Ross Palmer

2334 Tuscan Hills Lane

Las Cruces, NM 88011

575-532-5396

rossp2@juno.com

January 21, 2016

U.S. Department of Transportation

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Submission of request for Authorization to Conduct Unmanned Aircraft Systems Operations 

Allowed by Section 333 of the FAA Modernization and Reform Act of 2012 Through the Exemption 

Process Identified Under 14 CFR Section 11.81

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, I Ross Palmer as an independent contractor and operator of 3D Robotics Iris+, and X8

sUAS, seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in 

Appendix A.

Ross Palmer

sUAS Contractor

2334 Tuscan Hills Lane

Las Cruces, NM 88011

575-532-5396

rossp2@juno.com
Contents

Description of the UAS..................................................................................................................................3

Exemption:....................................................................................................................................................3

Safety and risk assessment evaluations:.......................................................................................................4

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 ...........................................................................4

The sUAS .......................................................................................................................................................5

Aircraft Performance/Specifications:........................................................................................................5

3DR Iris+ ................................................................................................................................................5

3DR X8...................................................................................................................................................5

Operator Requirements:...............................................................................................................................6

Mandatory Operating Conditions.................................................................................................................7

Public Interest...............................................................................................................................................7

Privacy...........................................................................................................................................................8

Conclusion.....................................................................................................................................................8

APPENDIX A: ..................................................................................................................................................9

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS ......................................................9

APPENDIX B: SUMMARY OF ROSS PALMER, SECTION 333 EXEMPTION REQUEST ......................................12
Description of the UAS

1. 3D Robotics Iris+

The 3D Robotics Iris+ is a quad sUAS in a Standard X frame Quad formation.

The 3DR Iris+ features the PixHawk autopilot system with GPS navigation combined with a proven multirotor design. As part of the APM Copter family, the 3DR Iris+ uses the full range of autonomous flight 

features supported by APM Copter, including loiter, circle, return to launch, follow me, acrobatic flying 

mode, and more. Installation of free mission planning software allows the operator to run programmed 

way point missions and analyze flight data. Robust fail-safe features include, Geo-fencing; RTL; Low 

Battery; and Loss Link. 3DR Iris+ is a capable multirotor for tasks such as Aerial Photography, Aerial 

Videography, Structural inspections, and terrain mapping.

2. 3D Robotics X8

The 3D Robotics X8 is an 8 motor sUAS in a Standard X frame Quad formation.

The 3DR X8 features the APM 2.6 autopilot system and GPS navigation combined with a powerful and 

redundant multi-rotor design. As part of the APM Copter family, the 3DR X8 uses the full range of 

autonomous flight features supported by APM Copter, including loiter, circle, return to launch, follow 

me, acrobatic flying mode, and more. Installation of free mission planning software allows the operator 

to run programmed way point missions and analyze flight data. Geo-fencing, robust fail-safes, and a 

durable air frame provide preventative safety measures to give peace of mind. 3DR X8 is the most 

powerful 3DR multi-copter solution, perfect for heavy payloads, stability in high winds, and capturing 

high quality video.

Exemption:

The requested exemption would permit commercial operation of 3DR Iris+ and X8 UAS, with payload 

installed, weigh approximately 3 lbs. and 4 lbs. respectively. Both are capable of capturing still imagery, 

video, and other sensors including IR, multi-spectral, etc.

Remote sensing applications for these two sUAS include mapping, structural inspections, aerial imagery, 

and demonstrations. Use of the two sUAS for these purposes, safely provide high quality data at a 

fraction of the cost of using conventional aircraft. They can also operate in conditions that conventional 

sized aircraft could not accommodate. 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure an equivalent level of safety to currently authorized operations using manned aircraft.

The airspace in which the sUAS will operate will occur in FAA approved airspace as designated in the 

COA.
Safety and risk assessment evaluations:

I respectfully submit that these small unmanned aerial systems will be used in lieu of comparatively 

hazardous operations now conducted with fixed wing and rotary manned aircraft. The FAA can have 

confidence that the operations will achieve at least an equivalent or greater level of safety for persons 

and airspace users. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 

“Establish requirements for the safe operation of such aircraft systems in the national airspace system.”

The regulations from which the exemption is requested are as follows:

14 C.F. R. 61.113(a) & (b) 14 C.F. R. 91.7 (a)

14 C.F. R. 91.119(c) 14 C.F. R. 91. 121

14 C.F. R. 91. 151(a) (1) 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)

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

I submit that granting of this exemption application for use of the sUAS 3DR Iris+ and X8 for remote 

sensing with a focus on mapping, aerial imaging, industrial/structural inspections, and demonstrations. 

This will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the 

introduction of UASs into the national airspace system (NAS). In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the 

public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator.

The granting of the requested exemption is in the public interest based on the clear direction in Section 

333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations; and the significant public benefit, 

including enhanced safety and cost savings associated with transitioning to UASs for remote sensing. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without 

delay.
The sUAS

The sUAS in this petition will comply with the requirements set forth by Section 333 by its small size, 

weight, speed, and operational proximity to airports and densely populated areas. As a result under this 

exemption UAS’ are not deemed airworthy by an airworthiness certificate, but rather they are deemed 

airworthy by the operator conducting a thorough preflight of the aircraft. These aircraft will also be 

registered according to 14 CFR Part 47, marked in accordance to 14 CFR Part 45 Subpart C, and 

accompanied by a letter of alternative marking due to the unconventional design. Markings will be as 

large as practicable. These aircraft are of the same size, configuration, and operational capabilities of the 

aircraft granted in exemptions 11138, 11153, and 11157.

Aircraft Performance/Specifications:

•Ground Control Station (GCS): The aircraft will be primarily controlled through the use of a 2.4 GHz RC 

transmitter. The aircraft can also be pre-programmed to conduct a mission through the use of a laptop 

or tablet via a 915 MHz telemetry link. Whenever operations are conducted in this matter, the RC 

Transmitter will be able to take control of the aircraft if the need arises.

3DR Iris+

• Video Downlink: 

o 5.8 GHz at 200mW

• Lost Com: 

o Aircraft will autonomously return to the launch location and safely land.

• Flight controller:

o Pixhawk

• Emergency Procedure: 

o Should the need arise the aircraft can be commanded by a switch on the RC transmitter 

to safely land immediately or return and land at the launch location.

• Power Supply:

o Iris+: 3S 5100 mAh 25C Lithium Polymer Battery

• Dimensions:

o Iris+ : 26 in. prop tip to prop tip

• Maximum Speed:

o <44 knots

• Normal operating speed: 

o < 30 knots

• Weight with payload: 

o Iris+: 3 lb.

3DR X8

• Video Downlink: 

o 5.8 GHz at 200mW

• Lost Com: 

o Aircraft will autonomously return to the launch location and safely land.

• Emergency Procedure: 

o Should the need arise the aircraft can be commanded by a switch on the RC transmitter 

to safely land immediately or return and land at the launch location.
• Power Supply:

o 4S 5000 MAH 25C Lithium Polymer Battery

• Dimensions:

o 32 in. prop tip to prop tip

• Maximum Speed:

o <44 knots

• Normal operating speed: 

o < 30 knots

• Weight with payload: 

o X8=6 lb.

Aircraft manuals and operations checklist will be included as additional information to this petition for 

exemption.

Operator Requirements:

As the sUAS operator will meet or exceed all FAA requirements for UAS operations as listed below.

Minimum of:

• Private pilot’s certificate

• At least a third class medical, 

• Aircraft specific flight training as defined below.

• 25 hours as a UAS rotorcraft pilot including,

• 10 hours logged as a UAS pilot with a multi-rotor UAS,

• 5 hours with the specific make and model of the UAS, and

• At least 3 take-offs and landings within the preceding 90 days.
Mandatory Operating Conditions

Grant of the exemption to Ross Palmer will be subject to the following mandatory conditions for flight 

operations.

• Operations shall not occur over congested, actively, or densely populated areas as defined 

by the local FSDO.

• Permission from land owner is required before commencing any flight.

• Operations will only occur during Visual Flight Rules Meteorological Conditions (VMC).

• Operations will not occur 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 operator.

• The sUAS will remain clear of manned aircraft and yield right of way.

• A flight test will be conducted after any major repair or alteration.

• A preflight check will be conducted before each flight to assure airworthiness.

• Aircraft will remain within Visual Line of Sight (VLOS) of the operator.

• All operations will be conducted with a Visual Observer (VO).

• Operations will be limited to daylight hours.

• Operations will be concluded with no less than 25% battery power remaining.

• Operations will not exceed 400ft AGL.

• Operations will not occur within 5nm of any airport unless a letter of agreement with that 

airport’s management is obtained.

• Operations will take place under a COA.

• Operator will file a NOTAM for each flight.

• All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.

• All non-participants will keep 500ft away from operations unless there are adequate barriers 

to protect them.

• All operations will be conducted according to the manufacturer’s manuals.

• All documents that will be kept at the GCS include but are not limited to; the aircraft 

manuals, maintenance logs, aircraft registration, grant of exemption, and COA.

Public Interest

Consistent with the requirements of 14 C.F.R. §11.81(d), Petitioner offers the following reasons why 

granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public 

as a whole.

Approval of this exemption allowing commercial remote sensing operations of sUAS in mapping, aerial 

imagery, structural inspections, and demonstration will benefit the public as a whole in the following 

ways:

• It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, 

the FAA Administrator's assessment of whether certain UAS may operate safely in the 

National Airspace System before completion of the rulemaking required under Section 332 

of the Reform Act.
• The operation significantly improves safety and reduces risk by alleviating human exposure 

to danger associated with current aerial remote sensing methods, namely, full size 

helicopters. Reducing human exposure to death or serious injury associated with manned 

aircraft performing these tasks furthers the public’s interest.

• Petitioner's sUAS are battery powered and create no emissions. If Petitioner's sUAS crashes, 

there is no fuel to ignite and explode. Any impact of Petitioner's lightweight sUAS is far less 

than a full size manned aircraft. The public's interest is furthered by minimizing ecological 

impact of an accident and by reducing human exposure to potentially harmful emissions 

associated with manned aircraft.

• Remote sensing is as valuable tool for mapping, structural inspections, aerial imagery, flight 

testing and training. However, problems with safety, cost, statistical integrity, and logistics 

continue to impede remote sensing from conventional manned aircraft. The use of sUAS 

addresses these problems and is a powerful tool for performing a wide-range of remote 

sensing applications. The public as a whole will benefit from the safer and more costeffective remote sensing services that sUAS operations provide.

Privacy

All flights will occur over property with the landowner’s prior consent.

Conclusion

I Ross Palmer, seeks an exemption from the FARs set forth above and in Appendix A to allow commercial 

operations of a sUAS conducting remote sensing with a focus in research, mapping, aerial imaging, 

structural inspections, flight testing and R/C training.

Approval of this exemption allowing commercial operations of the two sUAS for remote sensing will 

enhance safety by reducing risk. Conventional remote sensing operations, using turbine or pistonpowered aircraft present risks associated with vehicles that can weigh 5,000 to 7,000 lbs., or more, carry 

large quantities of fuel, passengers, and, in some cases, cargo. In contrast, these two sUAS weighing less 

than 6 lbs. and powered by batteries eliminates a portion of that risk given the reduced mass and lack of 

combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not 

expose any individuals to the risks associated with manned aircraft flights.

Additionally, no national security issue is raised by the grant of the requested exemptions due to all 

pilots being certified through the FAA.

The operation of the two sUAS weighing less than 6 lbs., for remote sensing in accordance with the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein.

These sUAS provide satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight, 

speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual 

line of sight, and national security—and its showing of an equivalent level of safety provides more than 

adequate justification for the grant of the requested exemptions allowing commercial operation of the 

two sUAS in the remote sensing business.
APPENDIX A:

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

I, Ross Palmer, request an exemption from the following regulations, all of which have been granted by 

every approved Section 333 exemption at the time of this submission.

14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in command.

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

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2)

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

Equivalent Level of Safety

Currently, there are no applicable areas identified for sUAS in either the private or commercial sector 

and therefore an exemption is required to conduct commercial operations. As flight operations will be 

conducted in a restricted environment as described in the operations section, these strict guidelines will 

achieve an equivalent level of safety for each individual flight especially when compared to commercial 

flights identified in Part 61 when originally developed.

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

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the 

sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness.

Equivalent Level of Safety

Given the size of the IRIS+ & X8 and the preflight procedures including the review of maintenance logs 

and preflight check lists, an equivalent level of safety will be provided to assure the aircraft is in an 

airworthy condition.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above the surface and 

away from any person, vessel, vehicle, or structure in non-congested areas.

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

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the 6 pounds proposed herein, 

and given the lack of flammable fuel, any risk associated with these operations is far less than those that 
presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS, as well as the location where it is operated. As set forth in the operations 

section of this exemption, the sUAS will be operated away from densely populated areas and at least 

5nm away from airports (unless a letter of agreement from the airport’s management is obtained), 

where buildings and people will not be exposed to operations without their pre-obtained consent. 

Because of the advance notice to the property owners and participants, all affected individuals will be 

well aware of the planned flight operations.

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft 

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS uses AGL from 

take of location and not MSL altitude.

Equivalent Level of Safety

An equivalent level of safety will be achieved by the operator confirming the altitude of the launch site 

shown on the altitude indicator before flight. Moreover, the PIC will use the barometric altitude AGL 

indicator to constantly monitor the sUAS height, thus ensuring operation at safe altitudes.

14 C.F.R. § 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.F.R. § 91.151(a) (1)'s fuel requirements for flight in VFR 

conditions during the day. Section 91.151(a) (1) states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes;

Here, the battery powering the UAS provides approximately 12 minutes of flight. To meet the 30 

minutes reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not be conducted. Given the 

limitations on the sUAS proposed flight area and the location of its proposed operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% 

reserve battery power still available. This restriction would be more than adequate to return the sUAS 

safely to the ground and its planned landing zone from anywhere in its limited operating area even in 

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

does not include the type of risks that Section 91.151(a)(1) was intended to alleviate given the size and 

speed of the small UAS, and the proximity of the flight operation to the landing zone.
14 C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b): Maintenance Inspections

Petitioner also seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a) (1), 91.409(a) (2); 91.417(a) and (b). These regulations specify maintenance 

and inspection standards in reference to 14 C.F.R. Part

43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the 

aircraft inspected as prescribed in subpart E of this part and shall between required inspections ...have 

discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these regulations is 

needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the sUAS will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operator will ensure that the sUAS is in 

working order prior to initiating flight by following the preflight checklist, perform required 

maintenance, and keep a log of any maintenance performed. The operator is the person most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition.
APPENDIX B: SUMMARY OF ROSS PALMER, SECTION 333 EXEMPTION 

REQUEST

I, Ross Palmer, hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the 3D Robotics Iris+ and X8 unmanned aircraft in remote sensing. An 

exemption is requested from the following regulations:

14 C.F. R. 61.113(a) & (b); 

14 C.F. R. 91.7 (a); 

14 C.F. R. 91.119(c); 

14 C.F. R. 91. 121; 

14 C.F. R. 91. 151(a) (1); 

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).