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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Unmanned Eagle Eye, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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 DJI S900, DJI S1000+, DJI PHANTOM 3, DJI INSPIRE 1 VERSION 

2.0, 3DR SOLO, TAYZU ROBOTICS QUADRA UNMANNED AIRCRAFT

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on January 4, 2016

Christian Michael Peters

Unmanned Eagle Eye, LLC

203 Lago Circle Drive N.

Santa Fe, Texas 77517

Phone: 281-299-6490

Email: cpeters@UnmannedEagleEye.com
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TABLE OF CONTENTS

PAGE

GLOSSARY OF ABBREVIATIONS ............................................................................................ 3

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

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

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

BASIS FOR PETITION ................................................................................................................. 5

A. Name And Address Of The Petitioner. .................................................................................. 7

B. The Specific Sections Of 14 C.F.R. From Which Unmanned Eagle Eye, LLC Seeks 

Exemption................................................................................................................................... 8

C. The Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned Eagle 

Eye, LLC Seeks The Relief. ..................................................................................................... 12

D. The Reasons Why Granting Unmanned Eagle Eye, LLC Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole............................................ 16

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 Unmanned Eagle Eye. LLC Seeks Exemption. .......................................... 19

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

Which Unmanned Eagle Eye, LLC Seeks Exemption: ............................................................ 34

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

Eye, LLC Request..................................................................................................................... 35

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

APPENDICIES............................................................................................................................. 37
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR 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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UEE Unmanned Eagle Eye, LLC

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
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SUMMARY

Christian Michael Peters 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 Unmanned Eagle 

Eye, LLC (hereinafter “UEE” or “Unmanned Eagle Eye”) to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of 

landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Unmanned Eagle Eye, LLC provides its clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. UEE has established itself 

as a technological innovator in experiential multimedia and is recognized as a leader in providing 

a quality serivice. The objective of UEE’s aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting:

 Agriculture; Crop Health, Insurance Claims, Cattle Health, and Silo Inspections

 Industry; Inspecting power lines and pipelines, surveying and mapping of mines and oil 

refineries

 Videography & Photography; Real-Estate, Marketing, and any special event

 Hazardous Operations; Oil spills, hazmat spills, and search & rescue operations

 Security; Provide video surveillance and intelligence for an event 
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BACKGROUND

Unmanned Aircraft Systems: DJI S900, DJI S1000+, DJI PHANTOM 3, DJI INSPIRE 1 

VERSION 2.0, 3DR SOLO, TAYZU ROBOTICS QUADRA UAS

Unmanned Eagle Eye, LLC seeks an exemption to operate UASs for compensation or 

hire within the NAS. The DJI S900, DJI S1000+, DJI PHANTOM 3, DJI INSPIRE 1 VERSION 

2.0, 3DR SOLO, and TAYZU ROBOTICS QUADRA UAS (hereinafter “UEE’s Aircrafts”) are

vertical takeoff and landing (VTOL) Unmanned Aircraft’s (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. UEE’s Aircrafts have a maximum gross 

weight of approximately 9 pounds 15 ounces, a maximum diagonal wheelbase of 35.5 inches,

and a maximum speed of approximately 29 knots. UEE’s Aircrafts are equipped with a 

maximum of 8 rotors; powered by Lithium Polymer batteries.

UEE’s Aircrafts operated by UEE 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, Unmanned Eagle Eye, LLC pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate UEE’s Aircrafts 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). 
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In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, UEE operation of UEE’s Aircrafts meets the conditions of 

FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 

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

Accordingly, Unmanned Eagle Eye, LLC 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.

Unmanned Eagle Eye, LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. UEE will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and UEE’s 

Aircrafts Instruction Manuals). Furthermore, UEE will document and maintain all maintenance 

records for UEE’s Aircrafts.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Unmanned Eagle Eye, LLC to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate UEE’s 

Aircrafts in a manner consistent with this exemption, including evasive and emergency 

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

Unmanned Eagle Eye, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because UEE’s Aircrafts do not require an airworthiness certificate in accordance 
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with 14 C.F.R. Part 21, Subpart H. As such, UEE submits that it will ensure that UEE’s Aircrafts

are in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and UEE’s Aircrafts 

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

Unmanned Eagle Eye, LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as UEE’s Aircrafts will not have a typical barometric 

altimeter onboard. However, altitude information of UEE’s Aircrafts will be provided to the PIC 

via Global Positioning System (GPS) equipment and 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 UEE’s operation of UEE’s Aircrafts within visual line of sight, at or 

below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Unmanned Eagle Eye, LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. UEE submits that 

safety will not be affected by operation of UEE’s Aircrafts during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to 

fly for a total duration of approximately 13 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4 minutes.

In accordance with 14 C.F.R. § 11.81, Unmanned Eagle Eye, LLC 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 and point of contact is:

Christian Michael Peters
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Unmanned Eagle Eye, LLC

203 Lago Circle Drive N.

Santa Fe, Texas 77517

Phone: 281-299-6490

Email: cpeters@UnmannedEagleEye.com

B. The Specific Sections Of 14 C.F.R. From Which Unmanned Eagle Eye, LLC Seeks 

Exemption.

1. Unmanned Eagle Eye, LLC Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b).

Section 61.113m entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) 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.

(b) 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. Unmanned Eagle Eye. LLC 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. Unmanned Eagle Eye, LLC Exemption From The Requirements Of Section 

91.121.

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

part:
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(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. Unmanned Eagle Eye, LLC 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. Unmanned Eagle Eye, LLC 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—
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(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. Unmanned Eagle Eye, LLC 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. Unmanned Eagle Eye, LLC 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. Unmanned Eagle Eye, LLC 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:
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(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph 

(b) of this section:

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

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

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must

include--

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

work performed; and

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

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

for return to service.

(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 
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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 Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC Seeks The Relief.

1. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC 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 or 

higher level certificate, as well as a current and valid airman medical certificate, and who has 

met certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire.
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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, Unmanned Eagle Eye, LLC submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operate UEE’s Aircrafts

unless that PIC has met certain flight-hour and currency requirements, demonstrating that the 

PIC is able to safely operate UEE’s Aircrafts 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, Unmanned Eagle Eye, LLC submits that all flights of UEE’s Aircrafts, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Unmanned 

Eagle Eye, LLC business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC 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 Unmanned Eagle Eye, LLC to determine that UEE’s Aircrafts are in airworthy 

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

documents (i.e., the Unmanned Eagle Eye, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and UEE’s Aircrafts Instruction Manuals).

Unmanned Eagle Eye, LLC seeks the requested relief because UEE’s Aircrafts do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 
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Unmanned Eagle Eye, LLC will ensure that UEE’s Aircrafts are in airworthy condition based 

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and UEE’s 

Aircrafts Instruction Manuals) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC Seeks Relief From Section 91.121.

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

operations of UEE’s Aircrafts, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), Unmanned Eagle Eye, LLC seeks the requested relief because UEE’s Aircrafts altimeter 

may be set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained UEE’s 

Aircrafts are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC Seeks Relief From Section 91.151(b).
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Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of UEE’s Aircrafts which utilize battery power

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. Unmanned Eagle Eye, LLC seeks 

the requested relief because without an exemption from Section 91.151(b), the flight time 

duration of UEE’s Aircrafts which utilize battery power will severely constrain the practicality of 

any aerial video or still photo flight operations that UEE proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of UEE’s Aircrafts operating 

documents, and Unmanned Eagle Eye, LLC’s proposed operating limitations, ensure that UEE

will safely operate UEE’s Aircrafts (battery powered) during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Unmanned Eagle Eye, LLC Seeks And The Reason Unmanned 

Eagle Eye, LLC 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, Unmanned Eagle Eye, LLC requests relief

from these Sections because UEE’s Aircrafts do not require airworthiness certificates. As set 

forth more fully below, UEE’s Aircrafts meet the conditions of FMRA Section 333 for operation 
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without an airworthiness certificate. Accordingly, Unmanned Eagle Eye, LLC will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs using 

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the UEE

Aerial Operations Manual, Monthly Maintenance Log, and UEE’s Aircrafts Instruction 

Manuals). Furthermore, UEE will document and maintain all maintenance records for UEE’s 

Aircrafts.

D. The Reasons Why Granting Unmanned Eagle Eye, LLC 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 Unmanned Eagle 

Eye, LLC to safely, efficiently, and economically perform aerial video and photography of 

special events, film sets, and landscape over certain areas of the United States. 

Additionally, use of UEE’s Aircrafts will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of Unmanned 

Eagle Eye, LLC’s proposed operation of UEE’s Aircrafts will be realized without implicating 

any privacy issues.

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

UEE’s Aircrafts are battery powered and serve 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 UEE’s Aircrafts 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. 
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Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. UEE’s 

Aircrafts do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography 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.

2. The Public Will Benefit From The Safety And Efficiency Of UEE’s Aircrafts.

Conducting aerial acquisitions with UEE’s Aircrafts, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. By using battery power 

and electric motors, UEE’s Aircrafts produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

aircraft that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. UEE’s Aircrafts, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using UEE’s Aircrafts 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, UEE’s Aircrafts (weighing max 9 pounds 15

ounces, at their maximum gross weights with max diagonal wheelbase of 35.5 inches 

respectively, and with no fuel on board), has less physical potential for collateral damage to life 
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and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With UEE’s Aircrafts 

Will Benefit The Economy.

In addition to being safe and efficient, UEE’s Aircrafts are also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of UEE’s 

Aircrafts will allow United States based companies, like Unmanned Eagle Eye, LLC, 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 UEE’s Aircrafts 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 UEE’s Aircrafts, companies such as Unmanned Eagle Eye, LLC, 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 the commercial use of UEE’s Aircrafts, 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.

4. There Are No Privacy Issues.
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Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Unmanned Eagle Eye, LLC proposed operation of UEE’s Aircrafts will not implicate 

any privacy issues. Specifically, UEE’s Aircrafts will be operated only in compliance with 

operating documents (i.e., the UEE Aerial Operations Manual, Monthly Maintenance Log, and 

UEE’s Aircrafts Instruction Manuals) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the Federal Aviation Regulations, 

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

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 Unmanned Eagle Eye. LLC Seeks Exemption.

1. Reasons Why UEE’s Aircrafts Meet 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, Unmanned Eagle Eye, LLC operation of UEE’s Aircrafts

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

subsection (a), the Secretary shall determine, at a minimum—

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

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and 

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

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

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

certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system.

In seeking this exemption, Unmanned Eagle Eye, LLC submits that UEE’s Aircrafts can 

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

characteristics of UEE’s Aircrafts; (b) the pilot certification requirement; and (c) the specific 

operating limitations.

a. The Specifications Of The UEE’s Aircrafts Demonstrate Its Safe Characteristics.

UEE’s Aircrafts do not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The UEE’s Aircrafts.

The technical specifications of UEE’s Aircrafts are set forth by UEE’s Aircrafts

Specifications and Data Sheet, attached hereto as Exhibit A, Exhibit B, Exhibit C, Exhibit D, 

Exhibit E, and Exhibit F.

ii. UEE’s Aircrafts Autonomous Flight And Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area.
21

UEE’s Aircrafts may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of UEE’s Aircrafts are provided in

UEE’s Aircrafts User Manuals.

iii. UEE’s Aircrafts Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost UEE’s Aircrafts will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, UEE’s Aircrafts does not reacquire control link data from 

the GCS, the UA will assume that the Control Link is lost and the UA will return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of UEE’s Aircrafts are set forth in

UEE’s Aircrafts User Manuals.

iv. UEE’s Aircrafts GCS And Its Operation.

A complete description of the operation and specifications of UEE’s Aircrafts GCS and 

flight control software is provided in UEE’s Aircrafts User Manuals.

b. Flight Operations Of UEE’s Aircrafts Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer.

Unmanned Eagle Eye, LLC will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of UEE’s Aircrafts. 

Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of UEE’s Aircrafts Will Be Conducted Pursuant To Specific Operating 

Limitations.
22

In seeking this exemption, proposes to commercially operate UEE’s Aircrafts for the 

special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UASs weighing less than 55 pounds 

maximum gross weight: UEE’s Aircrafts Unmanned Aircraft Systems. Proposed 

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

grant.

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

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

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

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

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the 

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 

PIC must be able to communicate verbally at all times. Electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

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

permitted to operate the camera or other instruments.
23

9. The operating documents and the grant of exemption must be accessible during UAS 

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

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

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

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

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

update or revision would affect the basis upon which the FAA granted the exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA’s UAS 

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

revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that 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.

11. 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. The PIC who conducts the functional test flight must make an entry 

in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 
24

14. The operator must carry out its maintenance, inspections, and record keeping 

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

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety 

Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third- class 

medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

PICs are permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119.

19. 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). If flight at 

night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted 

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

airport’s management is obtained, and the operation is conducted in accordance with a 
25

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.

21. 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.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined 

location within the planned operating area and land or be recovered in accordance with 

the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

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

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

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under the grant of exemption. 

This COA will also require the operator to request a Notice to Airman (NOTAM) not 

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

operations shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential transponder 

requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial 

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

large as practicable.

27. 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.

28. The documents required fewer than 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 UAS is operating. These 
26

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

upon request.

29. The UA must remain clear and yield the right of way to all manned aviation operations 

and activities at all times.

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

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

(persons other than the PIC, SO, operator trainees or essential 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 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 

owner/controller of such vessels, vehicles or structures 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, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

32. 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 for each flight to be 

conducted.

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

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

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

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov
27

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

(b) Would Not Adversely Affect Safety.

Unmanned Eagle Eye, LLC 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 UEE’s 

Aircrafts unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate UEE’s Aircrafts in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Considering Unmanned Eagle Eye, LLC 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 UEE’s Aircrafts, Unmanned Eagle Eye, LLC

submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for Unmanned Eagle Eye, LLC specific 

proposed flight operations.

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. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

Unmanned Eagle Eye, LLC will not allow any PIC to operate UEE’s Aircrafts unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or UEE’s Aircrafts UAS 

training and currency requirements, that the PIC is able to safely operate UEE’s Aircrafts in a 
28

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

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

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that 

was obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during Unmanned Eagle Eye, LLC proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 
29

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Unmanned Eagle Eye will ensure safe operations by not allowing any PIC 

to operate UEE’s Aircrafts unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate UEE’s Aircrafts in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

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, Unmanned Eagle Eye, LLC will ensure that UEE’s Aircrafts are in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein. 

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, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety.
30

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of UEE’s Aircrafts 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 and altitude. This altitude information, combined with Unmanned 

Eagle Eye, LLC’s operation of UEE’s Aircrafts within visual line of sight, at or below 500 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 is automatically established by the UASs at ground level. 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, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

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 UEE’s Aircrafts; (2) the 

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

operations. Accordingly, Unmanned Eagle Eye will ensure that it will safely operate the battery 

powered UEE’s Aircrafts during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of UEE’s Aircrafts; the 

limitations on the proposed flight operations; and the location of the proposed operations, will 
31

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, 

safety will be ensured as UEE’s Aircrafts provide audible and visual warnings to the PIC at the 

GCS when the UAs experiences low battery voltage, the first warning occurring at 

approximately 33% remaining battery power, and again at approximately 10% remaining battery 

power. At the critically low battery level, UEE’s Aircrafts will descend and land automatically.

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. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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, Unmanned Eagle Eye, LLC 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 

Unmanned Eagle Eye, LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the operating documents (i.e., the Unmanned Eagle Eye Aerial Operations Manual, Monthly 
32

Maintenance Log, and UEE’s Aircrafts Instruction Manuals). Furthermore, Unmanned Eagle 

Eye, LLC will document and maintain all maintenance records for UEE’s Aircrafts. 

Since UEE’s Aircrafts will be inspected as prescribed by the operating documents, 

Unmanned Eagle Eye, LLC will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of UEE’s Aircrafts User Manuals and 

Maintenance Log is attached hereto.

Likewise, the exemption sought will not adversely affect safety because Unmanned Eagle 

Eye, LLC will use trained technicians to perform maintenance, alterations or preventive 

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

operating documents.

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 UEE’s 

Aircrafts will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning 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 consideration of Unmanned Eagle Eye, LLC proposed operating limitations, the 

operating documents, and the technical aspects of UEE’s Aircrafts, Unmanned Eagle Eye, LLC

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 
33

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

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, Unmanned Eagle Eye, LLC requests 

that the FAA prescribe special conditions for the intended operation of UEE’s Aircrafts, which 

contain such safety standards that the Administrator finds necessary 32 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 video and photography over certain areas of the United States for 

compensation or hire. 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 UEE’s Aircrafts, 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 
34

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.

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

prescribe special conditions for Unmanned Eagle Eye’s intended operation of UEE’s Aircrafts, 

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 Unmanned Eagle Eye, LLC Seeks Exemption:

Unmanned Eagle Eye, LLC 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 Unmanned Eagle Eye, LLC

Seeks: 

This exemption will permit Unmanned Eagle Eye, LLC to commercially operate an 

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

photography over certain areas of the United States.
35

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

Eagle Eye, LLC 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, Unmanned Eagle Eye, LLC 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, Unmanned Eagle Eye, LLC will operate UEE’s Aircrafts

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, Unmanned Eagle Eye, LLC 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 UEE’s Aircrafts commercially, without an airworthiness certificate, 

for the limited purpose of conducting aerial video and photography over certain 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 
36

advancing the interests of the public, by allowing Unmanned Eagle Eye, LLC to safely, 

efficiently, and economically operate UEE’s Aircrafts commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Unmanned Eagle Eye, LLC 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 Unmanned Eagle Eye to operate UEE’s 

Aircrafts commercially for the purpose of conducting aerial video and photography over certain 

areas of the United States.

Dated: July 1, 2015

Respectfully Submitted.

Christian Michael Peters

_______________________________

Christian Michael Peters

Unmanned Eagle Eye, LLC

203 Lago Circle Drive N.

Santa Fe, Texas 77517

Phone: (281)-299-6490

Email: cpeters@UnmannedEagleEye.com
37

APPENDICIES

A – DJI S900Manufacturer’s User Manual

B – DJI S1000 + Manufacturer’s User Manual

C – DJI Phantom 3 Manufacturer’s User Manual

D – DJI Inspire 1 Version 2.0 Manufacturer’s User Manual

E – 3DR Solo Manufacturer’s User Manual

F – Tayzu Robotics Quadra Manufacturer’s User Manual

G – Monthly Maintenance Log

APPENDIX-A

DJI S900Manufacturer’s User Manual

APPENDIX-B

DJI S1000 + Manufacturer’s User Manual

APPENDIX-C

DJI Phantom 3 Manufacturer’s User Manual

APPENDIX-D

DJI Inspire 1 Version 2.0 Manufacturer’s User Manual

APPENDIX-E

3DR Solo Manufacturer’s User Manual

APPENDIX-F

Tayzu Robotics Quadra Manufacturer’s User Manual
38

APPENDIX-G

Monthly Maintenance Log

Christian Michael Peters

Unmanned Eagle Eye, LLC

203 Lago Circle Drive N.

Santa Fe, Texas 77517

Phone: 281-299-6490

Email: cpeters@UnmannedEagleEye.com
39