April 8, 2015 

 Exemption No. 11290 

 Regulatory Docket No. FAA−2014−0474 

Mr. Paul Misener 

Vice President, Global Public Policy 

Amazon.com 

440 Terry Avenue North 

Seattle, WA 98109 

Dear Mr. Misener: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated July 9, 2014,1

 you petitioned the Federal Aviation Administration (FAA) on 

behalf of Amazon.com (hereinafter petitioner or operator) for an exemption. The exemption 

would allow the petitioner to operate an unmanned aircraft system (UAS) to conduct outdoor 

research and development testing for Prime Air. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

Discussion of Public Comments: 

A summary of the petition was published in the Federal Register on August 15, 2014 

(79 FR 48294). Nine comments were received. Four commenters, the Small UAV Coalition 

(Coalition), Association for Unmanned Vehicle System International (AUVSI), the 

 

1

 By letter dated December 7, 2014, and posted to the public docket on December 8, 2014, the petitioner 

responded to the FAA’s request for information. 
2 

Unmanned Safety Institute (USI), and an individual supported the petition. Five commenters, 

the Air Line Pilots Association, International (ALPA) the National Agricultural Aviation 

Association (NAAA), and three individuals opposed it. 

In support of the petition, the Coalition stated the petitioner has proposed to abide by stronger 

safety measures than hobby and modeler groups operating similar aircraft. The Coalition 

stated that it does not believe that heightened safety measures should be required for the 

petitioner simply because of the commercial nature of its operations. The Coalition urged the 

FAA to adopt an evaluation framework for UAS operations under Section 333 of 

Public Law 112–95 that weighs the relative safety issues and risks of UAS by class and 

operational circumstances, rather than adopting artificial distinctions among unmanned aerial 

vehicles based on commercial and noncommercial operations. The petitioner’s UAS pose 

considerably less safety risk than larger UAS used for defense and other aerospace purposes. 

The Coalition asserted that because UAS operations like the petitioner’s pose minimal risk to 

safety, they should be subject to minimal and appropriate regulations. 

The Coalition noted the FAA is to consider the seven factors2 in Section 333 as a minimum. 

The Coalition stated the petition shows the FAA should consider factors other than those 

specified in Section 333, such as: location, the airspace and altitude of its small UAV 

operations, limited operational site access, two-way communications capability, and pilot 

training and experience. The Coalition maintained that the petitioner’s proposed operations 

satisfy the seven factors in Section 333 and include several additional mitigating factors to 

ensure the safety and security of the proposed UAS operations. The Coalition emphasized the 

FAA must evaluate each factor within the context of the petitioner’s proposed UAS 

operations. 

The Coalition also commented that the FAA should waive or exempt the requirement to hold 

an airman certificate. The Coalition further stated that applying manned aircraft pilot 

certification requirements to small unmanned aircraft is not necessary as a matter of safety, 

and does not make sense as a matter of public policy. 

The FAA notes that, as discussed in the grant of exemption to Trimble Navigation Ltd. 

(Exemption No. 11110), neither Section 333, nor the FAA’s exemption authority3

allows the FAA to exempt pilots from the statutory requirement to hold an airman 

certificate as prescribed in 49 U.S.C. § 44711. 

AUVSI asserted that Amazon’s petition adequately addressed the safety requirements of a 

number of FAA regulations. AUVSI and an individual commenter noted that there is a 

 

2

 Section 333(b) of P.L. 112–95 states, in part: “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; . . . .” 

3

 49 U.S.C. § 44701(f) 
3 

compelling need for the FAA to allow Amazon to test their systems to ensure the next 

evolution in package delivery happens in the United States first. They also cited the 

economic benefits of small UAS. 

USI supported the petitioner’s proposed operating conditions and parameters, including the 

use of highly qualified crews, line of sight operations, and restricted operating areas. USI 

suggested the petitioner adopt a Safety Management System and ensure all crews are trained 

in risk identification and Crew Resource Management. USI encouraged the FAA to work 

with the petitioner to mitigate risks associated with the expansion of the project to a full scale 

network of delivery UAS. 

ALPA expressed concern that the request is for an outdoor private test range, proximate to 

densely populated areas with substantial air traffic. ALPA stated that specific details of each 

operation must be coordinated with the FAA, which would result in a considerable increase in 

the FAA’s oversight tasks. The FAA notes ALPA’s concern and in order to minimize 

potential impact to the NAS, the FAA requires that each exemption holder operate under a 

Certificate of Waiver or Authorization (COA) which addresses airspace considerations, 

including requiring issuance of a NOTAM prior to operations. The FAA recognizes that UAS 

integration will generate new NAS access demand and will review and adjust accordingly. 

NAAA commented on pilot qualification stating that UAS operators should be required to 

hold commercial pilot certificate to ensure they are aware of their responsibilities as 

commercial operators in the NAS. They also stated that medical requirements ensure 

operators have the necessary visual and mental acuity to operate a commercial aircraft. 

The FAA has reviewed the knowledge and training requirements of sport, recreational, private 

and commercial certificates and concluded that a UAS PIC holding a minimum of a sport 

pilot certificate, and operating under this exemption, would not adversely affect operations in 

the NAS or present a hazard to persons or property on the ground. Additionally, as discussed 

in Exemption No. 11213 (Aeryon Labs, Inc.) the FAA has determined that operating a UAS 

with a U.S. issued driver’s license rather than an FAA-issued medical certificate will not 

adversely affect safety. 

NAAA noted that its members operate in low-level airspace, and therefore clear low-level 

airspace is vital to the safety of these operators. NAAA stated that seeing and avoiding other 

aircraft and hazardous obstructions is the backbone for agricultural safety, and that 

agricultural pilots depend on pilots of other aircraft to perform their see-and-avoid functions 

to prevent collisions. NAAA believes UAS operations at low altitudes will increase the 

potential for collision with agricultural aircraft. 

The FAA recognizes these concerns and has incorporated associated conditions and 

limitations into this exemption, including: (a) a Notice to Airmen (NOTAM) issued for all 

operations; (b) operations conducted within VLOS of the pilot in command (PIC) and the VO; 

and (c) the UAS PIC must always yield right-of-way to manned aircraft. 
4 

NAAA stated that FAA airworthiness certification should be a requirement for all unmanned 

aircraft to operate within the NAS. NAAA recommended UAS be equipped with ADS–B or 

similar identification and positioning systems, strobe lights, and be painted in high-visibility 

colors. NAAA also recommended UAS be operated strictly within the line-of-sight of the 

ground controller, with the assistance of a VO. 

As discussed below, Section 333 of the FAA Modernization and Reform Act of 2012 

authorizes the Secretary of Transportation to determine, considering a number of factors laid 

out in the statute, that an airworthiness certificate is not necessary for certain operations. The 

Secretary has made that determination in this case and therefore the aircraft operated by the 

petitioner will not need to be certificated by the FAA. 

Individual commenters noted that the FAA should not permit commercial small UAS 

operations until noise levels are significantly reduced and a Preliminary System Safety 

Assessment in accordance with SAE ARP4761 is completed. 

Airworthiness Certification 

The UAS proposed by the petitioner is an Amazon-manufactured multi-rotor small UAS that 

has been described to the FAA in a confidential filing. 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 
5 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Amazon.com is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, Amazon.com is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the an Amazonmanufactured multi-rotor small UAS that has been described to the FAA in a 

confidential filing when weighing less than 55 pounds including payload. Proposed 

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

exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3.The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4.The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 
6 

5.The UA 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 or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO 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 VO can perform the duties 

required of the VO. 

7.This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 

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

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

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an 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. 

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9.The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 
7 

potential discrepancies, e.g. inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 
8 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

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

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

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 in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 
9 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. 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. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
VIA FDMS

The Honorable Michael P. Huerta

Administrator

Office of the Administrator

Federal Aviation Administration

800 Independence Avenue SW

Washington, DC 20591

July 9, 2014

Re:  Amazon Petition for Exemption  

Dear Administrator Huerta:

At Amazon, our energy comes from inventing on behalf of customers.  Amazon Prime Air,

a new delivery system that will get packages to customers in 30 minutes or less using aerial

vehicles, is one invention we are incredibly passionate about.  We believe customers will love it,

and we are committed to making Prime Air available to customers worldwide as soon as we are

permitted to do so.

Amazon shares Congress’s goal of getting small aerial vehicles (a.k.a., small unmanned

aircraft systems, or “sUAS”) flying commercially in the United States safely and soon.  In the FAA

Modernization and Reform Act of 2012, Congress directed the FAA “to safely accelerate the

integration of civil unmanned aircraft systems into the national airspace system” and, under

Section 333 of that law, gave the FAA power to grant innovators “expedited operational

authorization” to do so.  By this petition, Amazon is seeking its first such authorization, in order

to conduct additional research and development for Prime Air.  

  

We are rapidly experimenting and iterating on Prime Air inside our next generation

research and development lab in Seattle.  In the past five months, we have made advancements

toward the development of highly‐automated aerial vehicles for Prime Air, including:

    

 Testing a range of capabilities for our eighth‐ and ninth‐generation aerial vehicles,

including agility, flight duration, redundancy, and sense‐and‐avoid sensors and

algorithms;  

 Developing aerial vehicles that travel over 50 miles per hour, and will carry 5‐

pound payloads, which cover 86% of products sold on Amazon; and
The Honorable Michael P. Huerta

July 9, 2014

Page 2

 Attracting a growing team of world‐renowned roboticists, scientists, aeronautical

engineers, remote sensing experts, and a former NASA astronaut.

Current FAA rules allow hobbyists and manufacturers of model aircraft wide latitude in

flying their sUAS outdoors.  Because Amazon is a commercial enterprise we have been limited to

conducting R&D flights indoors or in other countries.  Of course, Amazon would prefer to keep

the focus, jobs, and investment of this important research and development initiative in the

United States by conducting private research and development operations outdoors near Seattle

– where our next generation R&D lab and distinguished team of engineers, scientists and

aeronautical professionals are located.  In order to allow outdoor R&D testing for Prime Air in the

United States, we are submitting this petition for exemption pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012.   

Granting Amazon an exemption to allow R&D testing outdoors in the United States is in

the public interest because it advances Congress’s goal of getting commercial sUAS flying in the

United States safely and soon.  It is a necessary step towards realizing the consumer benefits of

Amazon Prime Air and, at this point, Amazon’s continuing innovation in the United States

requires the requested exemption for outdoor testing in support of our R&D.

Further, granting this request will do nothing more than allow Amazon to do what

thousands of hobbyists and manufacturers of model aircraft do every day, and we will abide by

much stronger safety measures than currently required for these groups by FAA policies and

regulations.  In this petition for exemption, we seek to engage in essentially the same type of

sUAS operation that the FAA would permit us to currently – but for the fact that Amazon is not a

hobbyist or manufacturer of a model aircraft.

One day, seeing Amazon Prime Air will be as normal as seeing mail trucks on the road

today, resulting in enormous benefits for consumers across the nation.  We respectfully submit

this petition for exemption so that Prime Air can be ready to launch commercial operations as

soon as eventually permitted by subsequent FAA action.

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

(a) Mailing address and other contact information such as a fax number, telephone

number, or e‐mail address

 
The Honorable Michael P. Huerta

July 9, 2014

Page 3

Amazon.com  

Legal Department

Re: Prime Air Exemption Petition

440 Terry Ave. North

Seattle, WA  98109

Fax: 206‐266‐7010  

Email: prime‐air‐exemption@amazon.com

   

(b) The specific section or sections of 14 C.F.R. from which Amazon seeks an exemption

 14 C.F.R. § 21.191(a) – Experimental Certificates   

 14 C.F.R. § 45.23(b) – Display of marks; general

 14 C.F.R. § 91.9(b) – Civil aircraft flight manual, marking, and placard requirements

 14 C.F.R. § 91.203(a) and (b) – Civil Aircraft: Certifications Required

We believe an exemption from the regulations noted above will be sufficient to conduct

the R&D described in this exemption request.  To the extent that FAA may deem it necessary,

however, we also request an exemption from any regulations ancillary to the foregoing that may

be needed to facilitate the desired operations.1

(c) The extent of relief Amazon seeks, and the reason Amazon seeks the relief

We seek an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and

91 to the extent necessary to engage in private, non‐commercial R&D operations of sUAS on our

own property that would otherwise be expressly permitted if conducted by a hobbyist or a

 1 Given the nature of the specific relief sought by this exemption request under 14 C.F.R. §§

21.191(a), 45.23(b), 91.9(b) and 91.203(a) and (b), and the particular contours of our desired testing

operations and proposed safeguards, a request for relief from any associated or implementing

requirements of several related provisions that may otherwise be applicable, such as 14 C.F.R. §§ 91.7(a)

(civil aircraft airworthiness); 91.103(b) (pre‐flight action); 91.109 (flight instruction); 91.119 (minimum

safe altitudes); 91.121 (altimeter settings); 91.151(a) (fuel requirements in VFR conditions); 91.405(a)

(maintenance required); 91.407(a)(1) (operation after maintenance, preventative maintenance,

rebuilding, or alteration); 91.409(a)(2) (inspections); and 91.417(a) and (b) (maintenance records), should

either be unnecessary as moot or deemed incorporated herein.  Nevertheless, we seek an exemption from

any such specific provisions to the extent FAA finds it necessary to grant this request.   
The Honorable Michael P. Huerta

July 9, 2014

Page 4

manufacturer producing such sUAS.2  We have detailed, below, a significant set of safeguards

that will apply to these R&D operations.  Operations under these safeguards will provide for a

level of safety exceeding the level of safety required of similar sUAS operations that FAA

authorizes currently and without requiring compliance with the regulations from which we seek

an exemption.    Moreover, our operations will not “create a hazard to users of the national

airspace system or the public or pose a threat to national security”3 and are thus consistent with

the congressional mandate in Section 333 of the FAA Modernization and Reform Act of 2012,

which gives FAA a mechanism to allow certain UAS to operate safely in the national airspace

system.  

We also intend to use one or more of the six FAA‐selected test sites and seek a special

airworthiness certificate (experimental category) for our sUAS.  However, it would be impractical

for Amazon to pursue either one of these avenues as our sole or even primary method of R&D

testing at this time, and doing so would unnecessarily tax scarce FAA resources.  For example, it

would be an unreasonable burden on both the FAA and Amazon if we were required to apply for

a special airworthiness certificate for every sUAS design or testing configuration while we are in

R&D and conducting rapid prototyping.   

(d) The reasons why granting Amazon’srequest would be in the public interest; that is, how

it would benefit the public as a whole  

As described above, Prime Air will be a new delivery system that is poised to offer

enormous consumer benefits by delivering packages to customers in 30 minutes or less.  Please

see the introduction for details on how granting this request would benefit the public.

(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 Amazon seeks the exemption

Our R&D operations will provide for a level of safety that far exceeds the level of safety

required by FAA for hobbyists and manufacturers of model aircraft.4  The following operating

procedures will apply during the R&D testing conducted under this exemption request:

 

2

  See Pub. L. No. 112‐95, § 336, 126 Stat. 77‐78.

3 See id., § 333, 126 Stat. 76.

4 Because Amazon’s desired testing operations could not possibly be conducted using

conventional aircraft, the level of safety required of hobbyists and manufacturers of model aircraft is the

appropriate comparison.  
The Honorable Michael P. Huerta

July 9, 2014

Page 5

 The sUAS will (i) have a maximum weight of less than 55 pounds; (ii) be rotor‐

powered via a battery source; and (iii) be U.S.‐registered and display marks in

accordance with 14 C.F.R. Part 45, Subpart C.5

 Our sUAS R&D testing under this exemption will be conducted (i) within the visual

line of sight of the operator and/or one or more observers; (ii) at less than 400

feet AGL; and (iii) within Class G airspace. 

 The operations will be conducted in a confined area over isolated Amazon private

property located a sufficient distance away from (i) any airport, heliport, seaplane

base, spaceport or other location with aviation activities; (ii) any densely

populated areas; and (iii) any military or U.S. government installations or airfields.6

 All operations will remain within the lateral and vertical boundaries of the

operating area, taking into account all factors, including wind, gross weight and

glide distances, that may affect the capability of the sUAS to remain within the

airspace boundary; moreover, the integrity of the operating area will be

reinforced by geo‐fencing,7 including the ceiling height of no more than 400 feet

AGL.

 Our sUAS R&D testing under this exemption will be conducted (i) under the

supervision of a designated pilot in command (PIC) who has final responsibility for

the operation in accordance with 14 C.F.R. § 91.3 and either (A) holds a current

FAA private pilot certificate issued under 14 C.F.R. Part 61, Subpart E, a higher FAA

pilot certification, or a FAA‐recognized equivalent8 or (B) has completed FAA

private pilot ground instruction and passed the FAA private pilot written

 5 To the extent that FAA determines that the Amazon sUAS operating under this exemption must

bear an “experimental” marking, we seek an exemption from 14 C.F.R. § 45.23(b) to accommodate the

required markings pursuant to 14 C.F.R. § 45.29(f).

6 We will apply separately for the necessary certificates of waiver from the requirements of 14

C.F.R. §§ 91.113 and 91.119 and the associated airspace authorization.  Specific details of the operating

area, including latitude and longitude, and aeronautical charts and/or photographs, will be provided in

conjunction with that application process.   

7 Geo‐fencing is a feature in a software program that uses GPS or radio frequency triangulation to

define geographical boundaries.  A geo‐fence is a virtual barrier – effectively an electronic box in which

the sUAS will be confined.

8 A private pilot certificate should be sufficient for the PIC to conduct these research and

development sUAS flights.  See 14 C.F.R. § 61.113(b).
The Honorable Michael P. Huerta

July 9, 2014

Page 6

examination or FAA‐recognized equivalent; and (ii) using only operators that have

completed training on the normal, abnormal, and emergency procedures in

specific details and demonstrated proficiency with the sUAS being operated.

 No operator or observer will engage in, nor may an operator or observer permit,

any activity during a critical phase of flight which could distract any operator or

observer from the performance of his/her duties or interfere in any way with the

proper conduct of his/her duties.

 Operators will maintain the sUAS system in a condition for safe operation, and  

conduct a pre‐flight inspection prior to each flight so as to ensure that the sUAS,

control station, data link equipment, payload, and support equipment are in a

condition for safe operation and in a configuration appropriate for the purpose of

the intended flight.

 The operators and observers will maintain two‐way communications with each

other during all operations; if unable to maintain two‐way communications, or if

any condition occurs that may otherwise cause the operation to be unsafe, the

operator will immediately conclude the operation.

 Each sUAS willsafely stop operating and return automatically to a specific location

on Amazon’s private property if the communications link is lost.

 For each sUAS, the observer will have the ability to press a physical button, that

will be within his/her reach at all times, that reduces power to the vehicle so as to

force a controlled landing; both the hardware and communication for this safety

system will be physically separate from the sUAS flight control systems.  

 Testing operations will be conducted on private property, and only Amazon

employees, contract personnel, and invitees will be invited to the operations area;

security measures will be put in place to deter unauthorized access.

 The aircraft documentation required by 14 C.F.R. §§ 91.9 and 91.203(b), as

applicable, will be available to the PIC referred to above at any time Amazon’s

sUAS are operating.

We will effectively operate our own private model airplane field, but with additional safeguards

that go far beyond those that FAA has long‐held provide a sufficient level of safety for public

model airplane fields – and only with sUAS.  Indeed, the combination of the geo‐fencing and lost‐
The Honorable Michael P. Huerta

July 9, 2014

Page 7

link procedures described above will ensure the sUAS stays within the tightly defined operating

area within our private property.

(f) A summary FAA can publish in the FEDERAL REGISTER, stating: (1) The rule from which you

seek the exemption; and (2) A brief description of the nature of the exemption you seek

Petitioner: Amazon.com, Inc.

Sections of 14 C.F.R. Affected: §§ 21.191(a); 45.23(b); 91.9(b); and 91.203(a) and (b)

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§

21.191(a); 45.23(b); 91.9(b); and 91.203(a) and (b) to conduct private, non‐commercial small

unmanned aircraft systems (sUAS) operations on its own property subject to operating

procedures that meet or exceed those that FAA requires for similar operations.  

(g) Any additional information, views or arguments available to support your request

Please see the introduction to this exemption request.  

(h) If you want to exercise the privileges of your exemption outside of the United States,

the reason why you need to do so.

The research and development operations described in this exemption request will be

conducted wholly within the United States.

Please do not hesitate to contact me via email at prime‐air‐exemption@amazon.com if

you have any questions or concerns.

Respectfully submitted,

Paul Misener

Vice President, Global Public Policy  

Amazon.com