Prepared by Josh Gray- Spin Widgets December 21, 2015 

Attention: US Department of Transportation Docket Operations W.~st 

Building Ground Floor, Room W12-140 Uh 3 I 11 l 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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

the Federal Aviation Regulations from 14 CFR 45.23{b}; 14 CFR Part 21; 14 

CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 

91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a) (2); 91.417 (a) & (b) 

Dear UAS Integration at Federal Aviation Administration, 

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

(the Reform Act) and 

14 CFR Part 11, Spin Widgets, a research developer and operator of Small 

Unmanned Aircraft Systems ("UASs") equipped to conduct aerial 

photography for industrial, Real State, agriculture, motion picture, and 

Television industry for scripted closed set filming, hereby applies for an 

exemption from the listed 

Federal Aviation Regulations ("FARs") to allow commercial operation of its 

UASs (Fixed-wing & Multi-Rotor), so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the 

operation of small, unmanned and relatively inexpensive UAS under 

controlled conditions in airspace that is 1) limited 2) predetermined 3) 

controlled as to access and 4) would provide safety enhancements to the 

already safe operations in the industrial, film, and television production 

community presently using conventional and unmanned aircraft. Approval 

of this exemption would thereby enhance safety and fulfill the FAA 

Administrator's responsibilities to " ... establish requirements for the safe 

operation of such aircraft systems in the national airspace system." Section 

333 (c) of the Reform Act. The conditions proposed by the applicant are 

drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8 Issue a Certificate of 
Waiver for industrial, agriculture, Real State, motion picture, and Television 

industry. 

The name and address of the applicant is: 

Spin Widgets 

Attn: Josh Gray 

Phone: 928-202-6618 

Email: admin@spinwidgets.com 

Address: 610 N. Main St, Cottonwood, AZ 86326 

Locations for Exemption Request Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b); 14 CFR 

Part 21; 14 CFR 61.113 (a) & (b); 91.7 

(a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & 

(b); 91.409 (a) 

(2); 91.417 (a) & (b) are: 

1. Spin Widgets Cottonwood, AZ 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

Privacy 

All flights will occur over private and controlled access property with the 

property owner's prior consent and knowledge. Image capture of people will 
rarely take place, but in the event they are, they will have consented prior to 

being filmed or otherwise have agreed to be in the area where data 

collection will take place. 

Airborne (Day & Night) 

With regard to airborne Spin Widgets adheres to all FAA regulations. Further 

Spin Widgets airborne teams operate under the principals of: Safety First, 

Quality Assurance, Accountability, Reporting, and Training. When approved 

by the FAA it is SpinWidgets' mandate to treat all UAS operations the exact 

same as that of conventional aircraft. 

Approval of exemptions allowing commercial operations of UASs in the 

industrial, agriculture, Real State, motion picture, and Television industry 

will enhance safety by reducing risk. Conventional operations, using jet or 

piston powered aircraft, operate at extremely low altitudes just feet from 

the subject being in extreme proximity to people and structures; and 

present the risks associated with vehicles that weigh in the neighborhood of 

4,000ibs., carrying large amounts of Jet A or other fuel {193 gallons for jet 

helicopter shown below). Such aircraft must fly to and from location. In 

contrast, a UAS weighing fewer than SSibs and powered by batteries 

eliminates virtually all of the risk given the substantial reduced mass and 

lack of combustible fuel carried on board. 

The UAS is typically transported to the location via auto or cargo van in a 

medium sized case and is never flown to set. The UAS will carry no 

passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighting less than SSibs., conducted in the 

strict conditions outlined above, will provide an equivalent level of safety 

supporting the grant of the exemptions requested herein, including 

exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment and, as a result, are far 

safer than ground than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people. 
The primary uses of interest for Spin Widgets utilizing UASs are as follows: 

Visual inspections, Photo and Video of: 

1. Gas and Oil Wells 

2. Agriculture Land Mapping 

3. Rea I Estate 

4. Telecommunications Towers 

5. Power lines 

6. Structurallntegrity 

7. Motion Picture 

8. Television Industry 

It is estimated that the use of UAS aircraft will reduce hazardous tower 

climbs Poles Wells etc, Aside from reducing the number of physical climbs, 

the utilization of UAS will dramatically lower the use of cranes and lifts, 

which also pose dangerous conditions for build and repair personnel. In a 

number of instances, inspectors just need to get "eyes on" the tower top 

assemblies to look for specific deficiencies. With regard to power lines when 

climbers are sent in the power must be deferred. The use of UAS may allow 

these industries to fill in the data gaps where traditional aircraft are 

currently restricted. 

It is anticipated that the airborne image capture process will be 
·-------~·~~~~~~~~~~~~~~~-~~--------------

accomplished in both day and night environments. Currently, conventional 

aircraft are flown in highly populated and/or urban areas, with turbine 

powered helicopters. The grant of this exemption request will provide 

improved safety in both day and night operations. To capture the highest 

quality of resolution the majority of airborne data collections will take place 

during the 10:00am- 4:00pm window. 

There may be night operations conducted where infrared sensors will be 

deployed. If such operations are required the ground facilities and the 

subject tower/Pole/Wells assemblies may require additional lighting so that 

visibility is as though it was conducted during daylight hours. 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 

333 (a) through (c) of the Reform Act. This directs the FAA to consider 

whether certain unmanned aircraft systems may operate safely in the 

national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, 

the FAA is required to determine which types of UASs do not create a hazard 

to users of the NAS or the public or pose a threat to national security in light 

of the following: 

. The UAS's size, weight, speed, and operational capability: 

. Operation of the UAS in close proximity to airports and populated areas; 

and 

. Operation of the UAS within Visual Line of Sight (VLOS) of the Operator 

(PIC) and Observers. 

Reform Act §333 (a). Lastly, if the FAA determines that such vehicles "may 

operate safely in the national airspace system, the FAA shall establish 

requirements for the safe operation of such aircraft in the national airspace 

system." ld. §333 (c) (emphasis added). 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority by its terms includes exempting civil 

aircraft, as the term is defined under 

§40101 of the Act, the mat includes UASs, from the requirement that all civil 

aircraft must have a current airworthiness certificate. The Administrator 
may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 

49 U.S.C. §44704; 14 CFR §91.203 (a) (1). 

Applicant interprets this provision to place of the duty on the Administrator 

to not only process applications for exemptions under section 333, but for 

the Administrator to craft conditions herein for the safe operation of the 

UAS, if it should be determined that the conditions set forth herein do not 

fulfill the statutory requirements for approval. 

Spin Widgets' UASs are multi-rotorcraft and fixed-wing aircraft, weighing 55 

or fewer lbs. including sensor payload. They operate their multi-rotorcraft, 

under normal conditions at a speed of no more than 50 knots and have the 

capability to hover, and move in the vertical and horizontal plane 

simultaneously. They operate their fixed-wing aircraft, under normal 

conditions at a speed of no more than 50 knots and primarily have the flight 

characteristics of traditional airplanes. They will manually operate only in 

VLOS and will operate only within the sterile area described in the 

Confidential: Flight Operations Manual (FOM) attached as Exhibit 1 

(hereinafter "the Manual").3 Adherence to the Manual will insure that the 

UAS will"not create a hazard to the national airspace system or the public. 

Given the small size and weight of the UAS involved and the restricted 

sterile environment within which they will operate, the applicant falls 

squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial 

operations of UASs to commence immediately. Also due to the size of the 

UASs and the restricted areas in which the relevant UAS will operate, 

approval of the application presents no national security issue. Given the 

clear direction in Section 333 of the Reform Act, the authority contained in 

the Federal Aviation Act, as amended; the strong equivalent level of safety, 

surrounding the proposed operations, and significant public benefit, 

including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing UASs for inspection and survey 

operations, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the 
requested exemption without delay. 

The Flight Operation Manual is presented as an applicant confidential 

document under 14 

CFR 11.35 (b) as the entire manual contains proprietary methods and 

information that the applicant has not and will not share with others. The 

manual reflects learned experiences, methods, operating conditions, and 

procedures that are not available to the public and are protected from 

release under the Freedom of Information Act 5 USC 552 et.seq. Reform Act 

Section 333 (b) 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil 

aircraft that have the characteristics and that operate with the limitations 

listed herein. These limitations provide for at least an equivalent or even 

higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the 

already safe Videography and Photography operations conducted with 

conventional aircraft. These limitations and condition to which SpinWidgets 

agrees to be bound when conducting commercial operations under an FAA 

issued exemption include: 

1. The UAS will weigh less than 55 lbs Constructed by high reputation 

companies, single, Multicopter base on application. 

2. Flights will be operated manually within visual line of sight (VLOS) of 

the Operator (PIC) and Observers 

3. Maximum total flight time for each operational flight will depend on 

battery charge, the average flight will be 30 +/-minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to 

the 30 +/-minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, 
not more than 200 feet above an elevated platform from which 

airborne data collection is planned. 

5. Minimum two (2) man crew for each UAS operation will consist of the 

Operator (PIC) and Observers. In most cases the third aircrew member 

will serve as the Camera I Sensor Operator. 

6. The UAS Pilot will be an FAA licensed airman with at least a private 

pilot's certificate and Class 2 (or higher) airmen medical certificate. 

The Camera I Sensor Operator and Spotter (Observer) will hold at 

least a Class 2 (or higher) airmen medical certificate and TSA Security 

Screening. 

7. The UAS Pilot will serve as Pilot in Command {PIC). The PIC will possess 

at least a private pilot certificate and at least a current Class 2 (or 

higher) airmen medical certificate to meet the flight review 

requirement specified in 14 CFR § 61.56. 

8. The UAS pilot (PIC) will have a COA prior to conducting any operations, 

the COA will be submitted in conjunction with this petition of 

exemption 333. 

9. Prior to any operations conducted by Spin Widgets, the PIC will have 

accumulated and logged a minimum of 200 flight cycles and 25 hours 

of total flight time with an UAS, and 10 hours in the UAS flight 

simulator, accordance with CFR § 61.51 (b). 

10. Prior to operations the PIC will have a minimum of five hours as a UAS 

pilot operating and three take-offs and landing in the preceding 90 

days. 
11. The UAS will only operate within a confined "Sterile Area,. 

610 N. Main St, Cottonwood, AZ 86326 928-202-6618 

www.spinwidgets.com 

12. Spin Widgets will develop procedures to document and maintain a 

record of the UAS maintenance, preventative maintenance, alteration 

records, and status of replacement/overhaul component parts. 

13. A pre-flight briefing will be conducted in regard to the planned UAS 

operation prior to each day's production activities. It will be 

mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

14. The Operator will file a FAA Form 7711-1, or its equivalent, as 

modified in light of the requested exemption, with the appropriate 

Flight Standards District Office (FSDO). 

15. The Operator will obtain the consent of all persons involved in the 

filming and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and this radius may be reduced to 30 

feet based upon an equivalent level of safety determination, With the 

advanced permission of the relevant FSDO, operations at closer range 

can be approved. 

16. The Operator will submit a written Plan of Activities to the FSDO three 

(3) days before the proposed shoot as required by the Manual. 

17. Operator (PIC) and Observers will have been trained in operation of 

UAS generally and received up-to-date information on the particular 

UAS to be operated as required by the Manual. 
-···---------------------------------------

18. Spotter (Observer) and Pilot will at all times be able to communicate 

by voice, radio, and/or text. 

19. Written and/or oral permission from the relevant property holders will 

be obtained. 

20. All required permission sand permits will be obtained from territorial, 

state, county or city jurisdictions, including local law enforcement, fire, 

or other appropriate governmental agencies. 

21. If the UAS loses communications or loses its GPS signal, the UAS will 

have capability to return to a pre-determined location within the 

Security Perimeter and land. 

22. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles emergencies. 

23. The UAS Will 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. 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) {1) 

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 limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act {49 

U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA 

to exempt aircraft from the requirement capability, and proximity to 

airports and populated areas of the particular UAS. In all cases, an analysis 
of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed-wing or multi-rotorcraft) operating with an airworthiness 

certificate without the restrictions and conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries 

neither a Pilot nor Observers, carries no explosive materials or flammable 

liquid fuels, and operates exclusively within a secured area as set out in the 

Manual. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by both the Operator, pursuant to safety 

requirements, and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation as 

is now done with conventional tools. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil aircraft 

operated in connection with Videography and Photography production, 

provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by 

the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

14 CFR §45.23 (B): Marking of the Aircraft The regulation requires: 

The registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, the 

operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than 2 inches nor more than 6 

inches high, the words "limited," "restricted", 111ight-sport," "experimental," 

or 11provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption 

may be needed as the UAS will have no entrance to the cabin, cockpit or 

pilot station on which the word "Experimental" can be placed. Given the size 

of the sUAV, two-inch lettering will be impossible. The word "Experimental" 
will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked 

on its fuselage as required by §45.29 (f) where the Operator (PIC) and 

Observers and others working with the sUAV will see the identification of 

the UAS as "Experimental." The FAA has issued the following exemptions to 

this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations -Pilot in 

Command (PIC) 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a Pilot or Observers, the proposed operations 

can achieve the equivalent level of safety of current operations by requiring 

the PIC operating the aircraft to have a private pilot's license rather than a 

commercial pilot's license to operate this small UAS. Unlike a conventional 

aircraft that carries the Operator (PIC) and Observers, the UAS is remotely 

controlled with no living thing on board. The area of operation is controlled 

and restricted, and all flights are planned and coordinated in advance as set 

forth in the Manual. The level of safety provided by the requirements 

included in the Manual exceeds that provided by single individual holding a 

commercial pilot's certificate operating a conventional aircraft. The risks 

associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 CFR 

§61.113 (a) & (b). 

14 CFR §91.7 (a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is 

in airworthy condition. As there will be no airworthiness certificate issued 

for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the 

aircraft and the requirements contained in the Manual for maintenance and 

use of safety check lists and a preflight inspection, all maintenance and 

alterations will be properly documented in the aircraft records prior to each 

flight, an equivalent level of safety will be provided. 
14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft Section 91.9 

(b) (2} provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2} For which an Airplane or Multi-rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current 

approved Airplane or Multi-rotorcraft Flight Manual, approved manual 

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

The UAS, given its size and configuration 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 maintained by keeping the flight 

manual at the ground control point where the pilot flying the UAS will have 

immediate access to it. The FAA has issued the following exemptions to this 

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 95658, 10167, 10167A 10602, 32827, and 10700 

14 CFR §91.103: Preflight Action 

This regulation requires each pilot in command to take certain actions 

before flight to insure the safety of flight. As FAA approved multi-rotorcraft 

flight manuals will not be provided for the aircraft an exemption will be 

needed. An equivalent level of safety will be provided in the Manual. The PIC 

will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation 

of flight. 

14 CFR §91.109: Flight Instruction 

Section 91.103 provides 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. UASs and remotely piloted 

aircraft, by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. 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. See 

Exemptions Nos. 5778K & 9862A. The equivalent level of safety provided by 

the fact that aircraft. 

14 CFR §91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the 

minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a UAS that is a fixed-wing or multi-rotorcraft 

requests authority to operate at altitudes up to 400ft. AGL, or not more 

than 200ft. above an elevated platform from which filming inspections is 

planned, an exemption may be needed to allow such operations. As set 

forth herein, except for the limited conditions stated in the Manual, the UAS 

will never operate at higher than 400ft. AGL. It will however be operated in 

restricted area with security perimeter, where buildings and people will not 

be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed 

of the UAS as well as location where it is operated. No flight will be taken 

without the permission of the property owner or local officials. Because of 

the advance notice to the property owner and participants in the filming 

activity, all affected individuals will be aware of the planned flight operations 

as set forth in the Manual. Compared to flight operations with aircraft or 

multi-rotorcraft weighing far more than the maximum 55 lbs. proposed 

herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional 

aircraft operating at or below 500ft. AGL in this industry. In addition, the 

low-altitude operations of the UAS will ensure separation between these 

small UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

14 CFR §91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set 11 

... to the elevation 

of the departure airport or an appropriate altimeter setting available before 
departure." As the UAS may not have a barometric altimeter, but instead a 

GPS altitude read out, an exemption may be needed. An equivalent level of 

safety will be achieved by the operator, pursuant to the Manual and Safety 

Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions 

/ 

Section 91.151 (a) prohibits an individual from beginning "a flight in an 

airplane 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- (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 

45 minutes." 

The battery powering the UAS provides approximately 40 minutes of 

powered flight. To meet the 30 minute reserve requirement in 14 CFR 

§91.151, UAS flights would be limited to approximately 10 minutes in 

length. Given the limitations on the UAS's proposed flight area and the 

location of its proposed operations within a predetermined area, a longer 

time frame for flight in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within 

the scope of prior exemptions. See Exemption 10673 (allowing Lockheed 

Martin Corporation to operate without compliance with FAR 91.151 (a)). 

Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserved fuel, does not engender the 

type of risks that Section 91.151 (a) was intended to alleviate given the size 

and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes 

would greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power whichever happens 

first. This restriction would be more than adequate return the UAS to its 

planned landing zone from anywhere in its limited operating area. 

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and 
Registration The regulation provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil 

aircraft unless it has within it the following: 

(1} An appropriate and current airworthiness certificate ... 

(b) No person may operpte a civil aircraft unless the airworthiness 

certificate required by paragraph (b) 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 UAS fully loaded weighs no more than 55 lbs. and is operated without 

an on board Pilot. As such, there is no ability or place to carry certification 

and registration documents or to display them on the UAS. 

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, to the extent they are applicable to the UAS. 

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections 

These regulations require 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 © of this section, 

have discrepancies repaired as prescribed in Part 43 of this chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an 

airworthiness certificate, these sections will not apply to the applicant. 

Maintenance will be accomplished by the operator pursuant to the flight 

manual and operating handbook as referenced in the Manufactures Manual. 

An equivalent level of safety will be achieved because these small UASs are 

very limited in size and will carry a small payload and operate only in 

restricted areas for limited periods of time. If mechanical issues arise the 

UAS can land immediately and will be operating from no higher than 400ft. 

AGL. As provided in the Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed. Moreover, the operator is the 
person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register, should it be determined that publication 

is needed: 

Applicant seeks an exemption from the following rules: 

14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 

(a); 91.9 (b) (2); 

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 {a) & {b); 91.405 {a); 

91.407 {a) {1); 

91.409 (a) (2) and 91.417 {a) & {b) to operate commercially a small 

unmanned vehicle {551bs or less) in industrial area and industrial operations. 

Summary 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 

-size, weight, speed, operating capabilities, proximity to airports and 

populated areas and operation within visual line of sight and national 

security- provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of applicant's UAS in 

the industrial, Videography and Photography production industry pursuant 

to the Manual appended hereto. Spin Widgets is eagerly standing by to 

support the FAA and UAS community in its quest to establish proper 

regulations and protocols for the safe introduction of unmanned aircraft 

into the national airspace. 

Sincerely, 

Josh Gray 

Founder and Owner 

SpinWidgets 928.202.6618