved
§91.203 (a) (b): Civil Aircraft: Certifications required

Due to the small size of the sUAS, which weigh less than 55 pounds fully configured for flight, it 

is impossible to comply with these regulations. Insitu requests relief from these regulations 

through an exemption. In order to ensure an equivalent level of safety, Insitu personnel will have 

the registration documents immediately available at the GCS and displayed in a similar manner 

as stipulated in these regulations. Since the sUAS cannot be issued an airworthiness certificate at 

this time, a copy of the FAA response to this petition and any waivers granted will be 

immediately available. These requirements will be included in a preflight checklist to ensure 

compliance. 

14 CFR §91.405 (a): Maintenance required 

14 CFR §91.407 (a) (1): Operation after maintenance, preventive maintenance, rebuilding, 

or alteration

14 CFR §91.409 (a) (1) (2): Inspections

14 CFR §91.417 (a) (b): Maintenance Record

Insitu will maintain the aircraft as instructed in the owner’s manual, where applicable, and will 

not operate the aircraft until it has determined that any needed repairs have been made according 

to the maintenance and operations manual as well as any supplemental bulletins issued by the 

manufacturer. Insitu will also conduct functional check flights (FCF) as appropriate after certain 

major maintenance has been performed using the same safety guidelines as prescribed for 

training flights. Additionally, Insitu personnel will document scheduled and unscheduled 

maintenance performed according to already existing robust documentation requirements 

specific to the operation of a sUAS. As Insitu personnel will be required to follow the above 

processes and will never return a sUAS to service that has not been deemed safe for flight, Insitu 

requests an exemption from the above regulations as an equivalent level of safety will be 

achieved. 

Operational Considerations and Establishing an Equivalent Level of 

Safety

The sUAS will be used for aerial surveying (data acquisition), research and development, and 

training to retain within visual line-of-sight of the PIC and VO. In order to safely conduct the 

sUAS operations in regard to the requested exemptions, Insitu proposes the following 

operational considerations that will establish an equivalent level of safety. Our goal is to mirror 

the notice of proposed rulemaking (NPRM) RIN 2120-AJ60 released by the FAA on Feb 15, 

2015. 

1. Operations related to this exemption request will only utilize the sUAS aircraft identified in 

Appendix A. 

2. No operations related to motion picture and/or television filming will occur.

3. All aircraft listed in Appendix A weigh less than 55 pounds, including payload.

4. Preflight, weather, local airspace, and general operational planning will be conducted by 

appropriately certificated personnel (minimum of a Sport Certificate) who have also received 

training on the relevant sUAS. This training will include flight simulator training progressing to 

flight training supervised under controlled conditions.

5. Checklists for all phases of flight including preflight, takeoff, approach, and landing will be 

followed by the PIC, VO, and any other participants. 

6. The PIC and associated VO will operate the sUASs with the following limitations:
o Any requirements the FAA stipulates in response to this petition

o Within Visual Line of Sight (VLOS) of each sUAS at all times. However, only one sUAS 

(one UAV, one GCS) will operate at a given site with a PIC/VO team at any one time.

o The PIC and VO will perform see and avoid duties for the entire operational area.

o Operations over nonparticipants will not be allowed.

o Operations will be conducted for daylight only (official sunrise to official sunset, local 

time).

o Right of way will be yielded to all other aircraft, manned and unmanned.

o Maximum ground speed of 87 Knots (100 mph)

o Maximum wind speed will be per the manufacturer’s recommendations for each sUAS.

o Maximum altitude of 500 Feet above ground level (AGL).

o Altitude will be reported in feet AGL.

o Operations will only be conducted in Visual Meteorological Conditions (VMC), i.e. 3 

statute miles visibility from the GCS and clear of clouds as appropriate to the airspace 

operating in. This includes 500’ below the clouds in class C, D, and E airspace 

(operations over 10,000’ MSL not anticipated) and clear of clouds in class B and G 

airspace in accordance with14 CFR §91.155 

o Operations in class B, C, D, and E or any operation within 5 Statute Miles of an airport 

will always be coordinated with the local ATC, airport manager, and any other 

stakeholders as appropriate.

o PIC and VO will never operate more than one sUAS at a time for a given site. It’s 

possible that Insitu will operate more than one sUAS at multiple sites throughout the 

USA. However, each PIC and VO team will ONLY operate one sUAS at a time.

o The PIC and VO will have either a class 2 medical or a valid driver’s license and will 

never operate if any mental or physical condition exists that would interfere with the safe 

operation of the sUAS.

o The PIC will have a minimum of a Sports Pilot Certification.

o The sUAS will be registered, and the N-number will be displayed on the aircraft in the 

largest font practicable.

o 90 day currency on the system, including 3 takeoffs and landings to a full stop, will be 

maintained by the PIC.

o Appropriate clearance from obstacles in operating area will be maintained.

o 500 ft clearance from nonparticipating people will be maintained

o Operations will be conducted over Insitu owned land, or land that Insitu exclusively 

controls access to with the permission of the landowner.

o All relevant documentation for a particular sUAS will be immediately available to the 

PIC and VO during flight operations. Relevant documentation may include the operator’s 

manual/handbook, the maintenance procedures, COA, etc.

o All maintenance, determination of airworthiness, inspections, etc., will occur per the 

manufacturer’s recommendations. If the recommendations are not considered substantive 

by Insitu, then Insitu will use its expertise to develop appropriate recommendations.

o Insitu will assure that the aircraft and unmanned system elements are in an airworthy 

condition prior to each flight.

o Insitu will comply with all safety bulletins issued by the relevant manufacturer.

o If the UA loses link or GPS, the aircraft will return to a pre-determined location, away 

from any non-participants or land in a controlled manner where the lost link / lost GPS 

events occurs as per the system design and operation. 

o The PIC and VO will perform a risk assessment prior to each flight, including any 

contingencies that are relevant for the operations at a particular site.

o The PIC will abort the flight for any unplanned events wherein the conditions of the 

flight exceed the risk assessment that occurs prior to each flight as part of the Insitu 

Safety Management System.
o All operations will occur within the constraints/limitations/requirements stated in the 

relevant COA.

o Before conducting operations, the radio frequency spectrum used for operation and 

control of the UA must comply with the FCC, Federal Communications Commission. 

7. Any reportable incidents will be reported appropriately to the FAA, local authorities, and the 

NTSB as appropriate

o Additionally, Insitu has an existing Flight Safety Department that is an industry leader in 

UAS accident investigation and mishap prevention. Personnel in this department are 

experienced UAS operators and maintainers. This existing robust safety program will be 

applied to our operations of the set of sUAS in addition to reporting incidents in 

adherence to federal regulations.

Granting Exemption is in the Public Interest

Insitu believes that approval from the FAA will enhance efficiency and safety in any operation 

its sUAS conducts by reducing the need for manned aircraft to achieve an equivalent task of 

aerial surveillance, research and development, and training. Granting an exemption with 

appropriate limitations is in the public interest because it will allow Insitu to conduct these tasks 

(aerial surveillance, research and development, and training) without using manned aircraft 

which are inherently more dangerous due to personnel onboard, fuel and other flammable 

liquids, greater aircraft size and weight, less restricted operating area, proximity to other aircraft 

and de-confliction required, and low altitude flying that would be required to achieve an 

equivalent result. Due to its camera-only payload capability, lack of cargo, fuel or combustible 

materials, and considering aircraft size, weight, and limited operating area, the sUAS presents no 

major risk to nonparticipating people, property, or aircraft and will reduce congestion in the NAS 

and reduce workload of ATC facilities. As Insitu personnel acting as PIC of the sUAS will have 

a minimum FAA certification of Sport Pilot, the required screening by the TSA will already have 

been conducted; therefore the operations will not pose any threat to National Security. While 

adhering to the operational guidelines proposed in this petition as well additional requirements 

mandated by the FAA in response to this petition, Insitu firmly believes that sUAS operations 

can be conducted in the best interest of the public to an equivalent or greater level of safety as 

required by §333 of the Modernization Act and these exemptions should be granted in 

accordance with 49 USC §44701(f). 

Privacy

By not flying near persons or property without prior agreement of the land owner and in 

maintaining the 500 ft seperation from nonparticipants, there are no foreseen privacy issues.

Industry best practices and applical laws will always be adhered to.

National Security

All Insitu PICs will possess an FAA pilot certification of “Sport Pilot” or greater. Therefore, all 

PICs will be TSA reviewed and cleared. Furthermore, all sUASs are less than 55 lbs with limited 

range. Therefore, this petition and the subsequent use of the sUAS present no national security 

issue.
Federal Registry Summary

Docket No.: FAA-2015-___ or FAA-2016-___

Petitioner: Insitu, Inc.

Affected FARs include: 14 CFR Part 21, subpart H; 14 CFR 45.23(b); 14 CFR §61.113(a) (b); 

14 CFR §61.133 (a); 14 CFR §91.7(a); 14 CFR §91.9(b) (2); 14 CFR §91.105 (a) (1) (2); 14 

CFR §91.107; 14 CFR §91.109; 14 CFR §91.119 (b) (c) (d); 14 CFR §91.121; 14 CFR §91.151 

(a) (1) 14 CFR §91.203(a) (b); 14 CFR §91.405(a); 14 CFR §91.407(a) (1); 14 CFR §91.409(a) 

(1) (2); 14 CFR §91.417 (a) (b).

Description of Exemption Request: Insitu is seeking an exemption to conduction commercial 

aerial surveillance, research and development, and training. 

Insitu requests that the FAA grant the appropriate exemptions per Section 333 of the 

Modernization Act to allow for commercial operations.

Sincerely,

Paul Allen

Commercial/Civil Program Manager

Insitu, Inc., Phone: 541-399-6547, Email: paul.allen@insitu.com
Appendix A: List of sUAS aircraft proposed for this exemption request

1. 3DR Solo: https://3drobotics.com/

2. 3DR IRIS+: https://3drobotics.com/

3. 3DR X8+: https://3drobotics.com/

4. 3DR X8-M: https://3drobotics.com/

5. 3DR Aero: https://3drobotics.com/

6. 3DR Aero M: https://3drobotics.com/

7. 3DR Spektre: https://3drobotics.com/

8. Aeryon Labs Scout http://aeryon.com/faqs

9. Aeryon Labs Skyranger http://aeryon.com/faqs

10. Steadidrone Vader http://www.steadidrone.com

11. Steadidrone MAVRIK

12. Steadidrone FLARE

13. SteadiDrone QU4D

14. SteadiDrone QU4D X

15. DJI Phantom http://www.dji.com/

16. DJI Phantom 1

17. DJI Phantom 2

18. DJI Phantom 2 Vision 2+

19. DJI Phantom 3

20. DJI Inspire 

21. DJI Inspire 1

22. DJI S900

23. DJI Flamewheel F450

24. Volantex Ranger EX 757-3 http://www.volantexrc.com/product/75703

25. AirCover QR-425s http://www.aircoversolutions.com/suas-hardware.html

26. AirRobot AR100-B http://www.airrobot.de/index.php/about-airrobot.html

27. AirRobot AR100-C

28. AirRobot AR180

29. AirRobot AR200

30. SenseFly eXom https://www.sensefly.com/home.html

31. SenseFly eBee

32. SenseFly eBee Ag

33. SenseFly eBee RTK

34. Skycatch https://www.skycatch.com/products/uav/evolution

35. Precision Hawk Lancaster Hawkeye http://www.precisionhawk.com/