June 18, 2015

Exemption No. 11856

Regulatory Docket No. FAA–2015–0009

Mr. Mark Ingle

325 Sand Paver Way

Fort Mill, South Carolina 29708

Dear Mr. Ingle:

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.

By letter dated December 31, 2014, you petitioned the Federal Aviation Administration 

(FAA) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial imaging, videography, and surveillance.

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

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Tarot 650M.

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 
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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 collection1. 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.

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, Mark Ingleis 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.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Mark Ingle 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 Tarot 650Mwhen 

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.

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. 
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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 

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 
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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.

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 
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(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 

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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Exemption for Petition Page 1

December 31, 2014

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

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

the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) 

(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

Dear Sir/Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. Part 11, I, Mark Ingle, would like to apply for an exemption from the following 

Code of Federal Regulations (C.F.R) to allow commercial operation of lightweight 

Unmanned Aircraft Systems (sUAS) for aerial imaging, video, and surveillance. This

video and image data will be used for survey analysis, safety and/or damage 

inspection, aerial photography, as well as search and rescue. These are services that 

will be offered and safely executed to various clients or industries with these types 

of needs. The operations of the service(s) will only be carried out with the proper 

approval from property owners and any other agencies requiring approval. Safety 

will be top priority before, during, and after operations of the services. Described 

herein, along with request for exemption, are details on how my operations will be 

equal to, or more safe than use of traditional rotorcraft.

Part of my request, herein, for exemption will contain technical terms and 

components that make up the typical sUAS. These terms and definitions can be 

found at the end of this petition under the section Terms and Definitions.

My name and address:

Mark Ingle

325 Sand Paver Way

Fort Mill, South Carolina 29708

Cell Phone: 803.412.1958

I am requesting exemption from the following CFRs

14 C.F.R. Part 21 Subpart H

14 C.F.R. 45.27(a)

14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.103

14 C.F.R. 91.119
Exemption for Petition Page 2

14 C.F.R. 91.121

14 C.F.R. 91.203

14 C.F.R 91.151

C.F.R. REGULATIONS - REQUEST SPECIFIC EXEMPTION.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203

Due to the length and number of regulation with Part 21 Subpart H I am not listing all 

of the text but affirming that I have read all of the regulations in preparation for the 

request below. 

I seek to request exemption from 14 C.F.R. Part 21, Subpart H Airworthiness 

Certificates 14 CFR to the extent of not requiring a traditional airworthiness 

certificate for the operation of a sUAS. The reason I am requesting the exemption is 

due to the fact the Form 8130-6 does not support applicable entry to provide data 

about my sUAS and is not applicable to sUAS characteristics. The information 

requested is based on a typical aircraft. The mechanical, electronic, and capacity 

characteristics for a sUAS are very different from a typical aircraft made for 

passenger or cargo transportation. As such, the current qualification process for the 

airworthiness certificate does not make sense at this time. Once a form or process is

available to support sUAS airworthiness, I will be more than happy to submit one 

for processing and inspection of sUAS. I also encourage the FAA to develop an

airworthiness certification process for sUAS. Until a formal FAA process is in place,

the petitioner and pilot will follow the processes and procedures described herein 

to obtain the same level of safety expected under the current regulation of Part 21 

Subpart H.

In addition, the proposed multi-rotor vehicle was built by the petitioner using 

proven parts available from the sUAV market. The sUAS weight is limited to 2.1Kg 

and the size is limited to 650mm. The sUAS maximum flight speed is 25 mph. In the 

event of communication failure, the sUAS will return to home position (established 

before flight). In the event of catastrophic failure, the onboard parachute will be 

deployed by pilot in command. The sUAS will be operated in an approved restricted 

environment under safety procedures described later in this petition. Because of the 

small size this sUAS is safer than the typical rotorcraft. 

For 91.203, there is no cockpit or cabin, and a sUAS does not run on fuel. I would 

like to be exempt from all of 91.203 as well since this regulation is not applicable to 

a sUAS. However the intent of 91.203 is applicable to sUAS to the extent of proving 

airworthiness for battery, frame, and motor components. For this reason, recorded 

logs for sUAS inspection will always be in possession of the pilot in command. The 

operations of my sUAS will have a battery maintenance plan and a rotation plan 

along with current battery telemetry information provided to the pilot. Also any 
Exemption for Petition Page 3

documents that are required in the future will be with the sUAV pilot operating the 

sUAS.

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft.

1. Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks 

required by §45.23.

I request exemption from 14 CFR 45.27 (a) to the extent of not following this 

regulation since it is applicable to a typical aircraft. There is no fuselage, cabin, or 

boom on a multi-rotor sUAS. However the intent of assigning a unique identifier to 

a sUAS for the purposes of country and owner identification will be followed. The 

unique ID will be the owner’s phone number until further direction from the FAA.

14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks

(3) Rotorcraft, must be at least 12 inches high, except that rotorcraft 

displaying before April 18, 1983, marks required by §45.29(b)(3) in effect on 

April 17, 1983, and rotorcraft manufactured on or after April 18, 1983, but 

before December 31, 1983, may display those marks until the aircraft is 

repainted or the marks are repainted, restored, or changed.

(c) Width. Characters must be two-thirds as wide as they are high, except the 

number “1”, which must be one-sixth as wide as it is high, and the letters “M” 

and “W” which may be as wide as they are high.

(d) Thickness. Characters must be formed by solid lines one-sixth as thick as 

the character is high.

(e) Spacing. The space between each character may not be less than onefourth of the character width.

(f) If either one of the surfaces authorized for displaying required marks 

under §45.25 is large enough for display of marks meeting the size 

requirements of this section and the other is not, full size marks must be 

placed on the larger surface. If neither surface is large enough for full-size 

marks, marks as large as practicable must be displayed on the larger of the 

two surfaces. If no surface authorized to be marked by §45.27 is large enough 

for full-size marks, marks as large as practicable must be placed on the 

largest of the authorized surfaces. However, powered parachutes and 

weight-shift-control aircraft must display marks at least 3 inches high.
Exemption for Petition Page 4

(h) After March 7, 1988, each operator of an aircraft penetrating an ADIZ or 

DEWIZ must display on that aircraft temporary or permanent nationality and 

registration marks at least 12 inches high.

I request exemption from 14 CFR 45.29 (3) (c) )(d)(e)(f)(g)(h) to the extent of not 

requiring identification marks of 12 inches and applicable width, spacing, and 

thickness. Identification (phone number or FAA unique ID requirement) will be 

displayed on the motor arms of all multi-rotor sUAS as large as possible without 

effecting performance of the sUAS. A rough estimate would be about 3⁄4 inch font.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in 

command.

(a) Except as provided in paragraphs (b) through (h) of this section, no 

person who holds a private pilot certificate may act as pilot in command of 

an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as pilot in command of an 

aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of 

an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or 

hire.

(c) A private pilot may not pay less than the pro rata share of the operating 

expenses of a flight with passengers, provided the expenses involve only fuel, 

oil, airport expenditures, or rental fees.

I request exemption from 14 CFR 61.113 (a) to the extent of not requiring a pilot’s 

certificate at this time to operate a sUAS as pilot in command. I request the 

acceptance of Ground School Certificate and completing the petitioners training 

program (described in this document) as a means of meeting (61.113) (a). In 

combination to Ground School Certificate I request the acceptance of Academy of 

Model Aeronautics membership. This organization has a significant history with 

providing education for remote control devices including aircraft. Members have 

access to a centralized knowledge base for beginning and continuing education in 

aerodynamics. The membership number for Mark Ingle is 1063718. Academy of 

Model Aeronautics is located at:

5161 East Memorial Drive

Muncie IN 47302

Phone: 765.287.1256
Exemption for Petition Page 5

In addition, I request that the acceptance of a completed and approved 

Federal Background Check be included as a means of granting pilot in command 

status. The latest background check for Mark Ingle is included in this document as 

an embedded file. Click the pdf icon below to view

FBI_Background_Ch

eck.pdf

I request exemption from 14 CFR 61.113 (b) to the extent of receiving some 

portion of payment for sUAS services but not to the extent of carrying passengers or 

cargo since it will be impossible for my sUAS to carry more than 6 kg without 

significantly effecting flight time. The reason I am seeking this relief is to offset 

operational expenses until the sUAS market matures to yield profit and final 

regulations. In addition, to the extent of using a remote controlled device, a secured 

area, and no passenger involvement, the risk of hazardous conditions and risk to life 

are significantly reduced. My sUAS operation will be equally or more safe than 

traditional rotorcraft. Before any services are rendered, the pilot will be required to 

complete a sUAS flight training program of 100 hours total (in the air) flight time - 

60 hours in manual mode and 40 in self-leveling mode. The sUAS will be controlled 

remotely with a radio transmitter operating at 2.4 Ghz or 5.8 Ghz. For redundancy 

purposes, there will be two radio transmitters paired, in series, during operations –

the pilot and co-pilot will each have one radio transmitter with the devices

connected via the training port. The pilot will maintain control until verbally 

handing over control to the co-pilot, if needed. The certified sUAS pilot will also be 

required to pass a flight test demonstrated ability to fly the sUAS manually as well as 

self-level (autonomous) and show the ability to switch between flight modes at 

request. The certification test will include a flight course simulating typical flying 

challenges during service operations.

The exemption from this regulation will benefit the public by providing an 

opportunity for developing a market in sUAS services at a lower risks and lower 

startup costs than traditional rotorcraft services. And the same level of safety 

provided from pilot certification will be reached via the sUAS training program 

describe herein.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

Each pilot in command shall, before beginning a flight, become familiar with 

all available information concerning that flight. This information must 

include—

(a)...
Exemption for Petition Page 6

(b) For any flight, runway lengths at airports of intended use, and the 

following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the takeoff 

and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and runway 

slope, aircraft gross weight, and wind and temperature.

I request exemption from 14 CFR 91.103 (b)(1) and (b)(2) to the extent of not

requiring landing and takeoff distance calculation since there is no runway required 

for a sUAS. However, for safety, preflight calculations do apply to the operation of a 

sUAS and will be adhered to:

Below is the current proposed preflight checklist for multi-rotor sUAS and 

includes preflight calculations: (Preflight Check list is carried out by co-pilot 

with pilot giving confirmation by the verbal response of “Check”)

Preflight Checklist

1. Confirm weather conditions.

2. Check lock nuts on each prop.

3. Check each prop for damage or wear.

4. Check frame for cracks or loose screws.

5. Ensure motors are level.

6. Check landing gear is locked.

7. Secure battery with straps and connect/lock XT-60 power cord to power 

distribution board. Check for green indicator (LED) on electronic speed 

controllers while connecting.

8. Check voltage indication from flight controller and make note of current 

voltage and amperage.

9. Co-pilot determines Estimated Flight Time Capacity and compares to 

Required Flight Time from flight plan.

10. Check operating temperature of flight controller.

11. Check receiver and transmitter controller for yaw, pitch and roll.

12. Check sub-trims are set to zero.

13. Check low voltage alarm.

14. Check failsafe.

15. Pilot determines Estimated Flight Time Capacity and compares to Required 

Flight Time from flight plan. (This is separate from step 9. Both pilot and copilot calculations should match.)

16. Pilot compares flight time and route based on flight path

17. Note wind speed and direction. Wind must be <8 mph.
Exemption for Petition Page 7

18. Check throttle is set to idle.

19. Arm flight controller and check for errors or warnings.

20. Stand clear no less than 10 meters and throttle up props to 40%.

21. Check for any vibration or note abnormal prop noise.

22. Throttle down and disarm flight controller.

23. Request permission for takeoff from Safety Officer.

14 C.F. R. 91.119 (c) : Minimum Safe Altitudes

Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 

feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the 

surface—

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at 

less than the minimums prescribed in paragraph (c) of this section.

14 CFR 91.119 (a)(b) and (d) – These regulations are applicable to the operation of a 

sUAS and will be part of the flight route planning between pilot and co-pilot to provide 

emergency landing area(s) and identifying restricted area(s). No flights will take 

place in restricted areas.

I request exemption from 14 CFR 91.119 (c) to the extent of requiring an altitude of 

less than 200 feet above the surface unless the pilot is flying with first person video 

enabled equipment. Any flight route 200 feet above the surface will increase the 
Exemption for Petition Page 8

risk of loss of sight orientation in which the sUAS pilot must recover. The pilot will 

comply with the flight route and altitude plans and no adjustments will be made to 

the route until the flight route is completed. People and property owners above 

flight route must also provide verbal or written permission before operations. All 

public safety regulations will also be followed. Normal operations for services 

provided will be at very low-altitude.

This exemption will provide for more safe operations of a sUAS since the visual line 

of sight limit will mitigate loss of control. The size and weight of sUAS makes this 

exemption safer than current regulation for typical rotorcraft.

14 C.F.R. 91.121: Altimeter Settings

(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter

that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure 

in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210
Exemption for Petition Page 9

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to 

the minimum flight level, the pilot shall take the flight level equivalent of the 

minimum altitude in feet and add the appropriate number of feet specified 

below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000

I request exemption from 14 CFR 91.121 to the extent of not following all of the 

regulations (91.121) as it is written due to the fact that these regulations are 

applicable to a typical aircraft. However the intent of the regulation does need to be 

followed for sUAS operations. The flight controller used on my sUAS will be 

equipped with a micro barometer to provide altitude information via telemetry to 

the pilot in command. This telemetry data will also be visible to the copilot. The 

barometer will also be integrated with the configuration and operation of the flight 

controller to provide a way for the pilot to maintain an “altitude hold” automatically. 

The “altitude hold” will be enabled by the pilot per the flight route plan that is

established during pre-flight planning. GPS altitude information will be included in 

telemetry information but will not be integrated with the flight controller due to 

inherent risks with GPS signal loss.

This exemption allows for further development and integration of the “altitude 

hold” feature for other sUAS devices and understanding for certified pilots. In 

addition, this feature will provide another architecture layer supporting public and 

national airspace safety during sUAS operations. This specific technology, along 

with other advanced features, will foster other economic sector growth as a whole. 

Due to the small sUAS and ability to maintain consistent altitude, this exemption will 

provide a safer environment than current regulations for full sized rotorcraft.

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

(a) No person may begin 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
Exemption for Petition Page 10

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft 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, 

to fly after that for at least 20 minutes.

I request exemption from 14 CFR 91.151 (a) and (b) to the extent of not following 

these regulations (91.151) as it is written due to the fact that these regulations are 

applicable to a typical aircraft. However, the intent of the regulation (91.151) is to 

insure the safe operation of the powered aircraft while in flight and provide for 

extra fuel in case of emergencies. This same approach and intent will be followed 

for the operation of sUAS. Below is the calculation that will be used to determine 

flight time:

Flight Time Calculation

1. Determine the total weight of the sUAS during flight and divide weight by the 

number of motors – 4, 6, or 8. This will yield the thrust needed per motor.

2. Multiply the thrust needed by two to provide lift and hover of the sUAS.

3. Determine the amount of Watts needed to achieve hover thrust (Use 

manufactures specs if provided).

4. Divide power by nominal battery voltage to yield amps.

5. Divide Battery capacity (mah) by (Number of motors x amps)) and multiply 

this by 60 (minutes).

6. Multiply this number by 0.8 (20% loss of efficiency).

7. The result is your estimated flight time for hovering and lift.

8. The amount of power to reserve for RTH should be determined during flight 

planning between the pilot and copilot.

This same calculation can be used in reverse to determine the proper motor and/or 

battery configuration to achieve required flight times based on operational 

requirements per flight route. In some cases different video or image equipment 

maybe required.

Example:

Motor Specifications

Max Watts 330 Watts Battery Specifications

Working Current 16 Amps Battery Mah 5200

Hover Thrust 19 Amps Battery Volts 14.8

Max current(10s) 22 Amps Battery Amps 5.2

No Load Current 0.03 Amps Battery Watts 76.96

Internal Resistence 0.091 ohm
Exemption for Petition Page 11

Number of Poles 16

Prop 12x3 12x6

Watts/Motor For 

Hover 71.25

Max Voltage 15 Volts Amps/Motor 4.8

AUW 2100 grams

Number of Motors 4

Thrust Per Motor 525 grams Total Flight Time 16.2 min

Thrust Needed Per Motor 1050 grams Less Eff. Loss (%20) 13.0 min

Reserve battery power will be reviewed during flight planning and will be based on 

the distance from beginning location (take off) and the end location (landing and 

typically the home location). The percentage of battery reserve needed will be 

adjusted over time as the flight route is completed. This is due to external

environmental factors that will affect the physics of lift and directly impact power 

consumption during flight – wind, humidity, and heat. The percentage of battery 

power remaining and the distance to the end location will be used in real time 

calculations built into the flight controller to determine when the sUAS should land 

at the end location. The percentage of battery power will be displayed in telemetry 

information to the pilot in command. While in manual mode the pilot must adhere 

to the telemetry warning and proceed to the end location

*******

The following summary is provided for publication in the Federal Register:

Petitioner asks for an exemption from the following rules:

14 C.F.R. Part 21

14 C.F.R. 45.27(a)

14 C.F.R. 45.29 (3) (c)(d)(e)(f)(g)(h)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.103

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.203

14 C.F.R 91.151

The purpose of this request is to operate a small unmanned vehicle (10lbs or less) 

for aerial imaging, video, and surveillance services. Also search and rescue services 

will be offer to the South Carolina Search and Rescue Dog Association at no charge. 

For SAR services, all operations described herein will be followed in addition to 

following National Incident Management System protocol. No flight operations will 

take place during SAR services without the consent of the Incident Commander. 
Exemption for Petition Page 12

Exemption from the C.F.R. regulations will provide for safer operations than using 

traditional methods of rotorcraft.

Furthermore, a sUAS powered by batteries eliminates all risks associated with 

larger rotorcraft – fuselage, flight crew and fuel. sUAS do not require high-speed 

aerodynamics of large mechanical moving structure to achieve lift that is typical of 

rotorcraft thus reducing risk even further for society. 

The operation of small sUAS, weighing less than 10 lbs., will be conducted under 

very strict rules and conditions outlined herein, will provide an equivalent or better 

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. The sUAS operate at slow speeds, close to the ground, and in a 

controlled environment and, as a result, are far safer than conventional operations 

conducted with rotorcraft operating in close proximity to the ground and people.

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

owner’s prior consent and knowledge. Images taken will be of individuals who have 

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

aerial photography will take place.

Response to Section 333 (b) (1)

Section 333 (b) (1) ASSESSMENT OF UNMANNED AIRCRAFT SYSTEMS.—In making 

the determination under subsection:

(b), 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; 

I am addressing this mandate by designing a sUAS that has visual indicators to aid in

determining flight orientation and enhance visual line of sight capabilities. The key 

design features are fluorescent orange props in front and fluorescent yellow in rear. 

In addition there will bright green LEDs in front and bright red LEDs in the rear. 

Focus of training will be centered toward sUAS control at long parallel distances.

Training plan for preparation of certification for piloting a UAS:
Exemption for Petition Page 13

1. Pilot In Training will work along side a qualified or experience RC pilot for a 

total of 10 hours training. (These hours DO NOT count toward required

flight time)

2. Pilot In Training will log 100 hours of computer simulated flight time before 

training can begin in the field. (These hours DO NOT count toward required 

flight time)

3. 60 hours of logged flight time manual mode for the quad sUAS

4. 40 hours of logged flight time self-leveling mode for the quad sUAS

5. Pilot will be able to safely switch between modes while in flight.

6. Each flight training session will consist of the following:

a. Preflight checklist

b. Successful take off and landing. Pilot must demonstrate 

understanding and recovery from Ground State Hover Effect on at 

least one landing per session.

c. Recover from Vortex Ring State condition per session.

d. Left and right turn circle of UAS.

e. Recover from loss of visual line of sight (sUAS orientation) condition

from north, east, south and west.

f. Retrieval of object from a distance of 50 yards.

g. Figure eight flight path for 5 minutes.

h. Hover for no less than 5 minutes at 30, 50, 100, and 150 feet.

Maintenance Plan for sUAS:

1. Preventative maintenance will be required after 20 hours of total flight time

for each registered sUAS.

2. Detailed records will be kept for unplanned and planned maintenance as well 

as auxiliary equipment that is added or removed.

3. Equipment that is rotated from the sUAS will undergo inspection and testing 

by an approved inspector who will sign off on each inspected part and 

component.

4. All records will be retained for the life of the sUAS while in service.

5. All parts and components will be uniquely identified for tracking purposes 

during inspection and rotation of parts.

6. Preventative Maintenance Tasks:

a. Check and tighten all mechanical screws. Lock tight glue should be 

used on all screws. Record inspection with digital picture and date of 

inspection.

b. Replace all carbon fiber motor arms with new or inspected carbon 

fiber arms. Record replacement part and date.

c. Replace landing gear carbon fiber rods with new or inspected carbon 

fiber rods. Record replacement part and date.

d. Remove all propellers and inspect for cracks or damage. Replace 

propellers with new props. Record replacement part and date.
Exemption for Petition Page 14

e. Replace electronic speed controllers with new or inspected 

controllers. Confirm all controllers are operating with the latest 

firmware from the manufacture. Record replacement part and date.

f. Inspect all wiring and insure all wiring has the appropriate twist 

proportion to reduce magnetic fields.

g. Replace all motors with new or inspected motors. Record 

replacement part and date.

h. Replace flight controller with new or inspected flight controller. 

Confirm the flight controller has the latest firmware from the 

manufacture. Record replacement part and date.

i. Replace all worn anti-vibration material.

j. Any part of component found defective will be removed and replaced. 

The defective part of component will be record.

Required components for safe operation of sUAS

1. Flight Controller must have the following integrated components:

a. Inertia Measuring Unit

i. 3 Axis Gyro

ii. 3 Axis Accelerometer

iii. 3 Axis Magnetometer

b. Barometric pressure sensor

c. LED status indicator

d. Low voltage alarm capabilities

2. Electronic Speed Controller (ESC) must have the following:

a. LED status indicator

b. Input Frequency > 1Khz

c. Purpose built multi-rotor ESC!!!!

3. Propellers will be attached to threaded axil attached to motor by lock nut 

design. No other type of nut will be used.

4. Radio controlled deployable parachute.

5. Power distribution board with gold connectors

6. Radio Transmitter with the following:

a. 2.4 or 5.8 ghz communication frequency.

b. Battery capacity of one hour with low voltage indicator and auditable 

alarm.

c. No less than 9 channels for control and monitoring sUAS

d. Training port for redundancy during flight and training sessions.

e. Telemetry display with the following:

i. Battery Mah

ii. Battery voltage

iii. Radio Signal Strength Indicator (RSSI)
Exemption for Petition Page 15

iv. Active Acquired Satellite Count

Operational Procedures

Mark Ingle will abide by the following limitations, restrictions, and procedures when 

conducting its sUAS operations under an FAA issued exemption:

1. The sUAS will be less than 10 pounds.

2. Operations will only be conducted during daylight hours.

3. Flight operations will not occur within 5 miles of any public or private 

airport.

4. Flights will be operated within visual line of sight of a pilot (PIC) as well as a 

Co-pilot to aid in navigation while surveying or inspecting. For safety the PIC 

must be focused on flying 100%.

5. Maximum total flight time for each operational flight will be 30 minutes. The 

flight controller used on my lightweight UAS will maintain battery life 

calculation and alert the pilot to return to home(RTH) when 15% of battery 

life is remaining.

6. Flights will normally be operated at an altitude less than 175 feet AGL, never 

exceeding 250 feet. The maximum airspeed will not be more than 25 mph.

7. Based on the service provided a flight area will be determined ahead of 

operations via ground survey. The flight area will contain the flight route 

and a risk assessment will be determined before proceeding with planning 

and operations.

8. The flight area will be defined by no less that four longitudinal/latitudinal 

coordinates using approved geo spatial software. The coordinates will be 

known as the geo-fencing coordinates.

9. The flight route will have a begin location (takeoff) and end location

(landing) identified in the flight plan.

10. All involved in the sUAS “services” transaction will agree to the flight area 

and restrictions.

11. The owner of the property where operations are taking place must give 

permission via signed wavier for the flight area.

12. Any unauthorized persons entering the flight area will require the pilot in 

command to abort the flight operation landing the sUAS in a predetermined 

location.

13. A briefing will take place with all roles involved in the operations prior to 

beginning operations.

14. Roles for each flight operation will consist of:

a. Pilot (PIC) using either FPV or VLOS. Pilot will be in control of sUAS.

b. Co-Pilot assists with navigation and maintaining a safe flight area as 

well as assist with Preflight Checklist.

c. Safety Officer will inspect all areas in the flight area as well as 

continually assess weather conditions. The Safety Officer will mark 

flight area appropriately for public awareness when needed. Safety 
Exemption for Petition Page 16

Officer will maintain visual contact with sUAS at all times and 

maintain awareness of surroundings in flight area. The Safety Officer 

purpose is to serve as an “Air Traffic Control” function.

15. All of the roles involved during a flight operation will review the flight route 

and photo/video capture plans before taking flight.

16. The sUAS will not travel outside the flight area and will be enforced by:

a. Pilot and co-pilot adherence during manual flight modes.

b. Autonomous flight control using ground station software.

17. No other personnel will be allowed in the flight area without verbal or 

written consent. Operations of the flight should stop if unauthorized 

personnel entry flight area.

18. Roles will have appropriate safety equipment.

19. The Pilot will be trained in manual and self-leveling flight modes for each 

sUAS in use. Autonomous flight training will take place as well.

20. Pilot will have been trained in manual flight modes and require 60 hours of 

flight time before certified for operations. Self-leveling certification will 

require 40 hours of flight time.

21. In the event of an emergency while in manual mode, the Co-Pilot will have a 

second controller ready to take over flight of the sUAS.

22. In the event of system or component failure while in self-leveling or 

autonomous flight, the pilot or co-pilot will take over in manual mode. sUAS 

will also have a failsafe return to home.

23. A battery maintenance plan will be established that includes logging of the 

following:

a. Date and number of Charges with beginning and ending voltage

b. Date and number of Balance Charges with beginning and ending 

voltage

c. Proper disposal procedures when battery reaches end of rotation life.

Terms and Definitions
Exemption for Petition Page 17

Flight Controller – Used to aid the pilot in flying and steering the UAS via software 

program executing on a microprocessor. This device also contains an Inertia 

Measuring Unit (IMU).

IMU – Accelerometer, Gyroscope, and Magnetometer

Return to Home (RTH) – This is a setting performed before flight using GPS to 

record the longitude and latitude of the start location. 

First Person View (FPV) – Transmitted video from the sUAS giving a forward view of 

the UAS in real time either on a monitor of FPV goggles.

Visual Line of Sight – The view of the UAS in clear plain sight of the operator while 

having 100% control.

Ground Station Software – Software integrated with flight controller over radio 

frequency using modem to modem communication between the controller and a 

computer. The sUAS is flown via GPS coordinates sent to the flight controller.

Current Federal Background Check:
Exemption for Petition Page 18