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28 March 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations 

Dear Sir or Madam: 

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

and 14 C.F.R. Part 11, Advanced Aviation LLC, seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the AeroM Unmanned Aircraft System manufactured 

by 3D Robotics of California. Except for the aircraft, this application is similar to a previous

application to which you granted Exemption 11136 on 5 January 2015. 

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the system to support aerial surveying and mapping as well as UAS 

Operator training. The AeroM system consists of a lightweight (6.8 lb) battery operated aircraft, 

a PC-based ground control station with associated communications equipment and a manual 

radio controller capable of linking to a second set of instructor controls. The aircraft is capable 

of carrying multiple payloads making it an ideal platform for initial UAS Operator training. 

Advanced Aviation Solutions would like the opportunity to utilize model aircraft flying fields for

instruction. Many of these fields operate safely within 2 NM of airports with de-confliction

procedures coordinated with airport management. By adhering to the rules established by these

clubs, we feel we can safely train UAS pilots side-by-side with model aircraft hobbyists in close

proximity to airports. By approving these exemptions, the FAA will create the opportunity to 

produce professionally trained UAS Operators with both in-depth general knowledge and handson operational experience. 

The aircraft will be operated in the field with a Pilot in Command (PIC) and a ground-based 

Visual Observer (VO) with the following restrictions:

- All operations that occur in Class B, C, D and E airspace will comply with responsible ATC

agency restrictions

- Without an approved memorandum of understanding with airport management, the aircraft will 

not be operated within:

a) 5 nautical miles (NM) from an airport having an operational control tower; or 

b) 3 NM from an airport having a published instrument flight procedure, but not having an 

operational control tower; or 

c) 2 NM from an airport not having a published instrument flight procedure or an operational 

control tower; or 

d) 2 NM from a heliport

- All operations will occur at no more than 500' AGL
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- Operations will be operated over private or controlled access property with the permission of 

the land owner or controller

- All required permits will be obtained from state and local government prior to operation

- The aircraft will not be operated over congested areas

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC or VO at all times

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

- PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each operation

- The PIC will hold a Private Pilot's Certificate and current Class III medical

- The PIC will perform maintenance on the system and will complete a course of maintenance 

instruction as part of their initial training. 

We submit that the combination of the aircraft's light weight, historically demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established by

the FAA can have confidence that the operation will have an equivalent or greater level of safety 

of manned aircraft performing the same mission.

The name and contact information of the applicant are:

Advanced Aviation Solutions LLC

Attn: Kenneth J. McCormick

Ph: 253-439-8100

Email: ken@adavso.com

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

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- 14 CFR 91.7(a)
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We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

you require additional information or clarification. 

Sincerely,

Kenneth J. McCormick

Vice President

Appendices:

A. Exemption Request and Equivalent Level of Safety

B. Privacy Issues

C. Operational Safety Assessment

D. Aero-M Inspection and Maintenance Manual

E. 3D Robotics Aero-M User Manual

F. Aero-M Training Manual

G. RPA Student Pilot and VO Training Manual

H. ADAVSO Aviation Experience
Appendix A

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EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Advanced Aviation Solutions LLC requests an exemption from the following regulations as well 

as any additional regulations that may technically apply to the operation of the 3D Robotics 

AeroM:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. Due to the 

size of the aircraft and FAA proposals for small UAS, we request relief from the requirement for 

an airworthiness certificate. The PIC will maintain the small UAS in condition for safe operation 

and prior to flight must inspect the UAS to ensure that it is in a condition for safe operation. 

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

The regulation provides that an airworthiness certificate, with the registration number assigned to 

the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph 

(b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew." At 6.8 lbs, the AeroM is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. 

To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents 

deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground 

control station and available for inspection upon request. In order to identify the aircraft, we 

propose that the registration number be affixed to the aircraft as large as practical.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number. Each aircraft will be registered in accordance with 14 CFR part 47, and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be 

as large as practicable. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight 

manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight 

manual information is available to the aircrew while operating the aircraft. We request an 

exemption to this requirement since the aircraft is not only too small to carry documentation, the 

documentation would not be available to the crew. 

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, 

approved Airplane Flight Manual (appendix E) must be available to the crew at the ground 

station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations.

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 
Appendix A

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flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire.

We propose that the Pilot in Command (PIC) must possess at least a private pilot certificate and at 

least a current third-class medical certificate. The PIC will 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. 

Since there are currently no means available for the pilot of a UAS to gain the experience in an 

equivalent category and class in order to apply for a commercial pilot's license. Since the aircraft 

cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct a business.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a 

maximum of 500 feet AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the 

permission of the land owner. The land owner will be briefed of the expected route of flight and 

the associated risks to persons and property on the ground. We maintain that due to the small 

size of the AeroM, the hazard to persons, vessels, vehicles, and structures is not comparable to 

manned aircraft and should be considered in granting the exemption. 

Flight operations will 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 the UA 

and/or debris in the event of an accident. The operator will 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 within 500 feet will cease immediately 

and/or; 

b. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and

c. operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue 

hazard to those persons per § 91.119(a). 

14 CFR 91.121 Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with 

other aircraft. As such, an appropriate altimeter measurement presented to the pilot should be 

Above Ground Level and should be based on the barometric pressure at the point of launch. To 

provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground 

prior to every flight. Since the aircraft will fly no more than 60 minutes, even rapid changes in 

barometric pressure will have limited affect on the safety of the flight. 
Appendix A

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14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after 

that for at least 30 minutes. We feel the intention of this paragraph is to provide a reserve of 

energy as a safety buffer for go-arounds and other delays to landing.

The AeroM is battery operated and the maximum duration of flight from a single battery charge 

is 60 minutes. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly to the first point of intended landing and, assuming 

normal cruising speed, land the UA with 30% battery power remaining.

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive Maintenance, and 

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in 

an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 

91.409 require that the aircraft be "approved for return to service by a person authorized under 

43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the aircraft for return to service." 

As provided in the attached Maintenance Procedures (appendix D), the PIC will ensure that the 

aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10 

hours. Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, and updating software and firmware. All other maintenance will be performed by the 

manufacturer. The PIC will document work performed in accordance with 91.417. We feel that 

due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level 

of safety.

14 CFR 91.7(a) - Civil aircraft airworthiness

The regulation provides the aircraft require airworthiness certification. Due to the size of the 

aircraft and FAA proposals for small UAS, we request relief from the requirement for an 

airworthiness certificate. The PIC will maintain the small UAS in condition for safe operation and 

prior to flight must inspect the UAS to ensure that it is in a condition for safe operation.