April 2, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

Aerial Robotics LLP

3115 US Hwy 421 N

Frankfort, KY 40601

Dear Sir or Madam:

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

Act”) and 14 C.F.R. Part 11, Aerial Robotics seeks an exemption from the Federal 

Aviation Regulations (“FARs”) listed below to allow operation of unmanned aircraft 

systems (UAS) for commercial use..

Aerial Robotics anticipates that the majority of the work can be accomplished within the 

“blanket” sub 200 foot COA recently granted to Section 333 civil exemption holders. 

Aerial Robotics will apply for a new or amended COA for all flights not allowed under the 

blanket COA.

Aerial Robotics intends to utilize the proposed unmanned aircraft systems in the 

following applications:

Real Estate and Marketing

Building, Construction Progress and Structure Inspection

Aerial Mapping

Environmental and Precision Agriculture

Flight Training

Research and Development

Utilizing a UAS provides a higher level of safety for the pilot and people and property on 

the ground. Unmanned aircraft weighing a few pounds can accomplish many of the 

same tasks as a full size aircraft that weighs thousands of pounds and carries 

combustible fuel. A UAS reduces emissions and congestion in the National Air Space 

(NAS).

Utilizing a UAS benefits the public by providing a more efficient, safe and 

environmentally responsible tool for acquiring the customer’s imagery as compared to 

flying a manned aircraft. Grant of exemption would further benefit the public by allowing 

experienced UAS operators to provide services and training in a new UAS industry 

which is in desperate need of experienced people.
Due to the small size, light weight, slow flying speed and unmanned aspect of the 

proposed UAS Aerial Robotics requests relief from the following sections in 14 C.F.R

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

14 C.F.R. Part 27

14 C.F.R 45.23 (b)

14 C.F.R. §§ 61.113 (a) & (b)

14 C.F.R. §§ 61.133 (a)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103 (b)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) and (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 91.407 (a) (1)

14 C.F.R. 91.409 (a) (2)

14 C.F.R. 91.417 (a) & (b)

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

The characteristics of the proposed UAS operating in a controlled environment 

provide a greater degree of safety to the public, operators and property owners 

than conventional operations conducted with airworthiness certificates issued 

under this section.

Aerial Robotics will utilize checklists for preflight inspections as well as procedures 

for routine maintenance to ensure that the UAS is in an airworthy condition prior 

to each flight. 

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

Relief this section is requested for the same reasons as in the exemption request 

from 14 CFR Part 21, Subpart H

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

A small UAS cannot meet the marking requirements for a full size aircraft. Aerial 

Robotics will provide markings on the aircraft with the contact information and 

registered identification “N-number”. Markings will be as large as practical and 

visible to the pilot, observer and others working with the UAS.
14 CFR 61.113 (a) & (b); 61.133(a): Private pilot privileges and limitations: Pilot 

in command; Commercial pilot privileges and limitations

Relief from these sections is requested to allow an operator with a sport pilot

certificate or higher to conduct commercial UAS operations. The skill set required 

to operate a UAS is significantly different from that of a manned aircraft. Aerial 

Robotics proposes that a higher level of safety and airmanship skills can be 

obtained with the requirement that the PIC successfully complete UAS flight 

training as detailed in the operator’s manual in addition to possession of a current 

sport pilot certificate or higher and valid US drivers license.

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

An equivalent level of safety will be provided using the proposed procedures, 

manuals and checklists. Without an airworthiness certificate for the aircraft, 

relief from this section is also requested.

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

requirements

Aerial Robotics proposes that the operator’s manual for the UAS be kept at the 

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

14 C.F.R. 91.103: Preflight Action

Aerial Robotics proposes that the preflight procedures documented in the 

operator’s manual substitute for the preflight actions in this section.

14 C.F.R. 91.109: Flight Instruction

A higher level of safety than conventional full scale flight instruction can be 

achieved with the proposed UAS operating in a closed flight training area. No 

pilot or passengers will be carried in the aircraft. Dual flight controls would not 

provide additional safety for the operators.

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

Due to the nature of the proposed work, Aerial Robotics’ UAS operations will 

require the aircraft to be positioned less than 500 feet away from the operators

and structures, and operated at altitudes less than 500 feet AGL. The light weight 

and slow speed of the UAS negate the safety concerns associated with operations 

of full scale aircraft, when the UAS operations are performed in accordance with 

the proposed operating procedures.
14 C.F.R. 91.121: Altimeter Settings

The proposed UAS employs altitude control utilizing barometric and GPS sensors. 

Altitude is automatically referenced to the current ground level when the flight 

controller is powered up. This can provide a method of altitude calibration 

equivalent to conventional aircraft altimeter setting procedures. The proposed 

UAS will operate under the “blanket” 200-foot COA and when necessary will 

obtain a separate COA specific to the airspace required for that operation. The 

separate COA specific flights will be flown at an altitude less than 400 feet AGL. 

The combination of operating procedures, visual cues, automatic altimeter 

calibration, telemetry, altitude and range geofencing and hear-see-avoid 

capability will ensure separation between the UAS and manned aircraft.

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

The proposed UAS have flight times of less than 30 minutes and therefore cannot 

meet the 30 minute reserve requirement of this section. An equivalent level of 

safety can be achieved by operating the UAS in accordance with the operator’s 

manual. Voltage monitoring via telemetry as well as transmitter alarms will help 

ensure that adequate power will always be available for a controlled landing. 

Automatic battery failsafe settings provide an additional level of safety to help 

ensure that the UAS has adequate power to safely land.

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

Documents will be kept at the ground flight control point where the PIC and 

others can have immediate access to them.

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections

An equivalent level of safety will be achieved by performing the maintenance 

inspections in the operator’s manual. Because the UAS will not have an 

airworthiness certificate, relief from this section is requested.
Summary of operating procedures

It is the view of Aerial Robotics that operating an unmanned aircraft system (UAS) in 

accordance with the restrictions and procedures below and in accordance with the 

instructions and recommendations in the operator’s manuals will provide a public benefit 

and not pose a risk to the NAS or people and property on the ground.

The proposed UAS are small, lightweight, slow flying, aircraft conforming to the 

specifications in the attached operator’s manuals. All proposed aircraft weigh less than 

15 lbs.

All flights will be flown from and over property with prior written authorization from the 

property owners. Flight areas include construction zones not open to the public, areas 

surrounding structures closed to traffic, and roads closed to public traffic. Construction 

areas may be occupied by Aerial Robotics personnel, construction workers, and 

owners.

All personnel on the ground will be briefed prior to any UAS flight. Ground personnel 

will be advised as to the hazards and be advised to remain “heads up” when the UAS is 

operating.

The UAS will be operated by a Pilot in Command (PIC) maintaining visual line-of-sight 

(VLOS) and under visual flight rules (VFR) conditions. The PIC will possess a FAA 

issued sport pilot certificate or higher. The PIC will be responsible for the safe operation 

of the flight including autonomous modes. The PIC will use human vision unaided by 

any device other than corrective lenses, as specified on the PIC’s airman medical 

certificate or U.S. driver’s license.

A visual Observer (VO) will be located next to the PIC to serve as a safety spotter for 

other aircraft and to assist with verbal relay of telemetry data. The VO will communicate 

solely by voice with the PIC. Only one VO will communicate with the PIC for the 

duration of the flight. Electronic messaging or texting will not be used during the flight.

The UAS will take off and land from an area directly next to the PIC and VO. The PIC 

and VO will not operate the UAS from a moving land or air based vehicle. UAS 

operations will be limited to ranges that permit the PIC to comprehend aircraft 

orientation and direction at all times.

The proposed UAS will operate under the “blanket” 200-foot COA at flight speeds less 

than 100 mph. If applications require altitudes greater than 200 feet, Aerial Robotics will 

obtain a separate COA specific to the airspace required for that operation. The separate 

COA specific flights will be flown at an altitude less than 400 feet AGL and at flight 

speeds less than 100 mph.

All flights will be conducted in compliance with the airspace restrictions specified in the 

“blanket” 200-foot COA. If operation in other airspace is desired, Aerial Robotics will 
obtain all required authorizations from the FAA and controlling agencies prior to 

conducting those operations.

All flights will be conducted during daylight hours under VFR conditions.

The UAS will 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.

The PIC will immediately yield the right of way to all manned aircraft. The agility and 

vertical descent capabilities of the UAS combined with the ability of the PIC and VO to 

both hear and see full size aircraft approaching from all directions facilitates “hear, see 

and avoid” operations that are far more effective than can be achieved in a full size 

aircraft cockpit.

Flights will be performed using the procedures and recommendations in the attached 

operator’s manuals.

The UAS mission will be terminated to allow for at least 5 minutes of battery power for 

return to the launch area and landing procedures.

Aerial Robotics will not use the UAS for closed-set motion picture or television filming.

Staff resources

William A Dickerson is the proposed PIC. Experience includes 31 years of building and 

recreationally flying fixed wing, rotary wing, seaplane and multirotor model aircraft, 22 

years experience with recreationally flying full scale land based single engine aircraft 

with possession of a private pilot certificate and current third class medical certificate.

Glenn W Anderson is the proposed VO and is a registered professional electrical 

engineer with 39 years experience building and flying fixed wing, rotary wing, seaplane, 

ducted fan and multirotor RC aircraft. He has 15 years building and flying RC aircraft 

using some of the first RC autopiloting systems and has 5 years experience in 

configuration and use of the proposed 3D Robotics flight control systems.

Mr. Dickerson and Mr. Anderson were the owners of New Perspective Aerial 

Photography. New Perspective Aerial Photography operated from 1994 until 2009. 

This company provided aerial imagery to a variety of clients including Oak Ridge 

National Labs and the University of Kentucky. A history of New Perspective Aerial 

Photography is available at www.aerialrobotics.com.

In summary Aerial Robotics has procedures, staff and resources to safely assemble, 

operate and maintain the proposed unmanned aircraft systems. Aerial Robotics is 

committed to a safe and responsible utilization of this technology.
If additional information is needed or if there are any questions regarding this petition for 

exemption please contact the applicant at:

The name and address of the applicant are:

Aerial Robotics, LLP

3115 US HWY 421 N

Frankfort, KY 40601

ATTN: William A Dickerson

Cell: 502-418-0969

Email: bill@aerialrobotics.com

www.aerialrobotics.com