UNITED STATES OF AMERICA DEPARTMENT OF 

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LITTLEBIRDS VIEW FOR AN EXEMPTION SEEKING RELIEF 

FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATION SECTIONS 91.7(a), 91.121, 91.151(b), 

91.203(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 

91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF 

THE X-10 AND INSPIRE 1 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 

Submitted by; 

Robert Patton

5549 Old Plank Rd. Iron Station, NC 28080

Submitted on February 12, 2015

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CONTENTS

 Page 

SUMMARY .........................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER ..................4 

BACKGROUND ..................................................................................5 

BASIS FOR PETITION .......................................................................6

 NAME AND ADDRESS OF PETITIONER........................................8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

LITTLEBIRDS VIEW SEEKS EXEMPTION ....................................8

THE EXTENT OF RELIEF LITTLEBIRDS VIEW SEEKS AND THE 

REASON LITTLEBIRDS VIEW SEEKS THE RELIEF ...................13

THE REASONS WHY GRANTING LITTLEBIRDS VIEW'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ...................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY ............................................29

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER..........................................................................................34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT LITTLEBIRDS VIEW'S REQUEST...34

CONCLUSION...................................................................................35

3
SUMMARY

Littlebirds VIEW seeks exemption from the requirements of 14 C.F.R § 

91.7(a), 91.121, 91.151(b), 91.203(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate an Unmanned 

Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit Littlebirds 

VIEW to operate an Unmanned Aircraft System (UAS) for the aerial 

acquisitions of imagery across the United States, commercially, in 

support of construction progress, production, and forestry survey.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Littlebirds VIEW (hereinafter referred to as “LBV”) is an imaging group 

specializing in aerial photography/videography. LBV has an exceptional 

history of providing it’s clients with beneficial imagery safely and 

efficiently from manned, fixed-wing aircraft. LBV serves a wide range 

of clientele that utilize their imagery for various applications. These 

applications serve artistic, corporate, industrial, and production 

purposes. LBV has pursued their interest in construction progress with 

an emphasis on safety which has led to their acquisition of an X-10 UAS 

4
as well as an Inspire 1 UAS. Utilizing the UAS for this type of imagery 

production allows for even higher safety standards than previously 

prescribed. As set forth in this Petition, LBV seeks to operate its UAS 

equipment for the purposes of performing aerial acquisitions of imagery 

across the United States, commercially, in support of construction 

progress, production, and forestry survey.

BACKGROUND

Unmanned Aircraft System: X-10 and Inspire 1 UAS

LBV seeks an exemption to operate the LBV X-10 and Inspire 1 UAS’s 

for compensation or hire within the NAS. The X-10 and Inspire 1 UAS 

are comprised of a vertical takeoff and landing Unmanned Aircraft. The 

X-10 and Inspire 1 UAS have a maximum gross weight of less than 55 

pounds, and maximum speed of less than 50 mph. The X-10 and Inspire 

1 UAS are driven by Lithium Polymer batteries and powered by electric 

motors.

5
BASIS FOR PETITION

Petitioner, LBV pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform 

Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to operate the X-10 and

 Inspire 1 UAS in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121,

 91.151(b), 91.203(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b).

In consideration of the size, weight, speed, and limited operating area 

associated with the unmanned aircraft and its operation, LBV’s 

operation of the X-10 and Inspire 1 UAS meets the conditions of Section 

333 and therefore, will not require an airworthiness certificate in 

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

 LBV requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth

 requirements for maintenance that only apply to aircraft with an 

airworthiness certificate.

LBV submits that the requested relief is proper since an equivalent level 

of safety will be ensured. LBV will use its authorized technicians to

 perform maintenance, alterations, or preventive maintenance on the 

6
UAS using the methods, techniques, and practices prescribed in the 

manufacturer’s maintenance manual. LBV will document and maintain 

all maintenance records for the X-10 and Inspire 1 UAS.

LBV seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the X-10 and Inspire 1 UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, LBV submits that it will ensure that the X-10 and Inspire 1 

UAS are in an airworthy condition, prior to every flight, by determining 

that the UAS’s are in compliance with the X-10 and Inspire 1 Flight

 Manuals, and that the aircraft are in a condition for safe flight.

LBV also seeks an exemption from the requirements of Section 91.121,

 entitled Altimeter Settings, as the LBV UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the 

LBV UAS will be provided to the pilot in command via Global

Positioning System which downlinks to the operator for active

 monitoring of the flight path. This altitude information, combined with 

LBV’s operation of the X-10 and Inspire 1 UAS within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent 

to Section 91.121. LBV seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. LBV submits that safety will not be affected by terminating 

7
flights of the battery powered LBV UAS after 20 minutes of continuous 

flight, which would allow for five minutes of battery power remaining.

In accordance with 14 C.F.R. § 11.81, LBV provides the following

 information in support of its petition for exemption:

A. Name And Address Of The Petitioner. 

 The name and address of the Petitioner is:

 Littlebirds VIEW

 5549 Old Plank Rd. Iron Station, North Carolina 28080

B. The Specific Sections Of 14 C.F.R. From Which LBV Seeks 

Exemption. 

 1. LBV Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states 

the following:

(a) No person may operate a civil aircraft unless it is in an airworthy 

condition.

2. LBV Seeks Exemption From The Requirements Of Section 

91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the 

following, in part:

8
(a) Each person operating an aircraft shall maintain the cruising altitude 

or flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure;

3. LBV Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

4. LBV Seeks Exemption From The Requirement Of Section 

91.203(a)(1).

(a) Except as provided in Sec. 91.715, no person may operate a civil 

aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with this subparagraph (except a 

special flight permit, a copy of the applicable operations specifications 

issued under Sec. 21.197(c) of this chapter, appropriate sections of the 

air carrier manual required by parts 121 and 135 of this chapter 

9
containing that portion of the operations specifications issued under Sec. 

21.197(c), or an authorization under Sec. 91.611) must have on it the 

registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned 

special identification number before 10 days after that number is first 

affixed to the aircraft. A revised airworthiness certificate having on it an 

assigned special identification number, that has been affixed to an 

aircraft, may only be obtained upon application to an FAA Flight 

Standards district office.

5. LBV Seeks Exemption From The Requirement Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the 

following: Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this 

part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed 

in part 43 of this chapter.

6. LBV Seeks Exemption From The Requirements Of Section 

91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the 

following:

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized 

under § 43.7 of this chapter.

10
7. LBV Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may 

operate an aircraft

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by § 43.7 

of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

8. LBV Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), 

state the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for 

the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

11
(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives and safety 

directives including, for each, the method of compliance, the 

airworthiness directive or safety directive number and revision date. If 

the airworthiness directive or safety directive involves recurring action, 

the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the 

periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be 

retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired and 

the aircraft is approved for return to service.

12
C. The Extent Of Relief LBV Seeks And The Reason LBV Seeks The 

Relief.

1. Extent of Relief LBV Seeks And The Reason LBV Seeks Relief 

From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow LBV to determine that the X-10

 and Inspire 1 UAS’s are in an airworthy condition prior to every flight

 by ensuring that the UAS’s are in compliance with the X-10 and Inspire 

1 Flight Manuals, and that the aircraft are in a condition for safe flight.

LBV seeks the requested relief because the X-10 and Inspire 1 UAS’s do 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. Therefore, LBV will ensure that the X-10 and Inspire 1

 UAS’s are in an airworthy condition based upon its compliance with the

 operating documents prior to every flight.

2. Extent of Relief LBV Seeks And The Reason LBV Seeks Relief 

From Section 91.121.

Relief from Section 91.121 entitled Altimeter settings, may be required 

to allow flight operations of the X-10 and Inspire 1 UAS, which utilizes 

GPS equipment that downlink altitude information to the operator. 

Safety will be maintained as a result of the X-10 and Inspire 1 UAS’s 

altitude readout via GPS equipment, and LBV’s operation of the X-10 

and Inspire 1 UAS within visual line of sight, at or below 400 feet AGL.

13
3. Extent Of Relief LBV Seeks And The Reason LBV Seeks Relief 

From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in

 VFR conditions, is requested to the extent required to allow flights of 

the battery powered X-10 and Inspire 1 UAS during daylight hours in

 visual meteorological conditions, under visual flight rule conditions, to 

continue for a total duration of 20 minutes, which 

will ensure that the UAS will land with five minutes of battery power 

remaining. LBV seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered

 X-10 and Inspire 1 UAS will constrain the aerial acquisition flight 

operations that LBV proposes to conduct pursuant to this Petition.

The technical specifications of the X-10 and Inspire 1 UAS, the X-10

 and Inspire 1 Flight Manuals, and LBV’s proposed operating 

limitations, ensure that LBV will safely operate the battery powered 

X-10 and Inspire 1 UAS during daylight hours in visual flight rule 

conditions, for a total flight duration of 20 minutes, landing with five 

minutes of battery power remaining.

4. Extent Of Relief LBV Seeks And The Reason LBV Seeks Relief 

From Sections 91.203(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), And 91.417(a) & (b).

14
Since Sections 91.203(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness 

certificate, LBV requests relief from these Sections because the X-10 

and Inspire 1 UAS do not require an airworthiness certificate.The X-10 

and Inspire 1 UAS meets the conditions of Section 333 of the FMRA for 

operation without an airworthiness certificate. LBV will use authorized 

technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices 

prescribed in the manufacturer’s maintenance manual. Furthermore,

LBV will document and maintain all maintenance records for the X-10 

and Inspire 1 UAS.

D. The Reasons Why Granting LBV’s Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A 

Whole.

Granting the present Petition will further the public interest by allowing 

LBV to safely, efficiently, and economically perform aerial acquisitions 

of imagery across the United States, commercially, in support of 

construction progress, production, and forestry survey. Additionally, use 

of the X-10 and Inspire 1 UAS will decrease congestion of the NAS, 

reduce pollution, and provide benefits to the economy. The benefits of 

LBV’s proposed operation the X-10 and Inspire 1 UAS will be realized 

15
without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisition of 

Imagery

 LBV submits this Petition to commercially operate the X-10 and 

Inspire 1 UAS and perform aerial acquisition of imagery throughout the 

United States, in support of construction progress, production, and 

forestry survey. The X-10 and Inspire 1 UAS will provide safe, 

efficient, and economical aerial acquisition to further each of these areas, 

all of which are beneficial to the well-being of the general public.

The specific operations that LBV will perform with the X-10 and Inspire 

1 UAS demonstrate how the requested exemption will directly benefit 

the above referenced areas and the public. In regard to the construction 

progress, unmanned aircraft equipped with photographic equipment are 

able to give contractors and skilled laborers a unique perspective on their 

projects throughout every stage of construction. These craft can be put to 

use to relay real-time imaging of the exterior of a building, reaching 

areas and vantages that were previously difficult if not impossible to 

attain. This allows crews to scan the work in progress for any errors or 

16
inconsistencies, and to correct those issues before any danger might be 

posed to workers or the public. 

In regards to forestry, the X-10 and Inspire 1 UAS can survey large 

tracts of land and forested areas in a short period of time. The resulting 

data could be used for Forestry Department project planning, fire survey 

operations and more. Mapping technology is yet another area in which 

the use of these aircraft provides a valuable public service.

2. The Public Will Benefit From Decreased Congestion Of The 

NAS

 The X-10 and Inspire 1 UAS is battery powered and serves as a 

safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount 

of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of an X-10 and Inspire 1 UAS would reduce the amount 

of manned aircraft in the NAS, reduce noise and air pollution, as well as 

increase the safety of life and property in the air and on the ground.

By reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will 

17
be reduced. The X-10 and Inspire 1 UAS does not require an airport to 

takeoff or land. A reduction of manned aircraft conducting aerial survey 

missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations.

3. The Pubic Will Benefit From The Safety And Efficiency Of 

The X-10 and Inspire 1 UAS.

Conducting aerial acquisitions with the X-10 and Inspire 1 UAS, instead 

of manned aircraft will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial 

survey flight operations. Perhaps more importantly are the obvious 

implications of the reductions in substantial risk to life and property in 

the air and on the ground which is usually associated with traditional 

manned aircraft when used in these operations.

4. Performing Aerial Acquisition Operations With The X-10 

and Inspire 1 UAS Will Benefit The Economy.

 Operating the X-10 and Inspire 1 UAS provides an economical 

alternative to using manned aircraft to conduct aerial acquisitions. This 

allows US based LBV to remain competitive in their field and contribute 

18
to the growth of the US economy. Not only will the public benefit from 

the job stability provided by a profitable company like LBV, but the 

imagery acquired via LBV can dramatically benefit the specific target 

areas in which it is utilized. Inspectors, working with trained pilot 

operators, would have the ability to view a structure from virtually any 

exterior angle at various stages of construction. This previously 

unattainable, “bird’s-eye” view could identify areas in which a danger to 

public safety exists. In the case of projects that are moving ahead 

according to the established code and safety requirements, the use of 

unmanned craft would serve to streamline the inspection process. This 

allows inspectors to cover more projects in a shorter period of time, and 

allows contractors to move forward without undue delay. Both results 

translate into lowered costs for the public, both on the side of tax dollars 

saved and lowered construction costs.

5. There Are No Privacy Issues.

LBV’s proposed operation of the X-10 and Inspire 1 UAS will not 

implicate any privacy issues. The X-10 and Inspire 1 UAS will be 

19
operated in accordance with all Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. § 91.119. Additionally, 

the X-10 and Inspire 1 UAS will not be operated closer than 500 feet to 

any person, vessel, vehicle, or structure, which is not directly involved in 

the operation.

E. The Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety, Or How The Exemption Would Provide A Level Of 

Safety At Least Equal To That Provided By The Rule From Which 

LBV Seeks Exemption.

1. Reasons Why The X-10 and Inspire 1 UAS Meets The Conditions 

Of The FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333.

In consideration of the size, weight, speed, and limited operating area 

associated with the unmanned aircraft and their operation,LBV’s 

operation of the X-10 and Inspire 1 UAS meets the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in 

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

Section 333 provides authority for a UAS to operate without 

airworthiness certification and sets forth requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security. FMRA Section 

333 states the following, in part:

20
(a) In General.--Notwithstanding any other requirement of this subtitle, 

and not later than 180 days after the date of enactment of this Act, the 

Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this 

Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under 

this section that certain unmanned aircraft systems may operate safely in 

the national airspace system, the Secretary shall establish requirements 

for the safe operation of such aircraft systems in the national airspace 

system.

In seeking this exemption, LBV submits that the X-10 and Inspire 1

 UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the X-10 and Inspire 1 UAS;

(b) the pilot certification requirement; and (c) the specific operating 

(c) limitations.

21
a. The Specifications Of The X-10 and Inspire 1 UAS Demonstrate 

their Safe Characteristics.

The X-10 and Inspire 1 UAS do not create a hazard to users of the NAS

 or the public, or otherwise pose a threat to national security considering

 its size, weight, speed, and operational capability.

i. Technical Specifications Of The X-10 and Inspire 1 UAS.

The technical specifications of the X-10 and Inspire 1 UAS are in 

Exhibit C and D. Exhibit C and D contains proprietary information and 

is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

ii. The X-10 and Inspire 1 UAS Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area.

A complete description of the methods of navigation of the X-10 and 

Inspire 1 UAS is provided in Exhibit C and D. Exhibits C and D contain

 proprietary information and is to be held in a separate file pursuant to 

14 C.F.R. § 11.35(b).

iii. The X-10 and Inspire 1 UAS Is Designed For Automatic Return 

To Launch In The Event Of Loss Of The Control Link Or 

Navigation.

A complete description of the X-10 and Inspire 1 UAS’s automatic

 return to launch function in the event of a break in communication or 

loss of telemetry data is attached in Exhibit C and D. Exhibit C and D

 contains proprietary information and is to be held in a separate file

22
 pursuant to 14 C.F.R. § 11.35(b).

b. Flight Operations Of The X-10 and Inspire 1 UAS Are Limited To 

The Line Of Sight Of A Commercially Rated Certificated Pilot.

LBV will only utilize commercially certificated pilots who possess a 

valid second class airman medical certificate to act as a pilot in 

command of the X-10 and Inspire 1 UAS. The pilot in command must 

complete the X-10 or Inspire 1 UAS training and qualification, as posted 

in LBV’s Flight Operations Manual in Exhibit A. Exhibit A contains

 proprietary information and is to be held in a separate file pursuant to

 14 C.F.R. § 11.35(b).

c. Flights Of The X-10 and Inspire 1 UAS Will Be Conducted 

Pursuant To Specific Operating Limitations.

In seeking this exemption, LBV proposes to commercially operate the 

LBV UAS to perform aerial acquisitions of imagery across the United 

States, in support of construction progress, production, and forestry 

survey, pursuant to the following specific operating limitations:

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

following aircraft described in the operator’s manual which are multi 

rotor aircraft weighing less than 55 pounds: X-10 and Inspire 1 

Unmanned Aircraft System. 

2) The UAS may not be flown at an indicated airspeed exceeding 50 

miles per hour.

3) The UAS must be operated at an altitude of no more than 400 feet 

above ground level (AGL), as indicated by the procedures specified in 

23
the operator’s manual. All altitudes reported to ATC must be in feet 

AGL.

4) The UAS must be operated within visual line of sight of the pilot in 

command at all times. This requires the pilot in command to be able to 

use human vision unaided by any device other than corrective lenses, as 

specified on the FAA-issued airman medical certificate.

5) The pilot in command must be designated before the flight and cannot 

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

6) The operator’s manual and this grant of exemption must be 

maintained 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 operator’s manual, the 

conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its 

operator’s manual. The operator may update or revise its operator’s 

manual. 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. 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 amendment 

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the 

operator’s manual.

7) Prior to each flight the pilot in command 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. All 

maintenance and alterations must be properly documented in the aircraft 

records.

24
8) Any UAS that has undergone maintenance or alterations that affect 

the UAS operation or flight characteristics must undergo a functional 

test flight in accordance with the operator’s manual. The pilot in 

command 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 

operator’s manual.

9) The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant 

preflight inspection sections of the operator’s manual.

10) The operator must follow the manufacturer’s UAScomponent, 

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.

11) LBV must carry out their maintenance, inspections, and record 

keeping requirements in accordance with the operator’s manual. 

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 UAS technician or pilot in command 

returning the UAS to service.

12) LBV UAS technicians must receive and document training 

referenced in the operator’s manual.

13) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

14) LBV maintenance personnel must make a record entry in the UAS 

logbook or equivalent document of the corrective action taken against 

discrepancies discovered between inspections.

15) The pilot in command must possess at least a commercial pilot 

certificate and a second-class airman medical certificate. The pilot in 

command must also meet the flight review requirements specified in 14 

25
C.F.R. § 61.56 in an aircraft in which the pilot in command is rated on 

his or her pilot certificate.

16) The operator may not permit any pilot in command to operate unless 

that pilot in command has demonstrated, through the training and 

currency requirements set forth in the operator’s manual, that the pilot in 

command 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.

17) UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions. 

18) The UAS may not operate within 5 nautical miles of the airport 

reference point as denoted on a current FAA-published aeronautical 

chart. 

19) The UAS 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 pilot in command.

20) If the UAS loses communications or loses its signal, the UAS must 

return to a pre-determined location within the private or controlledaccess property and land, or be recovered in accordance with the 

operator’s manual.

21) The pilot in command must abort the flight in the event of 

unpredicted obstacles or emergencies in accordance with the operator’s 

manual.

22) The pilot in command is prohibited from beginning a UAS flight 

unless there is enough power to fly to the first point of intended landing 

prior to utilizing battery reserve power.

23) The operator must obtain an Air Traffic Organization issued 

Certificate of Waiver or Authorization prior to conducting any 

26
operations under this grant of exemption. This Certificate of Waiver will 

also require the operator to request issuance of a Notice to Airman not 

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

operation.

24) All aircraft operated in accordance with this exemption must be 

identified by serial number.

25) Before conducting operations, the radio frequency spectrum used for 

operation and control of the UAS must comply with the Federal 

Communications Commission or other appropriate government 

oversight agency requirements.

26) The documents required under 14 C.F.R. 91.9 must be available to 

the pilot in command any time the aircraft is operating. These 

documents must be made available to the Administrator or any law 

enforcement official upon request.

27) The UAS must remain clear and yield the right of way to all other 

manned aviation operations and activities at all times.

28) The UAS may not be operated by the pilot in command from any 

moving device or vehicle. 

29) Ultimately, it is the pilot in command’s responsibility to maintain the 

minimum safe altitudes required by § 91.119.

30) Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from 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 UAS, 

flight operations must cease immediately and/or; 

27
b. the aircraft is operated near vessels, vehicles or structures where 

the land owner/controller has granted permission and the pilot in 

command has made a safety assessment of the risk of operating 

closer to those objects and; 

c. operations near the pilot in command do not present an undue 

hazard to the pilot in command, per § 91.119(a). 

31) All operations shall be conducted over private or controlled-access 

property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained prior to the beginning of every flight.

32) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by the 

applicable Certificate of Waiver 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 per instructions contained 

on the NTSB Web site.

2.Reasons Why An Exemption From The Requirements Of Section 

91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be 

maintained because prior to every flight, LBV will ensure that the X-10

 and Inspire 1 UAS are in an airworthy condition based upon the X-10

 and Inspire 1 UAS compliance with its operating documents.

3. Reasons Why An Exemption From The Requirements Of Section 

91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the X-10 and Inspire 

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UAS will be provided to the pilot in command for active monitoring of 

the flight path. This altitude information, combined with LBV’s 

operation of the X-10 and Inspire 1 UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section

 91.121. The altitude information will be generated onboard the aircraft.

 Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy by the UAS pilot in command.

4. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety

 established by 14 C.F.R. Section 91.151(b) as a result of (1) the 

technical specifications of the X-10 and Inspire 1 UAS; (2) the

 limitations on the proposed flight operations; and (3) the location of the

 proposed flight operations. LBV will ensure that it can safely operate t

he battery powered X-10 and Inspire 1 UAS during daylight hours, in 

VFR conditions, for a total flight duration of no more than 20 minutes, 

resulting in a landing with five minutes of battery power remaining.

Previous exemptions granted by the FAA concerning

 Section 91.151 establish that safety is not adversely affected when the

 technical characteristics and operating limitations of the UAS are 

considered. Relief has been granted for manned aircraft to operate at less 

29
than the minimums prescribed in Section 91.151, including Exemption

 Nos. 2689, 5745, and 10650. 

5. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) 

Would Not Adversely Affect Safety.

In seeking this exemption, LBV submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration 

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)

(1) & (a)(2), and 91.417(a) & (b) will be met because LBV will use its 

trained technicians to perform maintenance, alterations, or preventive

 maintenance on the unmanned aircraft system using the methods, 

techniques, and practices prescribed in the manufacturer’s maintenance

 manual. LBV will document and maintain all maintenance records for 

the X-10 and Inspire 1 UAS.

Since the X-10 and Inspire 1 UAS will be inspected as prescribed by the

 manufacturer’s maintenance manual, LBV will maintain the equivalent

 level of safety established by Sections 91.405(a), 91.409(a)(1), and

 91.409(a)(2). The Flight Manual For The X-10 and Inspire 1 UAS sets

 forth airworthiness requirements for the UAS, including preflight and 

post flight inspections.

The exemption sought will not adversely affect safety because LBV will

 perform maintenance, alterations or preventive maintenance on the

30
 UAS using the methods, techniques, and practices prescribed by the

 manufacturer’s maintenance manual. 

A complete description of the X-10 and Inspire 1 UAS airworthiness and 

maintenance requirements is contained in Exhibit C and D. Exhibit C 

and D contains proprietary information and is to be held in a separate

 file pursuant to 14 C.F.R. § 11.35(b).

 The exemption sought would maintain an equivalent level of safety

 established by Sections 91.407, 91.417(a) and 91.417(b), because all 

maintenance of the X-10 and Inspire 1 UAS will be performed by LBV 

trained technicians, who will document and maintain maintenance 

records for the X-10 and Inspire 1 UAS. LBV submits that safety will 

not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b).

 The FAA has previously granted relief specific to UAS in circumstances 

similar, in all material respects, to those presented herein (e.g.Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138).

7. The FAA May Prescribe Any Other Conditions For Safe 

Operation.

In accordance with Section 333 of the FAA Modernization and Reform

 Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions,

 LBV requests that the FAA prescribe special conditions for the intended

31
 operation of the X-10 and Inspire 1 UAS, which contain such safety 

standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 

14 C.F.R §§ 91.7 (a), 91.121, 91.151(b), 91.203(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

conditions will permit safe operation of the UAS for the limited purpose 

of conducting aerial acquisitions over certain rural areas of the United 

States. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or

 otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe

 operation of the UAS in the NAS.

 The Administrator may prescribe special conditions pursuant to 14

C.F.R.§ 21.16, for operation of the X-10 and Inspire 1 UAS, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features 

of the aircraft. Section 21.16, entitled Special Conditions, states the

following:

If the FAA finds that the airworthiness regulations of this subchapter do

 not contain adequate or appropriate safety standards for an aircraft,

32
 aircraft engine, or propeller because of a novel or unusual design feature 

of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments for the product. The special conditions are 

issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds 

necessary to establish a level of safety equivalent to that established in 

the regulations. See 14 C.F.R. § 21.16.

In accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for LBV’s intended operation of the 

X-10 and Inspire 1 UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to

 that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections

 91.7(a), 91.121, 91.151(b), 91.203(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a)& (b).

A. A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which LBV Seeks Exemption: 

Littlebirds VIEW seeks exemption from the requirements of 14 

C.F.R Sections 91.7(a), 91.121, 91.151(b), 91.203(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption LBV Seeks: 

This exemption will permit Littlebirds VIEW to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial 

acquisitions of imagery across the United States, commercially, in 

support of construction progress, production, and forestry survey. 

33
B. Any Additional Information, Views, Or Arguments Available 

To Support LBV’s Request. 

This Petition is made pursuant to the FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333, which directs the Secretary

 of Transportation to determine if certain UAS may operate safely in the 

NAS. As such, LBV’s request for exemption may be granted pursuant to 

the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above. FMRA Section 333 sets forth the requirements for considering

 whether a UAS will create a hazard to users of the NAS or the

 public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without

airworthiness certification. As discussed in detail above, LBV will 

operate the X-10 and Inspire 1 UAS safely in the NAS, without 

creating a hazard to users of the NAS, or the public, or otherwise 

pose a threat to national security.

34
CONCLUSION

 LBV seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the X-10 and Inspire 1 UAS commercially, 

without an airworthiness certificate, for the purpose of conducting aerial 

acquisitions to support of construction progress, production, and forestry 

survey across the United States.

By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing LBV 

to safely, efficiently, and economically operate the X-10 and Inspire 1 

UAS commercially within the NAS.

In accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, LBV respectfully 

requests that the Administrator grant this Petition for an exemption from

 the requirements of 14 C.F.R Sections 91.7(a), 91.121, 91.151(b), 

91.203(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit LBV to operate the X-10 and Inspire 1 UAS 

commercially for the purpose of conducting aerial acquisitions in 

support of construction progress, production, and forestry survey.

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