AFS-15-047-E 

Exemption No. 11184 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

In the matter of the petition of 

LOWCOUNTRYRC, CORPORATION

for an exemption from part 21, Subpart H; 

§§ 45.23(b); 61.113(a) and (b); 91.7(a); 

91.9(b)(2); 91.103(b); 91.109; 91.119; 

91.121; 91.151(a); 91.203(a) and (b); 

91.405(a); 91.407(a)(1); 91.409(a)(2); 

and 91.417(a) and (b) of Title 14, Code of 

Federal Regulations 

Regulatory Docket No. FAA-2014-0803

GRANT OF EXEMPTION 

By letter dated September 29, 2014, Mr. Anthony J. Marino, President of 

LowCountryRC, Corporation (hereinafter Petitioner or Operator), 3104 River Drive, 

Thunderbolt, GA 31404, petitioned the Federal Aviation Administration (FAA) for an 

exemption from part 21, Subpart H; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The 

exemption would allow the petitioner to operate the DJI S1000 unmanned aircraft system 

(UAS) to conduct high definition aerial photography for the inspection of towers and 

structures. 

The petitioner supports its request with the following information: 

The petitioner proposes to operate the DJI S1000 UAS primarily to conduct high definition 

aerial photography primarily for the inspection of towers and structures, although a potential 

exists to aid law enforcement personnel and first responders in search and rescue operations. 

See Appendix A for the petition submitted to the FAA, including the regulations from which 

the petitioner seeks an exemption. 

The petitioner has provided the following information to support its request for an exemption, 

which includes proprietary supporting documents: 
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1. A2 Flight Control System User Manual V1.20 

2. A2 Product Release Notes 

3. Low Country RC Flight Manual 12-14-2014 

4. Low Country RC Maintenance Manual 12-14-2014 

5. Low Country RC Futaba Specification sheet 

6. DJI S1000 User Manual 

7. DJI S1000 Product Release Notes 

8. WooKong-M Quick Start Guide 

9. WooKong-M Product Release Notes 

10. Zenmuse Z15 User Manual 

11. Zenmuse Z15 Product Release Notes 

The FAA evaluated the petition and determined it was not precedent setting. Therefore, a 

summary of the petition was not published in the Federal Register for public comment.

The FAA’s analysis is as follows: 

The FAA has organized its analysis into four sections: (1) UAS, (2) the UAS pilot in 

command (PIC), (3) the UAS operating parameters, and (4) the public interest. 

UAS 

The petitioner requested relief from 14 CFR part 21, Certification Procedures for Products 

and Parts; specifically, Subpart H, Airworthiness Certificates. In accordance with the 

statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC § 44704, and 

in consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

Tower and structure inspections are hazardous and present unique difficulties for persons 

conducting inspections and maintenance of this infrastructure. The inspections are normally 

conducted utilizing personnel to physically inspect the tower and structure. Manned 

helicopters may also be used to transport inspection personnel to the top of the tower so that a 

physical inspection may be conducted. The petitioner plans to utilize a UAS to provide high 

definition aerial photography to minimize the need for inspectors to personally climb such 

structures. Manned helicopters assisting in tower and structure inspections can weigh 6,000 

pounds or more and are operated by an onboard pilot, in addition to other onboard 

crewmembers, as necessary. The petitioner’s unmanned aircraft (UA) will weigh less than 55 

pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight and restricted sterile area significantly reduces the potential for 

harm to participating and nonparticipating individuals or property in the event of an incident 

or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated 
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with the use of a UA for the inspection operation. In addition, utilizing UAS to conduct tower 

inspections will reduce the need for inspection personnel to perform this hazardous activity. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

UA carries no fuel, and therefore the risk of fire following an incident or accident due to fuel 

spillage is eliminated. 

The petitioner’s UAS has the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. 

The UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link 

event with a pre-coordinated, predictable, automated flight maneuver, and manual flight 

control functionality as a backup. These safety features provide an equivalent level of safety 

compared to a manned aircraft performing a similar operation. 

This exemption does not require an electronic means to monitor and communicate with other 

aircraft, such as transponders or sense and avoid technology. Rather the FAA is mitigating the 

risk of these operations by placing limits on altitude, requiring stand-off distance from clouds, 

permitting daytime operations only, and requiring that the UA be operated within visual line 

of sight (VLOS) and yield right of way to all other manned operations. Additionally, the 

exemption provides that the operator will request a notice to airmen (NOTAM) prior to 

operations to alert other users of the National Airspace System (NAS). 

Regarding the petitioner’s requested relief from 14 CFR § 45.23(b), Display of marks, the 

petitioner requests this relief stating that the UA does not have a cabin, cockpit or pilot station 

on which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft. The petitioner’s UAS will not be certificated under § 21.191, and 

therefore the “experimental” marking is not required. Since the petitioner’s UAS will not be 

certificated under § 21.191, a grant of exemption for § 45.23(b) is not necessary. Markings 

must be as large as practicable per § 45.29(f). 

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405(a) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(2) Inspections, and 91.417(a) and (b) Maintenance records, the FAA has 

determined that relief from § 91.409(a)(1) is also necessary, because it is an alternate 

inspection requirement of § 91.409(a)(2). As provided in the operating documents, the 

operator will ensure that the UAS is in working order prior to initiating flight, perform 

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

Therefore, the FAA finds that adherence to the petitioner’s operating documents and the 

conditions and limitations below, describing the requirements for maintenance, inspection, 

and recordkeeping, are sufficient to ensure that safety is not adversely affected. Accordingly, 

the FAA finds that exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

and 91.417(a) and (b) is warranted. 
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UAS PIC 

Regarding the petitioner’s requested relief from 14 CFR § 61.113(a) and (b) Private pilot 

privileges and limitations, the FAA must consider the appropriate level of pilot certification 

for the petitioner’s proposed operations. The petitioner proposed to operate its UAS with 

pilots having been vetted and trained through a self-administered flight training program, 

based upon completion of an FAA-approved ground school. The petitioner states that “while 

helpful, a pilot license will not ensure remote control piloting skills.” Although Section 333 

provides limited statutory flexibility relative to 49 USC § 44704 for the purposes of 

airworthiness certification, it does not provide flexibility relative to other sections of title 49. 

The FAA does not possess the authority to exempt from the statutory requirement to hold an 

airman certificate, as prescribed in 49 USC § 44711. For further information see Exemption 

No. 11110 (Trimble Navigation, Ltd). 

The FAA is also requiring a pilot certificate for UAS operations because pilots holding an 

FAA issued private or commercial pilot certificate are subject to security screening by the 

Department of Homeland Security that certificated airmen undergo. As previously 

determined by the Secretary, the requirement to have an airman certificate ameliorates 

security concerns over civil UAS operations conducted in accordance with Section 333. 

Given these grounds, the FAA must determine the appropriate level of pilot certification for 

the petitioner’s proposed operation. 

Under current regulations, civil operations for compensation or hire require a PIC holding a 

commercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in 

accordance with pertinent parts of 14 CFR § 61.113(a) and (b), a pilot holding a private pilot 

certificate cannot act as a PIC of an aircraft for compensation or hire unless the flight is only 

incidental to a business or employment. However, in Grant of Exemption No. 11062 to 

Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate 

operating the Astraeus UAS would not adversely affect operations in the NAS or present a 

hazard to persons or property on the ground. Additionally, as previously determined by the 

Secretary of Transportation, the requirement to have an airman certificate ameliorates security 

concerns over civil UAS operations conducted in accordance with Section 333. 

The petitioner proposes to operate with a pilot who does not possess an FAA issued pilot 

certificate. This is similar to other petitions for exemption previously filed with and 

considered by the FAA. As in Exemption Nos. 11062 (Astraeus) and 11138 (Douglas 

Trudeau), the FAA has analyzed the petitioner’s proposed operation and determined it does 

not differ significantly from these grants of exemption. The petitioner plans to operate in the 

NAS over controlled access property with the permission of the property owner/controller, 

while also limiting property access to consenting participants while operations are underway. 

Given: 1) the similar nature of the petitioner’s proposed operating environment to that of 

Astraeus and Trudeau, 2) the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial requirements [ref: Exemption No. 11062], and 3) the 

airmanship skills necessary to operate the UAS, the FAA finds that the additional manned 
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airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for the petitioner’s proposed operations. Therefore, the FAA finds 

that a PIC holding a private pilot certificate and a third-class airman medical certificate is 

appropriate for the proposed operations. 

With regard to the airmanship skills necessary to operate the UAS, the petitioner has proposed 

a training program, as well as in-field operations in preparation for operating the UAS for the 

purpose of conducting the operations described in the operating documents. The petitioner 

states that the PIC must have accumulated and logged a minimum of twenty hours as the UAS 

pilot operating the make and model of the UAS to be utilized for the operations and three 

take-offs and three landings in the preceding 90 days. The conditions and limitations require 

that the PIC must maintain an understanding of all operational features including normal, 

abnormal, and emergency procedures of the UAS, as well as material in the operating 

documents. These and other requirements are included in the conditions and limitations 

below. 

Additionally, the conditions and limitations below stipulate that the petitioner may not permit 

any PIC to operate unless that PIC has demonstrated through the petitioner’s training and 

currency requirements that the PIC is able to safely operate the UAS in a manner consistent 

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

maneuvers and maintaining appropriate distances from people, vessels, vehicles, and 

structures. 

In conclusion, the FAA finds that a PIC holding a private pilot certificate and a third-class 

airman medical certificate, and who has completed the petitioner’s pilot vetting and training 

programs, can conduct the proposed UAS operations without adversely affecting the safety of 

the NAS and persons or property on the ground. Upon consideration of the overall safety case 

presented by the petitioner, the FAA finds that granting the requested relief from 

14 CFR § 61.113(a) and (b), is warranted. 

The petitioner indicates it will supplement its proposed operation(s) with a camera operator, 

“such that, at a minimum, two LOCORC personnel govern the safe flight of an LOCORC 

aircraft at all times.” However, the petitioner did not indicate whether it will supplement its 

proposed operation(s) with a visual observer (VO). The FAA notes that one of the 

determinations for operations under section 333 is operation within visual line of sight 

(VLOS). As the PIC is determined to be in command of the UA, he or she must maintain 

VLOS while operating the UA. The FAA also notes that a visual observer complements the 

PIC’s capability to see and avoid other aircraft (per § 91.113), including when the PIC may be 

momentarily attending to other flying tasks (e.g., maneuvering the aircraft close to structures, 

vehicles, or other objects). The VO provides an additional level of operational safety. The 

conditions and limitations below stipulate that the PIC must ensure that the VO can perform 

the functions prescribed in the operating documents. Additionally, as discussed in Exemption 

No. 11109 to Clayco, Inc. there are no regulatory requirements for visual observer medical 

certificates. Although a medical certificate is not required for a VO, the UA must never be 

operated beyond the actual visual capabilities of the VO, and the VO and PIC must have the 
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ability to maintain VLOS with the UA at all times. It is the responsibility of the PIC to be 

limit operations of the UA to distances within the visual capabilities of both the PIC and VO. 

Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not consider a 

medical certificate necessary for the VO. 

The FAA considers the PIC to be designated for the duration of the flight. Therefore, per the 

conditions and limitations below, the PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. 

UAS Operating Parameters 

Regarding the petitioner’s requested relief from 14 CFR § 91.7(a) Civil Aircraft 

Airworthiness, the petitioner’s request states that “no such certificate will be applicable in the 

form contemplated by the” FAA’s regulations. As such, the petitioner states the regulation is 

inapplicable. While the petitioner’s UAS will not require an airworthiness certificate in 

accordance with 14 CFR part 21, Subpart H, the FAA considers the petitioner’s compliance 

with its operating documents to be a sufficient means for determining an airworthy condition. 

Therefore, relief from § 91.7(a) is granted. The petitioner is still required to ensure that its 

aircraft is in an airworthy condition – based on compliance with the operating documents 

prior to every flight, and as stated in the conditions and limitations below. 

Additionally, in accordance with 14 CFR § 91.7(b), the PIC of the UAS is responsible for 

determining whether the aircraft is in a condition for safe flight and the FAA finds that the 

PIC can comply with this requirement. 

Regarding the petitioner’s requested relief from 14 CFR § 91.9(b)(2) Civil aircraft flight 

manual, marking, and placard requirements and 14 CFR § 91.203(a) and (b) Civil aircraft: 

Certifications required, the FAA has previously determined, as in grant of Exemption 

No.11062 to Astraeus, that relief from these sections is not necessary. Relevant materials may 

be kept in a location accessible to the PIC in compliance with the regulations. 

The petitioner requested relief from 14 CFR § 91.103(b), Preflight Action. The petitioner’s 

operating documents require the PIC to take certain actions before flight to ensure the safety 

of the flight. Although there will be no approved Airplane or Rotorcraft Flight Manual 

available, the FAA believes that the petitioner can comply with the other applicable 

requirements in 14 CFR § 91.103(b)(2). The procedures outlined in the operating documents, 

address the FAA’s concerns regarding compliance with § 91.103(b). The PIC will take all 

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

distances/conditions, and aircraft performance data before initiation of flight. The FAA has 

imposed stricter requirements with regard to visibility and distance from clouds; this is to both 

keep the UA from departing VLOS and to preclude the UA from conflicting with other 

aircraft operating in the NAS. The FAA also notes the risks associated with sun glare; the 

FAA believes that the PIC’s and VO’s ability to still see other air traffic, combined with the 

PIC’s ability to initiate a return-to-home sequence, are sufficient mitigations in this respect. 
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The PIC will also account for all relevant site-specific conditions in his or her preflight 

procedures. Therefore, the FAA finds that exemption from 14 CFR § 91.103 is not necessary. 

Additionally, the petitioner requested relief from 14 CFR § 91.109 Flight instruction; 

Simulated instrument flight and certain flight tests. The petitioner did not describe training 

scenarios in which a dual set of controls would be utilized or required, i.e. dual flight 

instruction, provided by a flight instructor or other company-designated individual requiring 

that individual to have fully functioning dual controls. Rather, the petitioner intends to 

accomplish training as referenced in the operating documents. Furthermore, the FAA is 

requiring that the petitioner’s PICs possess at least a private pilot’s certificate. Also, this 

exemption will require that training operations only be conducted during dedicated training 

sessions. The FAA finds that safety will not be adversely impacted if the petitioner follows 

the self-administered training and internal procedures outlined in the operating documents, in 

conjunction with the PIC meeting the flight review requirements specified in 14 CFR § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate. As such, the FAA finds 

that the petitioner can conduct its operations without the requested relief from § 91.109. 

Regarding the petitioner’s requested relief from 14 CFR § 91.119, Minimum safe altitudes, 

the petitioner did not specify the paragraph(s) of 14 CFR § 91.119 from which they require 

relief. Relief from § 91.119(a), which requires operating at an altitude that allows a safe 

emergency landing if a power unit fails, is not granted. The FAA expects the petitioner to be 

able to perform an emergency landing without undue hazard to persons or property on the 

surface if a power unit fails. Relief from 14 CFR § 91.119(b), operation over congested areas, 

is not granted because the petitioner did not provide sufficient information necessary for the 

FAA to determine whether the operation poses an adverse impact to safety. 

The petitioner proposes operations in tightly controlled and limited airspace with 

predetermined, specifically marked areas of operation in sectioned off locations. Additionally, 

the petitioner will always “obtain all necessary permissions and permits” prior to each UAS 

operation. The petitioner also stipulates all operations be conducted within visual line of 

sight. With regard to persons not directly involved in the flight operation, the petitioner did 

not provide an explanation for exposing those persons to increased risk. Therefore, the FAA 

is requiring that prior to conducting UAS specific operations, all persons not essential to flight 

operations (nonparticipating persons) must remain at appropriate distances. In open areas this 

requires the UA to remain 500 feet from all persons other than essential flight personnel (i.e. 

the PIC and VO). 

The FAA has also considered that the UA in this case will weigh 55 pounds or less. If 

barriers or structures are present that can sufficiently protect nonparticipating persons from 

debris in the event of an accident, then the UA may operate closer than 500 feet to persons 

afforded such protection. The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately. When 

considering how to immediately cease operations, the primary concern is the safety of those 

nonparticipating persons. In addition, the FAA finds that operations may be conducted closer 
8 

than 500 feet to vessels, vehicles and structures when the property owner/controller grants 

such permission and the PIC makes a safety assessment of the risk of operating closer to those 

objects. 

Thus, the FAA finds that relief from § 91.119(c) is necessary because all operations will be 

conducted below 400 feet above ground level (AGL) and may be operated closer than 500 

feet from persons, vessels, vehicles, and structures as described above. Provided adherence to 

the procedures in the operating documents and the additional conditions and limitations 

outlined below, the FAA finds that relief from § 91.119(c) is warranted. Because of the 

conditions and limitations below, relief from § 91.119(d) is not applicable. 

Regarding the petitioner’s requested relief from 14 CFR § 91.121 Altimeter Settings, the UAS 

uses a global positioning system (GPS) altitude indicator rather than a barometric altimeter. 

As stated in the conditions and limitations below, the FAA requires any altitude reported to 

ATC to be in feet AGL. The petitioner may choose to set the GPS altitude indicator to zero 

feet AGL rather than local barometric pressure or field altitude before flight. Considering the 

limited altitude of the proposed operations, relief from 14 CFR § 91.121 is granted to the 

extent necessary to comply with the applicable conditions and limitations stated below. 

Regarding the petitioner’s requested relief from 14 CFR § 91.151(a) Fuel requirements for 

flight in VFR conditions, relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in 14 CFR § 91.151(a), including Exemption Nos. 2689, 5745, and 

10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811, 

10808, and 10673 for daytime, VFR conditions. The petitioner states that its UAS operations 

will be conducted “in secure areas that are strictly controlled,” with UA under 55 pounds, and 

within VLOS. These factors, combined with the petitioner’s stated intention to terminate 

flights with 25% remaining battery power, provides the FAA with sufficient reason to grant 

the requested relief from 14 CFR 91.151(a). In accordance with the conditions and limitations 

below, the PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. 

These features, combined with the lack of passengers and crew, will ensure safety in NAS 

operations and not present a hazard to persons or property on the ground. 

Additionally, in evaluating the petitioner’s proposed operating parameters with regard to 

VLOS and a safe operating perimeter, the FAA considered operations from a moving device 

or vehicle. Since the petitioner did not discuss provisions for these circumstances, the 

conditions and limitations below preclude operations from moving devices or vehicles. 

As stated in the petition, the scope of the petitioner’s proposed operation is “to provide high 

definition aerial photography with small, unmanned aircraft and lightweight UAS’s.” Further, 

the petitioner describes a broader scope of operations including “the inspection of towers and 

structures that would otherwise require climbing at great risk to the personnel involved, 

though given the stability and maneuverability, they may be used by law enforcement 
9 

personnel, search and rescue and by other first responders for other photography including 

video.” The petitioner’s operating documents and petition provided limited information to 

support inspection and imagery of towers and structures. No supporting information or 

descriptions were found to support search and rescue operations in support of first responders. 

Therefore the FAAs analysis was limited to use of UAS for the inspection and imagery of 

towers and structures. The conditions and limitations below restrict the UAS operation to this 

purpose only. 

Regarding an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization 

(COA), the majority of current UAS operations occurring in the NAS are being coordinated 

through Air Traffic Control (ATC) by the issuance of a COA. This is an existing process that 

not only makes local ATC facilities aware of UAS operations, but also provides ATC the 

ability to consider airspace issues that are unique to UAS operations. The COA will require 

the operator to request a NOTAM, which is the mechanism for alerting other users of the 

NAS to the UAS activities being conducted. The conditions and limitations below prescribe 

the requirement for the petitioner to obtain an ATO-issued COA. 

Public Interest 

The FAA finds that a grant of exemption is in the public interest. The enhanced safety and 

reduced environmental impact achieved using a UA with the specifications described by the 

petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly 

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

find that the UAS operation enabled by this exemption is in the public interest. 

The following table summarizes the FAA’s determinations regarding the relief sought by the 

petitioner: 
10 

Relief considered (14 CFR) FAA determination (14 CFR) 

21 Subpart H Relief not necessary 

45.23(b) Relief not necessary 

61.113(a) and (b) Relief granted with conditions and 

limitations 

91.7(a) Relief granted with conditions and 

limitations 

91.9(b)(2) Relief not necessary 

91.103(b) Relief not necessary 

91.109 Relief not necessary 

91.119 

Relief not granted for paragraphs (a) and 

(b); paragraph (c) granted with 

conditions and limitations; paragraph (d) 

not applicable 

91.121 Relief granted with conditions and 

limitations 

91.151(a) Relief granted from 91.151(a)(1), day, 

with conditions and limitations 

91.203(a)(b) Relief not necessary 

91.405(a) Relief granted with conditions and 

limitations 

91.407(a)(1) Relief granted with conditions and 

limitations 

91.409(a)(1)(2) Relief granted with conditions and 

limitations 

91.417(a) and (b) Relief granted with conditions and 

limitations 

The FAA’s Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, LowCountryRC, Corporation is granted an exemption 

from §§ 61.113(a) and (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1)(2), and 91.417(a) and (b) to the extent necessary to allow the petitioner to 

operate a UAS to conduct high definition aerial photography for the inspection of towers and 

structures. This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

Relative to this grant of exemption, LowCountryRC, Corporation is hereafter referred to as 

the operator. 
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The petition and the following supporting documentation are hereinafter referred to as the 

operating documents: 

1. A2 Flight Control System User Manual V1.20 

2. A2 Product Release Notes 

3. Low Country RC Flight Manual 12-14-2014 

4. Low Country RC Maintenance Manual 12-14-2014 

5. Low Country RC Futaba Specification sheet 

6. DJI S1000 User Manual 

7. DJI S1000 Product Release Notes 

8. WooKong-M Quick Start Guide 

9. WooKong-M Product Release Notes 

10. Zenmuse Z15 User Manual 

11. Zenmuse Z15 Product Release Notes 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1) Operations authorized by this grant of exemption are limited to the following aircraft 

described in the operator’s petition which is an octocopter weighing less than 55 

pounds including cameras: DJI Industries S1000 Unmanned Aircraft System. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant. 

2) UAS operations under this exemption are limited to conducting operations for the 

purpose of high definition aerial photography for the inspection of towers and 

structures. 

3) The UA may not be flown at an indicated airspeed exceeding 50 knots. 

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

(AGL). All altitudes reported to ATC must be in feet AGL. 

5) The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

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

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

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 
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capability. The VO and PIC must be able to communicate verbally at all times. The 

PIC must be designated before the flight and cannot transfer his or her designation for 

the duration of the flight. The PIC must ensure that the VO can perform the functions 

prescribed in the operating documents. 

7) The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

8) The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operating documents, the conditions and limitations herein take 

precedence and must be followed. Otherwise, the operator must follow the procedures 

as outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator's responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

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

operator must petition for an amendment to its grant of exemption. The FAA's UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

9) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

10) Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo 

a functional test flight in accordance with the operator’s manual. The PIC who 

conducts the functional test flight must make an entry in the UAS aircraft records of 

the flight. The requirements and procedures for a functional test flight and aircraft 

record entry must be added to the operating documents. 

11) The preflight inspection section in the operating documents must be amended to 

include the following requirement: The preflight inspection must account for all 
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discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operating documents. 

12) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements, with particular attention 

to flight critical components that may not be addressed in the manufacturer’s manuals. 

13) The operator must carry out their maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

and alterations must be noted in the aircraft logbook, including total flight hours, 

description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

14) The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

15) Each UAS operated under this exemption must comply with all manufacturer System 

and Safety Bulletins. 

16) The PIC must possess at least a private pilot certificate and a valid third-class airman 

medical certificate. The PIC must also meet the flight review requirements specified 

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

17) The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria, completes the operator’s training program, maintains currency 

according to the operating documents, and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

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

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

is also required to complete the operator’s training requirements. A record of training 

must be documented and made available upon request by the Administrator. Flights 

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

experience-building), are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 
14 

18) UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

19) The UA may not operate within 5 nautical miles of an airport reference point as 

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

with that airport's management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator's COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

20) The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

21) If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property (safe zone) and 

land or be recovered in accordance with the operator’s manual. 

 

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

23) The PIC is prohibited from beginning a UAS flight unless (considering wind and 

forecast weather conditions and assuming normal cruising speed) there is enough 

power to fly at normal cruising speed to the intended landing point and land the UA 

with 25% battery power remaining. 

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

25) All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 
15 

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

control of the UA must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements. 

 

27) The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

28) The UA must remain clear and yield the right of way to all other manned aviation 

operations and activities at all times. 

 

29) The UAS may not be operated by the PIC from any moving device or vehicle. 

30) The UA may not be operated over congested or densely populated areas. 

31) Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC or VO), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet 

of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the property 

owner/controller has granted permission and the PIC has made a safety 

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

c. Operations near the PIC or VO do not present an undue hazard to the PIC or 

VO, per § 91.119(a). 

32) All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. 
16 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

 

This exemption terminates on February 28, 2017, unless sooner superseded or rescinded. 

Issued in Washington, DC, on February 23, 2015. 

/s/ 

John Barbagallo 

Acting Deputy Director, Flight Standards Service 
17 

Project No.: AFS–15-047-E 

Project Officer: _______________ 

Doc No. 

ARM–1/100/: Program Office AFS–80 

Mr. Anthony J. Marino, President 

Low Country RC, Corporation 

3104 River Drive 

Thunderbolt, GA 31404