us Deporrmenl 

of Tronsponolioo 

Federal Aviation 

Administration 

June 29, 2015 

Charles Roberts 

2090 Brush Grove Road 

Rochelle, JL 61068 

Dear Mr. Roberts: 

800 Independence Ave . S W 

Wash•nglon DC 20591 

This letter is to infonn you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days. 

Why We Can Not Process Your Request 

We entered your June 25,2015, exemption request into the public docket (No. FAA-2015-

2178), but we are unable to process your request any further. The information you sent does 

not comply with the requirements of§ 11.81 (copy enclosed). For us to consider the request 

any further, you must send us all of the following: 

• The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief. 

G The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

• The reasons why 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 you 

seek an exemption. 

• Any additional infonnation, views, or arguments available to support your request. 

What You Should Do 

If you 'vant us to process your request any fu11her, you must send the information described 

earlier to reach us within 30 days. Please note that § ll.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption. 
If We Do Not Hear From You 

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677. 

Sincerely, 

Brenda Robeson 

Program Analyst, Airmen and 

Airspace Rules Division 

Enclosure 

2 
August 12, 2015 

Brenda Robeson 

Program Analyst, Airmen & Airspace Rules Division 

US Department of Transportation 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington DC 20591 

Re: Response to your letter dated 6/29/2015 

Dear Ms. Robeson: 

Attached is my response to your letter dated 6/29/2015 (also attached). 

Sincerely, 

Charles C. Roberts, Jr. 

2090 Brush Grove Rd. 

Rochelle, IL 61 068 
Charles C. Roberts, Jr. requests 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)(l), 9 1.409(a)(l) & (a)(2), 

and 91.417(a) & (b), and permit Charles C. Roberts, Jr. to operate property surveys in the 

United States, as follows. 

Charles Roberts seeks relieffrom Section 6l. ll 3(a) and (b), entitled "Private Pilot 

Privileges and Limitations: Pilot in Command (PIC)" : 

Charles Roberts states that safety will not be compromised because the PIC will be 

thoroughly trained in the operation ofthe UAS which includes several hours of flight 

operation, training in safety procedures according to the manufacturer's manual, and training 

in the fail safe system provided by the UAS manufacturer. The operator wi ll be in good 

physical condition. The usage of the UAS will be incidental to the business of Charles 

Roberts and will not carry passengers. 

Charles Roberts seeks relief from Section 91.7(a) entitled "Civil Aircraft Airworthiness": 

Charles Roberts states that prior to each usage, the UAS will be tested to insure an airworthy 

condition as per the manufacturer's manual. The UAS does not require an airworthiness 

certificate in accordance with C.F .R. Part 21 , Subpart H, as it is in compliance with the 

operation manual prior to each usage and has satisfied any maintenance related questions. 

Charles Roberts seeks relief from Section 91. 12 1. entitled "Altimeter Settings": 

Charles Roberts states that the UAS zero altitude will be set at the launch site rather than at a 

local barometric pressure instrument before each usage. FAA requires reporting altitude 

information on UAS operation, but the altitude reading will not have the same reference as 

that from a local barometric pressure instrument. Since the flights are of limited altitude, 

relief is requested because altitude settings are reset at launch and an equivalent level of 

safety will be achieved from usage of the onboard UAS barometric pressure sensing system. 

Charles Roberts seeks relief from Section 91.151 (b). entitled "Fuel Requirements for Flight 

in VFR Conditions": 

Charles Roberts states that battery powered flight of approximately 10 minutes during 

daylight hours in VFR conditions is the capability of UAS. The 20 minute additional flight 

time requirement cannot be achieved with such a UAS because of limited battery capacity. 

Consequently, relief is sought. 

Charles Roberts seeks relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.4 17(a) & (b): 

Charles Roberts states that the above sections refer to aircraft with an airworthiness 

certificate. The UAS does not require an airworthiness certificate. Consequently, relief is 

sought. Charles Roberts will be using trained technicians to perform maintenance on the 

UAS as well as document the maintenance. 
Reasons it would benefit the public for allowing relief for Charles Roberts: 

Granting the request will benefit the public interest by allowing Charles C. Roberts, Jr. to 

perform aerial surveys of farm fields which result in increased productivity, increased farm 

crop yields and more food available to society. Granting the request will benefit the public 

interest by allowing Charles C. Roberts, Jr. perform aerial surveys of buildings which will 

result in decreased congestion in the air space, reduction in pollution since internal 

combustion engine aircraft will not be used, reduced noise pollution, increased safety since 

the mass of the vehicle is very low and reduced cost of building analysis. The battery 

powered UA V will save several gallons of aviation fuel when compared to a conventional 

manned aircraft. The UA V weighs less than 3 pounds, reducing the chance of damage to 

life and property when compared to a several thousand pound manned aircraft and crew. 

The UAS will benefit the economy, will offer greater flexibility for close in analysis of the 

subject property, with significantly reduced cost over manned aircraft.