Petition for exemption / rulemaking 

This is an exemption request pursuant to FMRA Section 333 and Part 11 of the 

FAA Reform Act of 2012 for Strategic Designs. 

The proposed exemption, if granted, would allow Strategic Designs to conduct 

commercial operations of small unmanned aircraft systems (“UAS”) meeting or 

exceeding all of the operational and safety requirements Congress has set forth 

in Section 333. 

Petitioner is an aerial service and technology company that plans to exploit the 

capabilities of Unmanned Aerial Systems to offer a multitude of services, 

including: 

- Aerial surveying / inspections - Remote sensing - Telecommunications -

Agriculture - Aerial filmmaking and photography - Energy systems inspections 

and asset management / wind turbine inspection 

- Construction site inspections and monitoring - Wildlife and forestry monitoring

- Educational and research operations - Pipeline / cell tower inspections

Pilot in Command (PIC) The pilot in command will be the owner of Strategic 

Designs, Mr. Brian Gaudet. Mr. Gaudet received his airman’s Private Pilot 

Certificate in 1977, number 3638364 and holds a current FAA-issued 3rd class 

airman medical certificate. Mr. Gaudet has logged over 150 hours in single 

engine aircraft. Mr. Gaudet is also currently 1/5 owner of a Cessna Cardinal 177B 

which he flies regularly. 

Petitioner will comply with the applicable procedures and requirements stated in 

§ 91.103. Specifically, the PIC will take all actions including reviewing weather, 

flight battery requirements, aircraft performance data, and landing and takeoff 

distances before initiation of a flight. The PIC will also account for all relevant 

site-specific conditions in their preflight procedures. 

Contact information:

Brian Gaudet

39 Tiffany Cir.

Millbury, MA 01527

bgflyer@icloud.com

508-754-5664
Petition Exemption Summary: 

The specific section or sections of 14 CFR from which you seek an 

exemption;

Petition for Exemption under Sec 333

Regulations from which the exemption is requested:

- 14 C.F.R. Part 21 (H)

- 14 C.F.R. 61

- 14 C.F.R. 91.103(b)(2)

- 14 C.F.R. 91.105

- 14 C.F.R. 91.109

- 14 C.F.R. 91.119

- 14 C.F.R. 91.121

- 14 C.F.R. 91.151

- 14 C.F.R. 91.405

- 14 C.F.R. 91.407

- 14 C.F.R. 91.409

- 14 C.F.R. 91.417

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes on private property. 

I am a member of the Academy of Model Aeronautics. I am petitioning for an 

exemption to provide a commercial service to private land owners and 

companies who wish to obtain and capture Aerial photos and videos of said 

property for purposes including real estate listings, agriculture monitoring, 

insurance property claims, inspections, and monitoring structures (roofs) and for 

use as a marketing tool for businesses. I would like to be able to accept payment 

for these services therefore making this a commercial use of a UAS.

Also, I request a grant of exemption to use any aircraft identified on the List of 

Approved UAS under Section 333 at regulatory docket FAA-2007-3330 at 

www.regulations.gov, when weighing less than 55 pounds including payload. 

Proposed operations of any aircraft not on the list currently posted to the above 

docket will require a new petition or a petition to amend this exemption.
How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small 

business owners, real estate agents, and others who wish to document their land 

or property, to take advantage of the technology that now exists in the form of 

UAS’s and allows them to do so using an experienced and certified RC Pilot in 

Command that understands how to safely operate such technology.

Reasons why the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to the existing rule;

I am an FAA licensed Private Pilot, a member of the AMA and therefore 

understanding the importance of different uses and safety concerns regarding 

FAA regulated airspace, I would be a good candidate for exemption of Sec 333 

while not putting Air Safety in any accelerated risk. The specific UAS (DJI Inspire 

1 whose Operating Manual is Included in my petition) The DJI Inspire 1 UAV 

includes GPS navigation and many more safety systems outlined in the 

referenced manual. When flying for this commercial purpose I would be flying at 

a maximum altitude of 400 feet with the majority of flight operating at less than 

200 feet. Flights would be mostly vertical for the purposes of taking photos / 

video, decreasing the risk of any interference to other aircraft and persons on the 

ground or in the area. My general knowledge of the aviation safety systems 

implemented by the FAA would be used to ensure that safety would not be 

affected by my operations. I would not be flying near disaster areas, sporting 

events, or high traffic areas including airports, and I would pay attention to all 

NOTAMS.

I Intend to follow these suggested safety regulations;

• Always keep aircraft in sight and under control.

• Always keep people and pets at least 35 feet (10 meters) away when the 

battery is connected.

• Keep children out of the vicinity of this product at all times.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly.

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Always have a first aid kit with you.

• Always have an appropriate fire extinguisher with you.
• Never operate aircraft with damaged wiring.

• Never touch moving parts.

• Follow all safety recommendations detailed by the manufacturer (DJI).

A summary we can publish in the Federal Register Federal Register —

I, Brian Gaudet am seeking an exemption of the FAA’s Sec 333 rules that does 

not allow the use of an Unmanned Aircraft to be used for Commercial purposes 

in regards to National Airspace Safety. I am petitioning for an exemption to 

provide a commercial service to private land owners and companies who wish to 

obtain and capture Aerial photos and videos of said property for purposes 

including real estate listings, agriculture monitoring, insurance property claims, 

inspections, and monitoring structures (roofs) and for use as a marketing tool for 

businesses. Being an FAA licensed Private Pilot, and a member of the AMA, I 

therefore understand the importance of the different uses and safety concerns 

regarding FAA regulated airspace, I would be a good candidate for exemption of 

Sec 333 while not putting Air Safety in any accelerated risk. The specific UAS I 

intend to use is the (DJI Inspire 1) whose Operating Manual is Included in my 

petition.) The DJI Inspire 1 UAV includes GPS navigation and many more safety 

systems outlined in the referenced manual. When flying for this commercial 

purpose I would be flying at a maximum altitude of 400 feet with the majority of 

flight operating at less than 200 feet. Flights would be mostly vertical for the 

purposes of taking photos / video, decreasing the risk of any interference to other 

aircraft and persons on the ground or in the area. My general knowledge of the 

aviation safety systems implemented by the FAA would be used to ensure that 

safety would not be affected by my operations. I would not be flying near disaster 

areas, sporting events, or high traffic areas including airports, and I would pay 

attention to all NOTAMS. I appreciate the FAA’s consideration of this petition for 

exemption.

The specific section or sections of 14 CFR from which you seek an 

exemption;

Regulations from which the exemption is requested:

- 14 C.F.R. Part 21 (H)

- 14 C.F.R. 61

- 14 C.F.R. 91.103(b)(2)

- 14 C.F.R. 91.105

- 14 C.F.R. 91.109

- 14 C.F.R. 91.119

- 14 C.F.R. 91.121
- 14 C.F.R. 91.151

- 14 C.F.R. 91.405

- 14 C.F.R. 91.407

- 14 C.F.R. 91.409

- 14 C.F.R. 91.417

A brief description of the nature of the exemption I am seeking;

I am petitioning for an exemption to provide a commercial service to private 

land owners and companies who wish to obtain and capture Aerial photos and 

videos of said property for purposes including real estate listings, agriculture 

monitoring, insurance property claims, inspections, and monitoring structures 

(roofs) and for use as a marketing tool for businesses. I would like to be able to 

accept payment for these services therefore making this a commercial use of a 

UAS.

Any additional information, views, or arguments available to support your 

request;

I am fully aware of the pre flight safety checks and procedures implicated in the 

operation manual for the DJI Inspire 1 and intend to implement pre flight safety 

checks and checklists and utilize the safety technology provided with this unit. I 

intend to only fly in non populated, residential or rural areas and stay clear of all 

obstacles, utility lines etc. I intend to be fully aware of my surroundings at all 

times and to only fly the unmanned aircraft within a visual line of sight and only in 

Visual Flight Conditions.

My FAA Issued Private Pilot License Certificate Number is 3638364

My Membership Number in the Academy of Model Aeronautics is 1092266 for 

2016

I understand the and will comply with all the health and safety regulations for 

PIC’s and will be the only operator under this exemption.

Description of UAS and Equivalent Level of Safety

The primary UAS system that will be used is the DJI Inspire 1 quadcopter 

(model T600). The UAS will be safely operated in the NAS by maintaining line 

of sight visual contact, flown only during daylight, and less than 400ft above 
the ground. Flights will be operated at a lateral distance of no less than 100 

feet from any persons or property not associated with the operation. Additional 

safety features on the DJI Inspire 1 include return to home functionality when 

GPS is available and failsafe technology that return the aircraft to the takeoff 

point if the batteries run low. Additionally, the max flight time for the UAS will 

be limited to maintain a reserve of 25% battery power. At all times, the UAS 

will be operated in accordance with the safety and operational requirements of 

the manual (see link below.)

The specifications for the UAS DJI Inspire 1 are as follows: 

Weight: 2935 g

Diagonal Size: 438 x 451 x 301 mm

Max Ascent Speed: 5 m/s

Max Descent Speed: 4 m/s Max Speed: 22 m/s (no wind)

The Petitioner has supplied the following additional information on the DJI 

Inspire 1 UAS:

Inspire 1 Specs

http://www.dji.com/product/inspire-1/spec

Inspire 1 Quick Start Guide

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Quick_Sta

rt_Guide_v1.4_en.pdf

Inspire 1 User Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Man

ual_v1.4_en.pdf

Inspire 1 Safety Guidelines

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Safety_G

uidelines_en.pdf

Inspire 1 Maintenance Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_Maintena

nce_ManualV1.0_en.pdf

UAS Operations

Preflight would include checking the operation of the UAS to include the 

battery in both the transmitter and the UAS, the condition of the body of the

UAS and its propellers. Updates to the firmware will be done as they become 

available and maintenance will be performed pursuant to the manufacturers 

recommendations. The area in which the drone will be flown will be checked 

for power lines, antennas, and other obstructions. The weather conditions will 

be monitored throughout the flight. Wind conditions will be reviewed and the 

UAS will only be flown in daylight. As the pilot, Brian would ensure that he is 

safe to operate the drone as though he were flying in the aircraft himself.
Lost Link Events. Finally, the FAA tweaked its standard grant language 

regarding lost link events. The FAA’s previous requirement stated “[i]f the UAS 

loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access proper- ty.” The 

requirement in the most recent terms states that if the pilot loses command or 

control link, the UAS “must follow a pre-determined route to either reestablish 

link or immediately recover or land.”

UAS Operating Parameters The petitioner states that all flights will be 

operated within visual line of sight (VLOS) of pilot, in daytime VFR flight 

conditions and all operations will be conducted with the assistance of a 

second spotter/observer. The UAS flights will be limited to a maximum altitude 

of 400 feet AGL. Altitude is accurately measured by GPS. The petitioner 

further states that an operator will ensure that only consenting production 

personnel will be allowed within 100 feet of the UA operation, and UAS will be 

kept at least 100’ from any inhabited structure. Generally the petitioner’s UAS 

will be operated in rural or suburban areas that will permit significantly larger 

safety zones. 

Flight Standards District Offices (FSDOs) will be notified as required prior to 

operations to describe intended coordination for proposed operation(s). 

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of 

Waiver or Authorization (“COA”) prior to conducting any operations under this 

grant of exemption. In fulfilling its requirements under the COA, Petitioner will 

be required to request a NOTAM not more than 72 hours in advance, but not 

less than 48 hours prior to the operation. 

Petitioner’s UAS will remain clear and yield the right of way to all manned 

operations and activities at all times (including, but not limited to, ultralight 

vehicles, parachute activities, parasailing activities, and gliders / hang gliders). 

Petitioner will not conduct UAS operations within 5 nautical miles of the 

geographic center of a non-towered airport unless a letter of agreement with 

that airport’s management is obtained and the operation is conducted in 

accordance with a Notice to Airmen (“NOTAM”). 

Safety and Benefits of the UAS The petitioner will be using the UAS in a 

variety of applications that generally require expensive full-size manned 

aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad of 

benefits over the use of full-sized manned aircraft for electric power line 

inspection, oil/gas pipeline inspection, advanced agriculture, film and still 

photography, just to name a few. Replacing significantly larger manned 

aircraft carrying crew and flammable fuel with small UAS carrying no 

passengers or crew creates a much greater margin of safety for the pilots and 
crew. By granting Petitioner’s requested exemptions, the FAA will help drive 

development of safe and successful commercial UAS operations and will 

advance the public knowledge base for such operations. Petitioner is 

committed to promoting the UAS research efforts of policymakers including 

the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS 

operations and serving as a resource for future UAS research operations. 

Thus, the FAA has good cause to grant this Petition. 

If you want to exercise the privileges of your exemption outside the United 

States, you must state the reason.

I have no intention on using this exemption outside the United States

Conclusion For the foregoing reasons, the exemptions requested herein 

should be granted and Petitioner should be permitted to conduct small UAS 

operations in accordance with its manuals and all other operating parameters 

deemed necessary and appropriate by the FAA. 

Thank you for your consideration. 

Sincerely,

Brian Gaudet

Owner/Pilot

Strategic Designs

39 Tiffany Cir.

Millbury, MA 01527

bgflyer@icloud.com

508-754-5664