519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

1 | P a g e

April 12, 2015

To: US Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

From: Paul Ramirez, President & COO

Unmanned Ad-Hoc Industries, Inc.

519 E Oak Hill Drive

Spring, TX 77386-1282

(Submitted electronically to the Federal 

Docket Management System-FDMS)

Re: Request for Exemption under section 333 of the FAA Reform Act

Summary of Exemption Request

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, and the Federal Aviation 

Administration’s general exemption authority under Title 49, United States Code, Section 44701(f), 

Unmanned Ad-Hoc Industries, Inc. (“UAI”) hereby petitions for exemptions from the following Federal 

Aviation Regulations specified in Title 14 of the Code of Federal Regulations:

14 CFR Part 21, Subpart H

14 CFR 45.23(a)

14 CFR 61.113(a)(b)

14 CFR 61.133(a)

14 CFR 91.7(a)

14 CFR 91.109(a)

14 CFR 91.119(c)

14 CFR 91.9(b)(2)

14 CFR 91.121

14 CFR 91.151(a)(1)

14 CFR 91.203(a)(b)

14 CFR 91.319(a)(1)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

14 CFR 91.409(a)(1)(2)

14 CFR 91.417(a)(b)

These proposed exemptions, if granted, will allow UAI to operate their High Endurance Folding Frame 

(“HEFF”) Unmanned Aircraft System (“UAS”) and will benefit the following commercial applications:

Agriculture, Oil, Gas, and Mineral Survey/Scan

3-Dimensional Terrain and Structural Modeling

Disaster Response, including Emergency Search & Rescue

Critical Infrastructure Monitoring, including Spectral & Thermal Analysis

Security Awareness
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

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The HEFF UAS uses multiple, swappable onboard cameras to capture high definition imagery and video 

that may be translated into three dimensional models of a surveyed area. UAI’s use of the UAS will grant

landowners, corporations, emergency response teams, and others an overall greater awareness, 

heightened security, safety, as well as negate the need for conventional aircraft assistance. This results 

in enhanced efficiency for any activity conducted, as well as an immediate environmental benefit.

Operation under the anticipated exemption will be subject to strict conditions and requirements, 

ensuring at minimum, an equivalent level of safety to currently authorized operating standards and 

procedures per FAA Regulations.

Supplemental Information:

The following information is to be submitted separately to assist the FAA in making an effective 

evaluation:

Part A: Production Acceptance & Technical Specification of the High Endurance Folding Frame (HEFF)

Part B: Unmanned Ad-Hoc Industries, Inc. Flight Operations and VLAUAS Guidelines

Part C: Operator and Observer Training Standard and Certification Example

Part D: HEFF Aircraft Logbook and Maintenance Reporting

Part E: UAI Summary of Manned and Unmanned Experience & Certifications

Background of Applicant

Unmanned Ad-Hoc Industries, Inc.

Attn: Paul Ramirez

519 E Oak Hill Drive

Spring, Texas 77386

Phone: (888) 396-5924, ext. 1

Email: Paul.Ramirez@globaluai.com

Unmanned Ad-Hoc Industries was formed in 2014 to fill a clear need in the UAS commercial market for 

remote sensing applications. UAI has assembled a group of professionals each with over 9 years of 

worldwide UAS experience in safety, flight operations, project and site management, engineering 

design, and system integration; bringing an unparalleled level of professionalism and safety expertise to 

an emerging market. UAI is strictly a services provider, and will not sell any of its UAS components

individually.
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

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Aircraft Overview

The HEFF aircraft is of quad-rotor design, based around a custom fabricated carbon fiber chassis. Two 

lithium polymer batteries power four counter-rotating electric motors in order to provide exceptional 

predictability, endurance, stability, and control. In operational configuration, the aircraft weighs less 

than 25lbs and has dimensions of; length 31”, width 41”, and height 23”. Maximum flight endurance is

45 minutes, while maximum limited airspeed is 60 knots. Although highly maneuverable, the HEFF 

aircraft was designed with intent to hover in place primarily. GPS utilization and redundant altimeter 

technology onboard the HEFF’s flight controlling computer ensure an accurate physical position is 

always maintained while minimizing potential failures. The aircraft, via its tablet computer Ground 

Control Station, is capable of autonomous launch and recovery, as well as waypoint routing. A handheld 

remote controller acts as the Operator’s direct line to aircraft control, and is capable of initiating an 

automatic return home sequence. Should Command and Control (“C2”), data link, or battery level (20%) 

become jeopardized, the aircraft will automatically execute a pre-programmed emergency sequence. 

Depending on the emergency, this may include hovering in place for a preset time, returning home on a 

planned route, or landing autonomously. 

UAI will require at least one company-trained, FAA Ground School certified Operator and one companytrained Visual Safety Observer during operations in order to maintain positive physical and visual control 

of the aircraft at all times. Because the HEFF is equipped with typical aircraft navigation lighting it is clear 

that the unmanned aircraft is more clearly visible during night time conditions when compared to the 

ability to visually spot the vehicle during daylight hours. For this reason UAI believes that by operating its 

aircraft above 400 feet, near airports, or generally near populated areas in which people are not made 

aware and consent to unmanned operations will cause unacceptable safety risk and will not operate 

within these conditions. If granted exemption, UAI will yield right-of- way to all manned operations, as 

well as file appropriate NOTAMs prior to any operations in the NAS.

Aircraft Lighting:

Forward & Aft Left: Red

Forward & Aft Right: Green

Atop Aircraft: Red Rotating Beacon

Below Aircraft: White Strobe
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

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Training

UAS Operator

UAI requires every Operator to be fully qualified on its HEFF UAS appropriately. Trainees are given 

demonstration in general skills such as; maintaining altitude, maintaining visual line of sight, general 

navigation principles, obstacle avoidance, air traffic de-confliction, and emergency procedures. 

Qualification as an Operator for the HEFF UAS requires the Operator trainee to show proficient levels of 

all aforementioned skill areas, with special emphasis on emergency procedures. 

UAS Safety Observer

UAI requires every person who will be acting as a flight safety observer to be proficient in airspace 

knowledge, emergency procedures, aeronautical chart interpretation and airspace safety, ground 

operations, ATC radio frequency communication. Two-Way radio communication will be established 

between the UAS operator and safety observer(s) during flight operations. HEFF Level 1 operator 

certification is the minimum standard for safety observer qualification. 

Currency is maintained through monthly aircraft flights and instruction.

Authority for Petition

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a method for 

seeking expedited FAA authorization of safe, civil UAS operation in the National Airspace System 

(“NAS”).

Section 333(a) states that 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.”

Section 333(b) outlines any factors the Secretary of Transportation must consider in order to determine 

whether commercial UAS operation should be approved. These factors include at minimum “[the UAS’s]

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 [...]”

Section 333(c) states that should the Secretary determine a certain UAS may operate safely in the NAS, 

“the Secretary shall establish requirements for safe operation of such aircraft systems in the National 

Airspace System.”

Section 44701(f) of Title 49, United States Code, states that “The [FAA] Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or 

any of sections 44702-44716 of this title if the Administrator finds the exemption is in public interest.”
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

5 | P a g e

Explanations

14 CFR Part 21, Subpart H: Procedural requirements for issuing and changing design approvals, 

production approvals, airworthiness certificates, and airworthiness approvals

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR § 91.203(a)(1). Given the size and weight of the HEFF 

aircraft (25 lbs) and the limited operating area associated with its utilization, it is unnecessary to go 

through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current 

safety levels. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS 

involved. 

In this case, an analysis of these criteria demonstrates that the HEFF operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The HEFF weighs 25 lbs fully 

configured. It will not carry a pilot or passenger, will not carry flammable fuel, and will operate 

exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations 

under this exemption will be tightly controlled and monitored by both the operator, pursuant to the 

conditions set forth above, and by local public safety requirements. The FAA will have advance notice of 

all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size 

of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not 

flown there all establish the equivalent level of safety. 

 Lightweight (<25lbs), small form factor aircraft

 Powered by sealed lithium polymer batteries, eliminating fuel spillage or risk of fire

 Remote crew location, eliminating risk in the event of an incident

 Waypoint/Route programming capability, ensuring obstacle/obstruction avoidance

 Built in fail-safe modes (hover in place, return to home, autonomous landing)

After consideration of the size, weight, speed, and limited operating area associated with the aircraft 

and its operation, UAI believes exemption from 14 CFR Part 21 should be granted.
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

6 | P a g e

14 CFR 45.23(a): Display of marks; general

The HEFF does not have an entrance to a cabin, cockpit or pilot station in order to place required 

markings. Due to the size of the aircraft, 2 inch lettering is not possible. The HEFF will have a 1” marking 

denoting its tail number which will achieve an equivalent level of safety as required by §45.29(f) in 

which the pilot, observer, and others ground crew personnel attending to work on the aircraft will see 

each aircraft with a specific marking to denote aircraft serial number. Aircraft to be flown will be 

registered in accordance with 14 CFR part 47. 

UAI requests exemption be granted from 14 CFR Part 45.

14 CFR 61.113(a) and (b); 61.133(a): Private pilot privileges and limitations; Pilot in Command; 

Commercial Pilot Privileges and Limitations

UAI’s intent:

 Provide UAS services over property only with permission from landowner

 Display appropriate warning signage on all borders of property during operation

 Maintain high level UAS airmanship skillset via UAI specified currency & training requirements

 Ability to achieve equivalent level of safety required by current regulations

 As operation of UAS is fundamentally different than manned aircraft, the current level of air and 

ground instruction of all aircraft operators (see Supplemental Information, Part E) is sufficient 

for safe UAV operations. A private pilot’s license does not apply to UAV operations and should 

not be considered as a minimal qualification to perform unmanned aircraft operations. 

Furthermore, a commercial pilot certificate as prescribed in Part 61.133 is outside the scope of 

the proposed unmanned aircraft operations as no carrying of persons or property will be 

performed. 

UAI believes exemption from 14 CFR 61.113(a) and (b); 61.133(a) should be granted.

14 CFR 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there is no published standard for validating airworthiness condition of the HEFF aircraft, UAI will abide 

by internal company process documentation to validate operational functionality which will achieve an 

equivalent level of safety by ensuring compliance with all maintenance and inspection manuals

(Supplemental Information, Part D).

UAI believes exemption from 14 CFR 91.7(a) should be granted.
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

7 | P a g e

14 CFR 91.119(c): Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits 

aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.

An equivalent level of safety will be achieved given the size, weight, speed, and material with which the 

HEFF is built. Flight operations will not occur without the permission of the land owner/authorized agent

or those who control the land. Because of the advance notice to the landowner, all affected individuals 

will be aware of the unmanned flight operations. Compared to aerial survey operations conducted with 

aircraft or rotorcraft carrying flammable fuel, any risk associated with these operations will be far less 

than those currently allowed with conventional aircraft operating at or below 500 feet AGL. The lowaltitude operations of the UAS will maintain separation between these small-UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119.

The ideal altitude for the projects proposed within this request will be at or below 400 feet above 

ground level and standard operational procedures will provide for a constant airspace awareness to 

allow for maximum separation between small UAS operations and operations of conventional manned 

aircraft. Additionally, UAI operators and observers will display appropriate warning signage on all 

perimeters of surrounding property while UAV operations are in progress. 

UAI believes exemption from 14 CFR 91.119(c) should be granted, as an equivalent level of safety will be 

achieved.

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

The regulation requires that any person to operate a U.S.-registered civil aircraft “[...]

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof.”

Given the size of the HEFF, it has no ability or place to carry such a flight manual on the aircraft, not only 

because there is no pilot on board, but because there is no room or capacity to carry such an item on 

the aircraft. 

The equivalent level of safety will be achieved by keeping the flight manual (Supplemental Information, 

Part A) at the ground control point where the pilot flying the UAS will have immediate access to required 

flight manual documentation.

UAI believes exemption from 14 CFR 91.9(b)(2) should be granted, as an equivalent level of marking and 

documentation will be achieved.
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

8 | P a g e

14 CFR 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

In operational configuration, the HEFF is a remotely piloted aircraft and does not have fully functional 

dual controls. Flight control is accomplished through the use of a control box or ground control station 

that communicates with the aircraft via line-of-sight radio communications. The flight plan is preprogrammed into the autopilot before or during flight and may also receive manual pilot input control 

functions to alter the pre-programmed flight. If instruction is accomplished through a training program, 

as set forth in Part C of the Supplemental Information, an equivalent level of safety will be assured. The 

FAA has approved exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft (5778K & 9862A). The equivalent level of safety 

will be achieved by the manufacturer providing the training and through the use of experienced and 

qualified pilots familiar with the HEFF.

UAI believes exemption from 14 CFR 91.109(a) & 91.319(a)(1) should be granted.

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows: 

(a) [...] no person may operate a civil aircraft unless it has [...] an appropriate and current airworthiness 

certificate. 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The HEFF when fully configured for flight operations weighs no more than 25 lbs. As such, there is no 

ability or place to carry certification and registration documents or to display them on the UAS. In 

addition, there is no pilot on board the aircraft. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous 

exemptions to this regulation. 

UAI believes exemption from 14 CFR 91.203 (a) & (b) should be granted, as the regulation is not 

applicable to its HEFF UAS.
519 E Oak Hill Drive, Spring, Texas 77386-1282

Phone: 888-396-5924 • Email: info@globaluai.com

9 | P a g e

14 CFR 91.121: Altimeter settings

Section 91.121 requires aircraft operators to maintain cruising altitude or flight level by reference to an 

altimeter. As the HEFF UAS utilizes Global Positioning System and internal redundant barometric 

altimeters flight level will be determined using this type of instrumentation. 

UAI believes exemption from 14 CFR 91.121 should be granted, as the regulation is not applicable.

14 CFR 91.151(a)(1): Fuel requirements for flight in VFR conditions

Due to the HEFF UAS being battery powered, UAI believes exemption from 14 CFR 91.151(a)(1) should 

be granted, as the regulation is not applicable.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a)(b): Maintenance Requirements

Section 91.405(a) requires that an aircraft operator or owner “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 [...]” 

Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an 

annual inspection for the issuance of an air worthiness certificate. Section 91.417(a) requires the owner 

or operator to keep records showing certain maintenance work that has been accomplished by 

certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return 

to service.

UAI has prescribed a specific process and inspection standard that will allow an equivalent level of safety 

to be achieved as a result of diligent and consistently applied maintenance practices. The aircraft 

operator is responsible for accurate status upkeep of the maintenance record to include the battery 

maintenance log, ensuring the UAS is in safe condition for flight operations, and ensuring all software is 

current prior to aircraft operation. Through this, UAI believes exemption from the listed regulations 

should be granted.

Summary

UAI believes that approval from the FAA will enhance efficiency and safety in any operation its HEFF UAS 

conducts, due to reducing the need for manned aircraft. Due to its camera-only payload capability, lack 

of cargo, fuel or combustible materials in general, aircraft size, weight, and limited operating area, the 

HEFF UAS presents no major risk to individuals, nor poses any threat to National Security. While 

adhering to at least an equivalent level of safety of all current regulations, UAI firmly believes 

exemptions to the listed regulations should be granted, and operation of its HEFF UAS commercially 

should be permitted.