UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

MotoMon Corporation

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATION

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

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

 Hubsan H109S

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)
TABLE OF CONTENTS

 page

Glossary of Abbreviations ....................................................... 3

 Summary ........................................................................... 4

 Introduction and Interests of Petitioner ....................................... 5

 Background ........................................................................ 6

 Basis for Petition .................................................................. 7

 Name and Address of Petitioner ................................................ 8

 Specific sections of 14 C.F.R from which MotoMon Corporation seeks

 Exemption .......................................................................... 9

 The extent of relief MotoMon Corporation seeks relief and the reason

 MotoMon Corporation seeks relief........................................... 10

 The reasons why granting MotoMon Corporation’s request would be

 In the public’s interest........................................................... 11

 The reasons why granting the exemptions would not adversely affect

 Safety.............................................................................. 12

 Summary that can be published in the Federal Register..................... 13

Any additional information, views, or arguments available to support

 MotoMon Corporation’s request..............................................

 Conclusion.........................................................................

 
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest ATC 

Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization FAA 

Federal Aviation Administration FAR 

Federal Aviation Regulation GCS 

Ground Control Station

GPS Global Positioning 

System LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft 

System VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions 

VO Visual Observer

VTOL Vertical Takeoff and Landing 4
SUMMARY

MotoMon Corporation seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 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 MotoMon Corporation to operate an 

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

video over certain public roadways and public areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

The petitioner, MotoMon Corporation is Incorporated in Florida, USA, were the corporation sells 

and supports GPS equipmnent, surveys vast amounts of property, and photographs large areas. 

MotoMon Corporation will utilizw the Hubsan H109S for training, video, testing GPS equipment 

and other uses in the performance of the business operation.

Primarily MotoMon Corporation is a sales, testing, and video operation business. 

BACKGROUND

MotoMon Corporation seeks an exemption to operate the HUBSAN Hubsan H109S UAS for 

compensation within the NAS. The HUBSAN Hubsan H109S is comprised of a vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The 

HUBSAN Hubsan H109S has a maximum gross weight of approximately 6.6 pounds, while having a 

diameter of 31 inches, height of 13 inches, and maximum speed of 23 mph. The HUBSAN Hubsan 

H109S UA is equipped with four propellers, each being driven by an electric motor powered by 

Lithium Polymer battery. The HUBSAN Hubsan H109S UA that will be operated by MotoMon 

Corporation will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well 

as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, MotoMon Corporation is 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 HUBSAN Hubsan H109S UAS in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 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, MotoMon Corporation operation of the HUBSAN Hubsan H109S 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. 6. Accordingly, MotoMon Corporation 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.

MotoMon Corporation submits that the requested relief is proper since an equivalent level of safety 

will be ensured. MotoMon Corporation will use its 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, MotoMon Corporation will 

document and maintain all maintenance records for the HUBSAN Hubsan H109S UAS. Relief from 

certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: 
Pilot in command, is requested by MotoMon Corporation to the extent necessary to allow a Pilot in 

Command (PIC) who has completed the HUBSAN Hubsan H109S UAS training and currency 

requirements, to conduct the proposed UAS flight operations. MotoMon Corporation submits that 

the conditions and limitations set forth herein will ensure the safety of the NAS, as well as the safety 

of persons or property on the ground.

MotoMon Corporation seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the HUBSAN Hubsan H109S UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, MotoMon Corporation submits that it will 

ensure that the HUBSAN Hubsan H109S UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS is in compliance with the HUBSAN Flight Manual, and that the aircraft is 

in a condition for safe flight.

MotoMon Corporation also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the HUBSAN Hubsan H109S UA will not have a typical barometric altimeter 

onboard. However, altitude information of the HUBSAN Hubsan H109S UAS will be provided to 

the PIC via Global Positioning System (GPS) equipment and a radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude 

information, combined with MotoMon Corporation operation of the HUBSAN Hubsan H109S UA 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, MotoMon Corporation seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. MotoMon Corporation submits 

that safety will not be affected by terminating flights of the battery powered HUBSAN Hubsan 

H109S UA after 30 minutes of continuous flight, which would allow for five minutes of battery 

power remaining.

In accordance with 14 C.F.R. § 11.81, MotoMon Corporation 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: 

MotoMon Corporation

Mr. John Moder, Vice President

14707 S. Dixie Hwy., 

Suite 301

Miami, Florida 33176 

USA

Contact; Mr. John Moder

MotoMon Corporation

B. The Specific Sections Of 14 C.F.R. From Which MotoMon Corporation Seeks Exemption. 

1. MotoMon Corporation Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) 

and (b) prescribe the following, in relevant part: 8 No person who holds a private pilot certificate 

may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(a) A private pilot may, for compensation or hire, act as PIC 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. 

2. MotoMon Corporation 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. 

3. MotoMon Corporation, Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(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; 

4. MotoMon Corporation 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.

5. MotoMon Corporation 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. MotoMon Corporation 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[.]

7. MotoMon Corporation 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. MotoMon Corporation 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: 10 

(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. 

(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 (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD 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. 

C. The Extent Of Relief MotoMon Corporation Seeks And The Reason MotoMon 

Corporation Seeks The Relief. 

1. Extent of Relief MotoMon Corporation Seeks And The Reason MotoMon Corporation

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot certificate and a

third-class airman medical certificate, and who has completed the HUBSAN training and currency 

requirements, to conduct the proposed UAS flight operations for compensation.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC 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.

As set forth more fully below, MotoMon Corporation submits that an equivalent level of safety will 

be maintained because no person who is not an employee of MotoMon Corporation will have 

operation rights to fly or maintain the HUBSAN Hubsan H109S and fly the UAS in a manner 

consistent with the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.
Further, MotoMon Corporation submits that all flights of the HUBSAN Hubsan H109S conducted 

by the PIC pursuant to the grant of this Petition - (1) will be incidental to MotoMon Corporation’s

business; and (2) will not carry passengers or property for compensation or hire. 12

2. Extent of Relief MotoMon Corporation Seeks And The Reason MotoMon Corporation

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 MotoMon Corporation to determine that the HUBSAN Hubsan H109S UAS is in an 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

HUBSAN Flight Manual, and that the aircraft is in a condition for safe flight.

MotoMon Corporation seeks the requested relief because the HUBSAN Hubsan H109S UAS does 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

MotoMon Corporation will ensure that the HUBSAN UAS is in an airworthy condition based upon 

its compliance with the operating documents (i.e., the HUBSAN Flight Manual) prior to every flight, 

and as stated in the conditions and limitations below.

3. Extent of Relief MotoMon Corporation Seeks And The Reason MotoMon Corporation

Seeks Relief From Section 91.121.

Relief from Section 91.121 entitled Altimeter settings, may be required to allow flight operations of 

the DIJ UAS, which utilizes GPS equipment and a radio communications telemetry data link to 

downlink altitude information to the PIC from the UA to the GCS. As more fully set forth below, 

safety will be maintained as a result of the DIJ Hubsan H109S UA’s altitude readout via GPS 

equipment, and MotoMon Corporation’s operation of the HUBSAN Hubsan H109S UA within 

visual line of sight, at or below 400 feet AGL.

4. Extent Of Relief MotoMon Corporation Seeks And The Reason MotoMon Corporation

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 HUBSAN UA during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR) conditions, to continue for 

a total duration of 30 minutes, which will ensure that the UA will land with five minutes of battery 

power remaining. MotoMon Corporation seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered HUBSAN UA will severely

constrain the practicality of any aerial acquisition and research flight operations that MotoMon 

Corporation proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the HUBSAN Hubsan H109S UAS, the 

HUBSAN Flight Manual, and MotoMon Corporation’s proposed operating limitations, ensure that 

MotoMon Corporation will safely operate the battery powered HUBSAN UA during daylight hours in 

VFR conditions, for a total flight duration of 30 minutes, landing with five minutes of battery power 

remaining.

5. Extent Of Relief MotoMon Corporation Seeks And The Reason MotoMon Corporation

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And

91.417(a) & (b).

Since Sections 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, MotoMon Corporation requests relief from these Sections 

because the HUBSAN Hubsan H109S UAS does not require an airworthiness certificate. As set 

forth more fully below, the HUBSAN Hubsan H109S UAS meets the conditions of Section 333 of 

the FMRA for operation without an airworthiness certificate. Accordingly, MotoMon Corporation

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, MotoMon Corporation will document and maintain all maintenance records 

for the HUBSAN Hubsan H109S UAS.
D. The Reasons Why Granting MotoMon Corporation’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 MotoMon Corporation to 

safely, efficiently, and economically perform aerial photographs and video over public areas of the 

United States, commercially, in support of government entities, GPS testing and documentation, 

scientific studies, and video mapping. Additionally, use of the HUBSAN Hubsan H109S UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. 

Notably, the benefits of MotoMon Corporation’s proposed operation of the HUBSAN H109S UAS 

will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisitioned Photographs and Video Performed.

MotoMon Corporation submits this Petition to commercially operate the HUBSAN Hubsan H109S

UAS and perform aerial acquisitions and research throughout areas of the United States, in support 

of government entities, private investigations, court appointed investigations, evidentiary video and 

photographs of crime scenes, and crime scene direction mapping. The HUBSAN Hubsan H109S

UAS will provide safe, efficient, and economical aerial acquisition and research operations to further 

each of these fields, all of which are critical to the well-being of the general public.

The specific operations that MotoMon Corporation will perform with the HUBSAN Hubsan H109S

UAS demonstrate how the requested exemption will directly benefit the above-referenced industries 

and the public. In court appointed investigations, the aerial acquisition performed by the HUBSAN

Hubsan H109S will create critical aerial evidence of a wider area than could be done on the ground. 

In private investigations the HUBSAN Hubsan H109S UAS will be used to aid in property 

inspections, and crime scene evidence. The HUBSAN Hubsan H109S UAS will also further the 

investigative process since large and vast amounts of photographs can be condensed into one video 

segment for court preparation and court viewing.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The HUBSAN Hubsan H109S UA 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 a HUBSAN Hubsan H109S 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. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The HUBSAN Hubsan 

H109S UA does not require an airport to takeoff or land. Likewise, 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 Public Will Benefit From The Safety And Efficiency Of The HUBSAN Hubsan H109S

UAS.

Conducting aerial acquisitions with the HUBSAN Hubsan H109S 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. By using battery power and electric motors, the 

HUBSAN Hubsan H109S UAS produces no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion twin engine aircraft that are 

typically utilized for aerial acquisitions, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The HUBSAN Hubsan H109S UA, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery powered 

electric motors, rather than an internal combustion engine.

By using the HUBSAN Hubsan H109S UAS to perform aerial acquisitions, the substantial risk to life 
and property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the HUBSAN Hubsan H109S UA (weighing approximately 

6.6 pounds at its maximum gross weight with a diameter of 31 inches, and with no fuel on board), has 

less physical potential for collateral damage to life and property on the ground, and in the air, compared 

to the manned aircraft that typically conduct aerial acquisitions (weighing approximately 6,500 

pounds with a wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).

4. Performing Aerial Acquisition Operations With The HUBSAN Hubsan H109S UAS Will 

Benefit The Economy. 

In addition to being safe and efficient, the HUBSAN Hubsan H109S UAS is also an economical 

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the 

HUBSAN Hubsan H109S UAS will allow United States based companies, like MotoMon 

Corporation, to remain competitive and contribute to growth of the U.S. economy. Specifically, with 

the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered HUBSAN

Hubsan H109S UAS is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high operational 

cost of a traditional manned aircraft. 

By operating the HUBSAN Hubsan H109S UAS, companies such as MotoMon Corporation can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the HUBSAN Hubsan H109S UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and federal 

tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

5. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

MotoMon Corporation’s proposed operation of the HUBSAN Hubsan H109S UAS will not 

implicate any privacy issues. Specifically, the HUBSAN Hubsan H109S UAS will be operated 

only in rural areas, and in accordance with all Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the HUBSAN Hubsan 

H109S UA 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 MotoMon Corporation Seeks Exemption.

1. Reasons Why The HUBSAN Hubsan H109S 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 its operation, MotoMon Corporation’s operation of the HUBSAN Hubsan H109S 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. Specifically, FMRA Section 333 states the 

following, in part:
(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-- 18

(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, MotoMon Corporation submits that the HUBSAN Hubsan H109S UAS 

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the HUBSAN Hubsan H109S UAS; (b) the pilot certification requirement; and (c) 

the specific operating limitations.

a. The Specifications Of The HUBSAN Hubsan H109S UAS Demonstrate Its Safe 

Characteristics.

The HUBSAN Hubsan H109S UAS does 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 HUBSAN Hubsan H109S UAS.

The technical specifications of the HUBSAN Hubsan H109S UAS are set forth in Appendix C of 

the “Flight Manual For The HUBSAN Hubsan H109S Unmanned Aircraft System (UAS),” attached 

hereto as 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)1.

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 

11.35(b), are not to be included in the Federal Docket Management System (FDMS).

ii. The HUBSAN Hubsan H109S UAS Autonomous Flight And Navigation Modes Enable 

The UAS To Remain Within A Defined Operational Area.

A complete description of the autonomous modes and methods of navigation of the HUBSAN

Hubsan H109S UAS is provided at pages 2, 4, 5, and 10 of the “Flight Manual For The HUBSAN

Hubsan H109S Unmanned Aircraft System (UAS),” attached hereto as 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).

iii. The HUBSAN Hubsan H109S UAS Is Designed For Automatic Return To Launch In The 

Event Of Loss Of The Control Link Or Navigation.

A complete description of the HUBSAN Hubsan H109S UAS’s automatic return to launch function 

in the event of a break in communication or loss of telemetry data is set forth on pages 2, 9, and 10 

of the “Flight Manual For The HUBSAN Hubsan H109S Unmanned Aircraft System (UAS),” 

attached hereto as 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). b. Flight Operations Of The HUBSAN Hubsan 

H109S UAS Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A 

Safety Observer.

MotoMon Corporation will only utilize certificated pilots who possess a valid airman medical 
certificate to act as a pilot in command (PIC) of the HUBSAN Hubsan H109S UAS. Additionally, a 

safety observer will assist all pilots. The PIC must complete the HUBSAN Hubsan H109S UAS 

training and qualification, as set forth in the “Flight Manual For The HUBSAN Hubsan H109S

Unmanned Aircraft System (UAS),” attached hereto as 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). 20

c. Flights Of The HUBSAN Hubsan H109S UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, MotoMon Corporation proposes to commercially operate the HUBSAN

Hubsan H109S UAS for the special purpose of conducting aerial acquisitions over public areas of 

United States, 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 is a quad rotor aircraft weighing less than 10 pounds: HUBSAN

Hubsan H109S Unmanned Aircraft System. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant. 

2) The UA may not be flown at an indicated airspeed exceeding 25 MPH & the UA must be operated 

at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures 

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

3) 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. 

4) All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement, as long as the PIC always maintains VLOS 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. 

5) 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. 

6) 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. 

7) 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 operator’s manual. 

8) 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. 

9) 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. 

10) MotoMon Corporation 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 PIC returning the UAS to 

service. 

11) MotoMon Corporation UAS technicians must receive and document training referenced in the 

operator’s manual. 

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

Safety Bulletins. 

13) MotoMon Corporation 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 PIC must possess at least a private pilot certificate and a third-class airman medical 

certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate. 

16) The operator may not permit any PIC to operate unless that PIC has demonstrated, through 

the training and currency requirements set forth in the operator’s manual, 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. 22 

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 (VMC). Flights under special 

visual flight rules (SVFR) are not authorized. 

18) The UA may not operate within 5 nautical miles of the airport reference point as denoted on a 

current FAA-published aeronautical chart. The UA may not operate within 3 nautical miles from 

any city or densely populated area. 

19) 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. 

20) 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 and land, or be recovered in 

accordance with the operator’s manual. 

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

accordance with the operator’s manual. 

22) 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 to the 

first point of intended landing prior to utilizing battery reserve power. 

23) 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 issuance of a Notice to Airman (NOTAM) 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, 

registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings 

in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable. 

25) 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. 
26) The documents required under 14 C.F.R. 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. 

27) The UA 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 PIC from any moving device or vehicle. 23 

29) The UA may not be operated over congested or densely populated areas. These areas include but 

are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts 

may not reflect pertinent local information. Ultimately, it 

is the PIC’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 

(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 land 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). 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 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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would 

Not Adversely Affect Safety.

MotoMon Corporation submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the HUBSAN Hubsan H109S

UAS unless that PIC has demonstrated, through the HUBSAN Hubsan H109S UAS training and 

currency requirements, that the PIC is able to safely operate the HUBSAN Hubsan H109S UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 24

Considering MotoMon Corporation’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the HUBSAN Hubsan H109S UAS, MotoMon Corporation submits that the 

additional manned airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for MotoMon Corporation’s specific proposed flight operations.

The HUBSAN Hubsan H109S UAS was the subject of a previous Grant of Exemption from Section 

61.113(a) and (b). In Exemption No. 11109, the FAA granted relief from Section 61.113(a) and (b) 

concerning the operation of the HUBSAN Hubsan H109S UAS by a PIC holding a private pilot 

certificate and third class airman medical certificate, based upon the following analysis:

The FAA has analyzed Clayco’s proposed operation and has determined that it does not differ 
significantly from the situation described in Grant of Exemption No. 11062 (Astraeus Aerial). 

Clayco plans to operate over private property with controlled access in the NAS. Given: 1) the 

similar nature of Clayco’s proposed operating environment to that of Astraeus’, 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 airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Clayco’s specific 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 (item #3 stated above), Clayco 

has proposed a 100 hour training program and 6 month currency requirements. The conditions and 

limitations below stipulate that Clayco may not permit any PIC to operate unless that PIC has 

demonstrated through Clayco’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.

See Exemption No. 11109 at 12.

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. 25

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138).

As in Exemption No. 11109, MotoMon Corporation will not allow any PIC to operate the 

HUBSAN Hubsan H109S UAS unless that PIC has demonstrated through the HUBSAN Hubsan 

H109S UAS training and currency requirements, that the PIC is able to safely operate the 

HUBSAN Hubsan H109S UAS in a manner consistent with this exemption, including evasive and 

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

structures.

A complete description of the HUBSAN Hubsan H109S UAS Training and Qualification 

requirements is set forth at page 5 of the “Flight Manual For The HUBSAN Hubsan H109S h 

Unmanned Aircraft System (UAS),” attached hereto as 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).

3. 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, MotoMon Corporation will ensure that the HUBSAN Hubsan H109S UAS is in an 

airworthy condition based upon the HUBSAN Hubsan H109S UAS’s compliance with its 

operating documents (i.e., the HUBSAN Hubsan H109S Flight Manual), and as stated in the 

conditions and limitations herein.

The HUBSAN Hubsan H109S UAS was the subject of a previous Grant of Exemption from Section 

91.7(a) (Exemption No. 11109). Additionally, the FAA has previously granted relief from Section 

91.7(a) 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). 26

4. 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 HUBSAN Hubsan H109S UA will be provided to the PIC via GPS equipment and 

a radio communications telemetry data link, which downlinks from the UA to the GCS for active 
monitoring of the flight path. This altitude information, combined with MotoMon Corporation’s 

operation of the HUBSAN Hubsan H109S UA 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 

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point 

will be established and confirmed for accuracy by the UAS PIC. The HUBSAN Hubsan H109S UAS 

was the subject of a previous Grant of Exemption from Section 91.121 (Exemption No. 11109). 

Additionally, the FAA has previously granted relief from Section 91.121 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, 11112, 11136, 11138).

5. 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 HUBSAN Hubsan H109S

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, MotoMon Corporation will ensure that it can safely operate the battery 

powered HUBSAN Hubsan H109S UA during daylight hours, in VFR conditions, for a total flight 

duration of no more than 30 minutes, resulting in a landing with five minutes of battery power 

remaining. In a previous Petition for Exemption, in which an operator was utilizing a HUBSAN

Hubsan H109S UAS identical in all material respects to the HUBSAN Hubsan H109S UAS 

MotoMon Corporation proposes to use, the FAA granted an exemption from the requirements of

Section 91.151, stating as follows:

In the event that the UAS should run out of power, it would simply land within the access controlled 

operating area. Given its weight and construction material, the risks are less than contemplated by 

the current regulation. Prior relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for 

daytime, Visual Flight Rules (VFR) conditions. The HUBSAN Hubsan H109S provides a battery

failsafe that commands the UA’s return to the launch point when critical minimum voltage is 

reached. The UAS batteries provide approximately 35 minutes of powered flight. The FAA agrees 

with Clayco’s proposal to limit UAS flights to not more than 30 minutes, or enough battery reserve 

to ensure that the UAS lands at the ground station with at least 20% battery reserve power, 

whichever happens first. Given the limitations on its proposed operations and the location of those 

proposed operations, a reduced minimum power reserve for flight in daylight VFR conditions is 

reasonable.

See Exemption No. 11109 at 15.

Here, as in Exemption No. 11109, the technical specifications of the HUBSAN Hubsan H109S UAS; 

the limitations on the proposed flight operations; and the location of the proposed operations, will 

ensure that MotoMon Corporation may safely operate the battery powered HUBSAN Hubsan H109S

UA during daylight hours in VFR conditions for a total duration of not more than 30 minutes, and 

landing with five minutes of battery power remaining.

Significantly, 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 than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

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

288811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11136, 11138).
6. 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, MotoMon Corporation 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 MotoMon Corporation

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. Furthermore, MotoMon Corporation will document and 

maintain all maintenance records for the HUBSAN Hubsan H109S UAS.

Since the HUBSAN Hubsan H109S UAS will be inspected as prescribed by the manufacturer’s 

maintenance manual, MotoMon Corporation 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 

HUBSAN Hubsan H109S UAS sets forth airworthiness requirements for the UA, including 

preflight and post flight inspections, as well as scheduled maintenance in four categories: daily, 

weekly, monthly, and yearly.

Likewise, the exemption sought will not adversely affect safety because MotoMon Corporation will 

perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight Manual 

For The HUBSAN Hubsan H109S UAS details procedures for each component of the UA, including 

the components of the propulsion system, avionics system, and payload system.

A complete description of the HUBSAN Hubsan H109S UAS airworthiness and maintenance 

requirements is set forth at page 6 of the “Flight Manual For The HUBSAN Hubsan H109S

Unmanned Aircraft 29 System (UAS),” attached hereto as 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).

Furthermore, 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 HUBSAN Hubsan 

H109S UAS will be performed by MotoMon Corporation trained technicians, who will 

document and maintain maintenance records for the HUBSAN Hubsan H109S UAS.

Significantly, previous exemptions granted by the FAA concerning the HUBSAN Hubsan H109S

UAS and Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish 

that safety is not adversely affected when the technical characteristics and operating limitations of 

the UAS are considered. In Exemption No. 11109, the FAA stated the following concerning the 

HUBSAN Hubsan H109S UAS and the HUBSAN Hubsan H109S Flight Manual:

Regarding the petitioner’s requested relief from 14 C.F.R 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). The FAA has carefully evaluated the petitioner’s request and determined that cause for 

granting the exemption is warranted. The FAA notes that the petitioner’s HUBSAN Hubsan H109S

UAS Flight Manual contain daily, preflight, monthly and yearly checks for the UAS. The FAA finds 

that adherence to the HUBSAN Hubsan H109S Flight Manual, as required by the conditions and 

limitations below, is sufficient to ensure that safety is not adversely affected. In accordance with the 

petitioner’s UAS maintenance, inspection, and recordkeeping requirements, the FAA finds that 

exemption from 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is 

warranted subject to the conditions and limitations below.

In consideration of MotoMon Corporation’s proposed operating limitations, the most recent 

HUBSAN Hubsan H109S Flight Manual, and the technical aspects of the HUBSAN Hubsan 

H109S UAS, MotoMon Corporation 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, MotoMon Corporation requests that the FAA 

prescribe special conditions for the intended operation of the HUBSAN Hubsan H109S 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 §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 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.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the HUBSAN Hubsan H109S 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, 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 thereto 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. 31

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for MotoMon Corporation’s intended operation of the HUBSAN Hubsan H109S

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 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

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

The Rules From Which MotoMon Corporation Seeks Exemption:

MotoMon Corporation seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 

91.7(a), 91.121, 91.151(b), 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 MotoMon Corporation Seeks:

This exemption will permit MotoMon Corporation to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial acquisitions and research over certain public

areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support MotoMon 

Corporation’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, MotoMon Corporation’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, MotoMon Corporation will operate the HUBSAN Hubsan H109S 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.

CONCLUSION

As set forth herein, MotoMon Corporation 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 HUBSAN Hubsan H109S UAS commercially, without an airworthiness certificate, 

for the limited purpose of conducting aerial acquisitions over certain public areas of 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 MotoMon Corporation to safely, efficiently, and economically operate the HUBSAN

Hubsan H109S UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, MotoMon Corporation respectfully requests that the Administrator 

grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit MotoMon Corporation to operate the HUBSAN Hubsan H109S UAS commercially for the 

purpose of conducting aerial acquisitions, investigations, crime scene video rendering and research over 

certain public areas of the United States.
Dated: May 20th, 2015

Submitted on behalf of MotoMon Corporation

Mr. John Moder

Vice President 

MotoMon Corporation

14707 S. Dixie Highway, suite 301

Miami, Florida 33176

Email

info@motomon.com