December 30, 2015 

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence Avenue, SW 

Cam MacGregor

707 South Creek Street #416 

Fredericksburg, TX 78624 

310-497-6232 

Washington, DC 20591 			

			

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE Washington, 

DC 20590 

Re: Request for exemption from multiple regulatory provisions to allow the use of small 

unmanned aerial systems controlled by Cam MacGregor

Dear Mr. Williams: 

Cam MacGregor respectfully requests an exemption from several provisions of Title 14 

of the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial 

systems (sUAS) to assist in the evaluation of infrastructure and operations for his clients. 

This request is motivated primarily by the desire to maximize safety in infrastructure and 

operations. While an exemption would not eliminate the current need for in-person visual 

inspection required by various federal regulatory departments, it would allow Cam 

MacGregor to broadly evaluate assets and operations with sUAS, resulting in a safer and 

more efficient infrastructure network. Accordingly, the grant of an exemption is 

consistent with Congress’ intent, reflected in Section 333 of the FAA Modernization and 

Reform Act of 2012 (Modernization Act),1 that safe systems be permitted in the national 

airspace prior to the issuance of final regulations governing general use of these systems. 2 

A summary of this request suitable for publication in the Federal Register is provided as 

Appendix A. 

Appendix B provides the manufacturers information regarding the design, aircraft 

performance, and fail-safe features. Cam MacGregor has provided manufacturer information 

related to operating limitations, normal and emergency procedures, and maintenance and 

inspection procedures. As aircraft designs are added, Cam MacGregor will update this 

appendix appropriately. 

Appendix C provides The Cam MacGregor Operations Manual for flights covered under this 

Exemption Request. 

1 P.L. 112-95, 126 Stat 11, February 14, 2012. 
2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type 

of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, and 

operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to 

national security.

Background Information

Cam MacGregor is in the business of collecting agricultural data through the use of sUAS 

for his farm and ranch clients. Cam MacGregor’s clients look for Safe Operations of 

sUAS. Cam MacGregor has developed specific Safe UAV Operational Procedures. 

Infrastructure Safety Inspection Operations: 

Agriculture Inspection 

As part of this, Cam MacGregor is requesting FAA Exemption for sUAS operations for 

safety, inspection and video capture usage. 

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA 

may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an 

exemption is in the public interest. The FAA has imposed a separate requirement in its 

procedural regulations, providing that the petitioner shall explain why granting the 

exemption would not adversely affect safety or how the exemption would provide at least 

an equivalent level of safety as compliance with the underlying regulation. In this case, 

approval of this exemption would advance the public interest by significantly enhancing 

Aerial analysis by traditional fixed wing aircraft is impractical because the required 

altitudes for safe flight reduce visibility below meaningful levels – it is simply not 

possible to see all asset anomalies from such heights. Helicopters present good vantage 

points; however manned helicopters are much more costly, subject to human safety and 

carry highly explosive aviation fuel making them impractical for deployment. By using 

sUAS for supplemental asset evaluation, Cam MacGregor will be able to substantially

upgrade his capacity to detect and address issues with the assets before they become a 

problem for safe operations. Thus, the use of sUAS has the potential to improve 

efficiency, resulting in greater agriculture production and quality, vital to the U.S. 

economy. 

Granting an Exemption will not Adversely Affect Safety

Cam MacGregor notes that there is no applicable standard for an equivalency

determination. Some have argued that the appropriate standard is that for model aircraft, 

noting that their operations, if conducted for recreational purposes, would fall completely

within the allowable operations for model aircraft. Cam MacGregor believes it is difficult 

to argue that there is sufficient correlation between model operations controlled by the 

Academy of Model Aeronautics and the ones contemplated by Cam MacGregor. At the 

same time, it is clear that equivalency cannot be established for traditional, manned civil 
aircraft because the design and use profiles between traditional aircraft and sUAS are 

simply too different. As such, Cam MacGregor believes it makes more sense to focus on 

why the contemplated operations would not adversely affect safety, which is all that 

§11.81(e) requires. 

Granting an exemption will not adversely affect safety. Cam MacGregor contemplates 

conducting sUAS operations over client owned or controlled land, solely during daylight 

hours, at altitudes well below that which would pose a risk to other aircraft. In general, 

sUAS operations are intended to be conducted in areas distant from both congested areas 

and airports. The nature of operations anticipated by Cam MacGregor requires that the 

sUAS be flown at relatively low altitudes and relatively low speeds. Cam MacGregor

expects that in most instances, the sUAS will be flown no less than 175 feet above the 

highest structure along the path of the sUAS. Accordingly, the risk of interference with 

another aircraft is minimal. Cam MacGregor also plans to conduct sUAS operations at 

least three miles from any public airports (including heliports). In the event an operation 

needs to be conducted closer to an airport, Cam MacGregor will inform the airport 

operator and airport air traffic control tower of the contemplated operation and will 

comply with any directions issued by air traffic control at that airport. 

Approval of exemptions allowing commercial operations of sUASs in the infrastructure 

aerial inspection industry will enhance safety by reducing risk. Conventional operations, 

using jet or piston power aircraft, operate at extremely low altitudes just feet from the 

subject being inspected and in extreme proximity to people and structures; and present 

the risks associated with vehicles that weigh in the neighborhood of 40,000lbs., carrying 

large amounts of jet or other fuel (140 gallons for jet helicopters). Such aircraft must fly

to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the inspection site. The 

sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including 333 Aircraft Exemption Status exempting 

the applicant from conventional aircraft requirements and allowing commercial 

operations. These lightweight aircraft 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 turbine helicopters operating in close proximity to the ground and people. 

The safety of those on the ground is protected by the fact that no one will be allowed into 

the area without the permission of the property owner. Security will be established for the 

flight area as part of the pre-flight control. Each individual within the secure area will be 

briefed prior to flight and will consent to being in the area. All others will be excluded 

from the area. 
Cam MacGregor intends to use a dedicated staff for sUAS operations. All operations will 

be within visual line-of-sight (i.e., no more than approximately 0.5 miles from the 

manipulator of the controls, or pilot in command (PIC)). Each PIC will conduct at least 

three take-offs and landings with the sUAS on which he or she is trained every 90 days. 

PIC’s will establish their qualifications thru a combination	of	aeronautical knowledge, 			

UAS	airmanship	skills,	and	verification	through	testing	of	flight	ability	before 			

infrastructures	operations	have	commenced. Depending on the type of operation, 

additional ground-based visual observers may be employed as well. These observers will 

be within constant visual line of sight and in constant contact with the PIC at all times.

The visual observers will assist the PIC in avoiding objects near the sUAS. 

There are no standards for either Private or Commercial sUAS pilot certificates. The safe 

operation and control of the UAS as described in this application does not depend on the 

type of FAA license held by the PIC. Given the restricted and controlled airspace within 

which operations will take place, the key factors needed by the PIC are knowledge of the 

airspace within which the operation will take place and how that airspace fits into the 

National Airspace System (NAS). That knowledge can be and is gained primarily through 

ground school and not through flight training in fixed wing or rotor aircraft, nor is it 

dependent on the acquisition of a commercial or private pilot’s certificate. Those 

certificates demonstrate knowledge of the factors and skills needed for the safe operation 

of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a 

commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or 

ability to safely operate a small unmanned aerial vehicle, operating at 400’ AGL or 

lower, within strictly controlled pre-approved airspace. Besides knowledge of airspace 

regulations, dexterity in the control and operation of the sUAS acquired from actual 

operation of the aircraft is the most important factor in establishing an equivalent level of 

safety. 

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant 

issues are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what 

is being used today to accomplish the same mission, and (3) what precautions will be 

taken to ensure the safety of those in the area of operation. We propose that the PIC has at 

least an FAA Private Pilots Certificate and a Class III medical; the aircraft be operated 

within a secure environment; and that no one be allowed to enter the secure environment 

unless they are part of the operation, have been fully briefed of the risks prior to operation 

of the sUAS, and have consented to the risks associated with being in the operating area. 

Should there be a mishap, the sUAS being flown pose significantly less of a threat than 

the helicopters and fixed wing aircraft now being employed because they are a fraction of 

the size, carry no flammable fuel, do not carry crew or passengers, and pose an 

infinitesimal risk to others. This is in stark contrast to conventional aircraft that are flown 

to the site, carry explosive fuel, carry passengers and crew, and operate in a much larger 

area. 

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who 

are also qualified to fly the type of sUAS that are utilized for infrastructure image-capture 
operations. There are even fewer commercial pilots that can fly these sUAS – to the point 

that to do both is considered rare. Assuming that it is unlikely for a company to find a 

pilot that has both qualifications, that company would either have to source a qualified 

sUAS pilot to train and obtain a commercial certificate, or find a commercial certificated 

pilot who would be willing to learn to fly a sUAS to the competency level required for 

professional use. The incidence of locating said licensed pilot in rural SW Texas is low.

Minimum requirements for the PIC include: 

1) Private Pilot’s license and a Class III medical; 

2) A minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft 

pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type 

 (single blade or multirotor); 

3) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be 

utilized for operations under the exemption and 3 take offs and landings in the 

preceding 90 days; 

4) Have undergone a qualification process as specified in the Flight Operations & 

Procedures Manual consisting of a knowledge & skill test of the aircraft to be 

used. 

Another consideration supporting the certificate requirement is that pilots holding a 

private pilot certificate are subject to security screening by the Department of Homeland 

Security. This requirement should ameliorate security concerns over UAS operations 

under this exemption. 

Cam MacGregor intends to use commercially available sUAS components for sUAS. 

These sUAS systems will be tested for quality & safety in his test facility before being 

deployed to the field. The sUAS is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, and operates exclusively within a secured area. Cam MacGregor has a 

routine maintenance schedule to verify that the sUAS will remain in safe and operational 

condition. Please see Appendix B, for Specific Types of sUAS. 

Notes Regarding: 14 C.F.R. Part 21, Subpart H

In	accordance with	the	statutory	criteria	provided	in	Section	333	of	PL	112---95	in 			

reference	to	49	USC44704,	and	in	consideration	of	the	size,	weight,	speed,	and 			

limitedoperating	area	associated	with	the	aircraft	and	its	operation,	we	request that	this	

aircraft	exemption	meets	the	conditions	of	Section	333.	Therefore,	if	granted	Section	

333	relief	of	14	CFR	part	21,	and	any	associated	noise	certification	and	testing	

requirements	of part	36,	is	not	necessary.

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft

Given the size of the sUAV, two-inch lettering will be impossible. UA	will	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	will	be	

as large	as	practicable. 			

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

Cam MacGregor’s request is based on the fact that no airworthiness certificate will be 

issued for the UAS. Cam MacGregor’s UAS will not require an airworthiness certificate 

in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness 

certificate will not be issued, exemption from § 91.7(a) is not necessary. 

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations was to display an aircraft’s 

airworthiness, certification, and registration documents so they would be easily available 

to inspectors and passengers. Based on the FAA Memorandum subject “Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft’s 

control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2) 

and 91.203(a) and (b) is not necessary. 

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests

Small UASs, by their design, do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via 

radio communications. Aircraft being considered for use by Cam MacGregor allow the 

UAS Instructor to place the aircraft into ‘loiter’ mode (fixed altitude stationary hold). In 

the event of the student losing control, the UAS Instructor can quickly and via alternate 

equipment (equipment not in the hands of the student) place the aircraft into a mode that 

then allows the instructor to bring the aircraft back into control and back to the 

predetermined and/or safe landing location. All aircraft have GPS-controlled hover mode.

Cam MacGregor does not describe training scenarios in which a dual set of controls 

would be utilized or required, i.e. dual flight instruction, provided by a flight instructor or 

other company-designated individual, that would require that individual to have fully 

functioning dual controls. Rather, Cam MacGregor evaluates the qualification of its PICs 

based on their experience with the UAS to be operated and verifies through testing, in 

lieu of formalized training. As such, Cam MacGregor does not seek relief from 14 CFR § 

91.109. 

Notes Regarding § 14 CFR 91.119(b)

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, 

because Cam MacGregor’s operations will only be conducted within the secured 

agricultural area described herein. 
Cam MacGregor Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from 

highly-reputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the sUAS 

loses communications, the sUAS will have capability to return to a pre-determined 

location within the Security Perimeter and land. 

2. Auto descent (landing) if battery were to drop lower than nominal level. 

3. Flights will be terminated at 25% battery power reserve. 

4. Live video for operator gives real-time positioning feedback. In other words, Cam 

MacGregor can monitor the scene from the vehicle's perspective for collision 

avoidance, and to maintain spatial orientation. 

5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle 

health at all times: speed, altitude, number of GPS satellites (when available), 

heading and voltage. 

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) 

link failures occur (highly improbable), vehicle returns automatically to the point 

of launch. 

8. Altitude information will be provided to the sUAS pilot via a digitally encoded 

telemetric data feed, which downlinks from the aircraft to a ground-based onscreen display. This altitude information will be generated by equipment installed 

on board the aircraft, using GPS triangulation, or digitally encoded barometric 

altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero 

altitude initiation point will be established and confirmed for accuracy by the pilot. 

Mechanical/Physical:

1. Cam MacGregor will fly line-of-sight (LOS) only. The vehicle will always remain 

in direct LOS to the pilot, thus eliminating the concern of signal severance (flying 

behind objects/walls). 

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots. 

3. Batteries should far exceed the capacity required for actual flight time. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Fireproof bags for storage and charging of high capacity LiPo batteries on-site. 

6. UASs operated	under	this	exemption will	be	marked	in	accordance	with	14 			

CFR	part	45 or	as	otherwise	authorized	by	the	FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators 

 (pilot, gimbal operator, mission director) 

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/communication. 
3. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for this 

briefing. 

4. The operator will obtain the consent of all persons involved in the sUAS operations 

and ensure that only consenting persons will be allowed within 100 feet of the 

flight operations. 

5. Observer and pilot will at all times be able to communicate by voice. 

6. Written and/or oral permission from the relevant property owners will be obtained.

7. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated. 

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), 

including energy source(s) and equipment. Operations authorized by this 

petition of exemption are limited to the following aircraft described in 

Appendix B. Proposed operations of any other aircraft will require a new 

petition or a petition amendment to this request.

2. The UA may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operator’s manual. 

All altitudes reported to ATC must be in feet AGL. 

4. 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 

medical certificate. 

5. All operations must utilize a visual observer (VO). 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. 

6. The operator’s manual included as Appendix C and this petition of exemption 

must be maintained 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 operator’s manual, the conditions and limitations 

herein take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operator’s manual. 

The operator may update or revise its operator’s manual. It is the operator’s 

responsibility to track such revisions and present updated and revised documents 

to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment. If the operator 
determines that any update or revision would affect the basis for which the FAA 

grants this petition for exemption, then the operator must petition for amendment 

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operator’s 

manual. 

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition 

 for safe flight. 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. The Ground Control Station, if utilized, must be 

 included in the preflight inspection. All maintenance and alterations must be 

 properly documented in the aircraft records. 

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 in accordance with the 

operator’s manual. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to 

the operator’s manual. 

9. The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the 

operator’s manual. At a minimum, requirements for the following must be 

included in the operator’s manual: 

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used) 

j. Any other components as determined by the operator; 

10. The Pilot In Command (PIC) must possess at least an FAA private pilot 

certificate and at least a current third-class medical certificate. 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. 
11. Prior to operations conducted for the purpose of infrastructure inspections, the

 PIC must have accumulated and logged, in a manner consistent with 14 CFR §

 61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

 rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS 

 type (single blade or multirotor). Prior documented flight experience that was

 obtained in compliance with applicable regulations may satisfy this 

 requirement. Training, proficiency, and experience-building flights can also be

 conducted under this petition of exemption to accomplish the required flight

 cycles and flight time. 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. 

12. Prior to operations conducted for the purpose of infrastructure inspection, the 

 PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

 61.51(b), a minimum of five hours as UAS pilot operating the make and

 model of UAS to be utilized for operations under the exemption and three

 take-offs and three landings in the preceding 90 days. Training, proficiency, 

 experience building, and take-off and landing currency flights can be 

 conducted under this petition of exemption to accomplish the required flight 

 time and 90 day currency. During training, proficiency, experience-building, 

 and take-off and landing currency 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. 

13. Prior to any flight operations authorized by this petition of exemption, the PIC 

and VO must have successfully completed a qualification process, as outlined 

in the operator’s manual. As this is a requirement stipulated by the operator, 

the test must be developed and implemented by a qualified person designated 

at the sole discretion of the operator. A record of completion of this 

qualification process must be documented and made available to the 

Administrator upon request. 

14. Prior to operations conducted for the purpose of infrastructure inspection, a flight 

demonstration, administered by an operator-approved and operator-qualified pilot 

must be successfully completed and documented. This documentation must be 

available for review upon request by the Administrator. Because the knowledge 

and airmanship test qualifications have been developed by the operator, and there 

are no established practical test standards that support a jurisdictional FAA FSDO 

evaluation and approval of company designated examiners, the petitioner will 

conduct these tests in accordance with the operator’s manual. 
15. The UA may not be operated directly over any person, except authorized and 

consenting personnel, below an altitude that is hazardous to persons or property 

on the surface in the event of a UAS failure or emergency. 

16. Regarding the distance from participating persons, the operator’s manual has 

safety mitigations for authorized and consenting personnel. At all times, those 

persons must be essential to the operations. 

17. Regarding distance from nonparticipating persons, the operator must ensure that 

no persons are allowed within 500 feet of the area except those consenting to be 

involved and necessary for the infrastructure inspection operations. This provision 

may be reduced to no less than 200 feet if it would not adversely affect safety and 

the Administrator has approved it. For example, an equivalent level of safety may 

be determined by an aviation safety inspector’s evaluation of the infrastructure 

inspection area to note terrain features, obstructions, buildings, safety barriers, 

etc. Such barriers may protect nonparticipating persons (observers, the public, 

news media, etc.) from debris in the event of an accident. 

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

pre-determined location within the security perimeter and land or be recovered in 

accordance with the operator’s manual. 

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

emergencies in accordance with the operator’s manual. 

20. Each UAS operation must be completed with 25% battery power remaining. 

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

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

petition of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. 

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. The operator must develop procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures must be added to the operator’s manual. 

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

Safety Bulletins. 
25. The operator must develop UAS technician qualification criteria. These criteria 

must be added to the operator’s manual. 

26. The preflight inspection section in the operator’s manual must be amended to 

include the following requirement: The preflight inspection must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator’s manual. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. At least three days before scheduled infrastructure inspection, the operator of the 

 UAS affected by this exemption must submit a written Plan of Activities to the

 local FSDO with jurisdiction over the area of proposed infrastructure inspection.

 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 infrastructure 

 inspection operations conducted under this petition 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 infrastructure 

inspection event; 

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

owners and/or local officials to conduct the infrastructure inspection 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 infrastructure inspection will be 

conducted and the altitudes essential to accomplish the operation. 

29. The 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. 

30. The UA must remain clear and yield the right of way to all other manned 

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

vehicles, parachute activities, parasailing activities, hang gliders, etc.). 
31. 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. 

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

33. 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. 

34. The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UA may not operate within 5 nautical miles of the geographic 

center of a non-towered airport as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

35. 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. Further flight 

operations may not be conducted until the incident, accident, or transgression is 

reviewed by AFS-80 and authorization to resume operations is provided. 

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, Cam MacGregor

provides the following information: 

Contact Information:

Cam MacGregor

707 South Creek Street #416

Fredericksburg, TX 78624

310-497-6232

cammacgregor@aol.com

Regulatory Provisions from which Cam MacGregor seeks an Exemption

Cam MacGregor believes he may need an exemption from the following provisions to 

conduct the contemplated operations. In some instances, relief is needed because relief 

from another provision renders compliance with the regulation at hand infeasible. 

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b) 
14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(1)&(2) 

14 C.F.R. §91.417(a)&(b) 

Cam MacGregor believes an exemption is only needed from the above-listed regulatory

provisions. To the extent that the FAA believes that additional relief is required for Cam 

MacGregor to conduct the operations described here, Cam MacGregor requests an 

exemption from any such regulatory provisions as well.3

3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as 

applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met and will 

require an exemption, Cam MacGregor believes a separate exemption should not be required for 

§91.417(a). 

The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status: 

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the 

requirement for an airworthiness certificate based on a consideration of the size, weight, 

speed, operational capability of the particular UAS, as well as its proximity to airports and 

populated areas. An analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate in the areas and under the conditions contemplated by Cam 

MacGregor will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the conditions proposed in this 

request. 

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by the operator and observer. Operations will be 

conducted in compliance with the FAA and with local public safety requirements to provide 

security for the area of operation as is now done with conventional equipment, infrastructure, 

bridge and out building evaluation. These safety enhancements provide an expanded degree 

of safety to the inspectors over conventional operations. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the sUAS, 

due to its size, speed of operation, location of operation, lack of explosive materials and 

inability to carry a substantial external load. 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS 
operated without an airworthiness certificate, in the restricted environment and under the 

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

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

14 C.F.R. §61.113(a) and (b) 

§61.113 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. 

***** 

Cam MacGregor anticipates initially using specially trained staff to conduct the sUAS 

operations. While these individuals will not hold commercial pilot licenses. The sUAS 

will not carry property for compensation or hire since they will be used solely to assist in 

evaluation of the client’s agricultural property in furtherance of Cam MacGregor’s 

client’s primary business, the successful operation of a infrastructure; however, the 

employees’ operation of the sUAS will not be incidental to their employment with Cam 

MacGregor, and they will be compensated for such work. Without an exemption, the pilot 

would be required to hold a commercial pilot certificate under §61.133. However, the risk 

associated with the contemplated operations is less than the risk posed by a traditional 

aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil 

aircraft, eliminating the risk to other aircraft, and within a geographical envelope under 

the sole control of Cam MacGregor. Accordingly, the risk would be limited to Cam 

MacGregor, who will be appropriately outfitted in safety gear, and the client’s property 

on the ground. Requiring a commercial pilot certificate would provide no appreciable 

safety benefit and would needlessly impose additional cost on Cam MacGregor. Because 

the contemplated operations would not comply with §61.113(b)(1) and none of the other 

exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b). 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General. 

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

aircraft below the following altitudes: 

*** 

(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. 
Cam MacGregor submits that the only relief he requires from §91.119 is from the 

minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed 

wing operations because asset evaluation conducted at 500 feet or higher is insufficiently

distinct to be meaningful. Since operations at this altitude also pose a heightened risk of 

collision with another aircraft, safety can only be assured through the grant of an 

exemption. The anticipated rotorcraft operations should be adequately addressed by

paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because 

an emergency landing of the aircraft due to a power failure will not create an undue 

hazard to persons or property on the surface. As noted in the explanation of why an 

exemption will not adversely affect safety, Cam MacGregor clients have exclusive 

ownership of the land over which the sUAS will be operated, and public access is 

restricted. It also has exclusive use of significant portions of land adjacent to the 

infrastructure and structures that will be the objects of evaluation and analysis. Cam 

MacGregor’s clients tightly control access to land and have the ability to assure that no 

individuals unassociated with the planned operations are on the affected land. As such, 

the risk of injury is minimal. Cam MacGregor does not contemplate conducting 

operations over congested areas, so relief is not requested from paragraph (b). 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” 

***** 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight. 

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed on board the aircraft, using 

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 

§91.151 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. 

(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. 

***** 

Operating the sUAS in a pre-defined area with less than 20 minutes of reserve battery

does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out 

of power in the event it has to be flown to an alternate airport or circle the planned airport 

in the event of unanticipated conditions. Cam MacGregor does not intend to use the 

sUAS for point-to-point flights and will not operate the sUAS beyond visual line of sight. 

Nor will the sUAS require an airport in order to land. Rather, Cam MacGregor will 

operate the sUAS using pre-planned flight paths (taking into account weather conditions) 

designed to allow the sUAS to fly to the point of intended landing. As such, there is no 

need for a time-based excess battery requirement. Rather it should be sufficient to require 

only as much additional excess flight capacity as necessary to safely land the sUAS. We 

believe that a 25% battery reserve is more than sufficient to meet this objective. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) 

§91.405 Maintenance required. 

Each owner or operator of an aircraft –

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter; 

***** 

§91.407 Operation after maintenance, preventive maintenance, 

rebuilding, or alteration. 

(a) No person may operate any aircraft that has undergone maintenance, 

rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under 

§43.7 of this chapter; 

***** 

§91.409 Inspections. 

(a) Except as provided in paragraph (c) of this section, no person may operate 

an aircraft unless, within the preceding 12 calendar months, it has had __ (1) 

An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by §43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

***** 

§91.417 (a) & (b) 

***** 

Cam MacGregor believes that an exemption from these three maintenance requirements 

is appropriate because the FAA has not developed maintenance standards that would 
allow an operator to meet the part 91 maintenance requirements. In particular, there are 

no individuals authorized by the FAA to approve a sUAS for return to service under 

§91.407(a) or to conduct the initial airworthiness and annual return to service inspections 

required by §91.409(a). Cam MacGregor will maintain the aircraft as instructed in the 

owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft 

until it has reasonably determined that any needed repairs have been made. However, 

because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is 

appropriate. 

Please do not hesitate to contact me at the phone number or via the e-mail address 

provided above should you have any questions or concerns. 

Respectfully submitted, 			

 Cam MacGregor 

Appendix A

Summary for Federal Register Publication 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register should the FAA determine that publication is needed. 

Petitioner: Cam MacGregor

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought: 

Cam MacGregor seeks relief from the requirements of 333 Aircraft Exemption Status, 14 

C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 

91.417(a)&(b) to conduct sUAS operations over Cam MacGregor’s client’s owned or 

controlled land, solely during daylight hours, to assist in the safe evaluation and analysis 

of infrastructure and operations. In general, sUAS operations are intended to be 

conducted in areas remote from both congested areas and airports. The nature of
operations anticipated by Cam MacGregor requires that the sUAS be flown at relatively 

low altitudes. Cam MacGregor expects that in most instances, the sUAS will be flown 

greater than 175 feet from the highest structure along the path of the sUAS and in no 

instances will be flown higher than 400 feet above the ground. Accordingly, the risk of 

interference with other aircraft is minimal. 

Appendix B

Specific	type(s), make	and	model 			

			

#1---DJI	S1000 			

			

See	Attached	Flight	Manual: 			

			 DJI	S1000	User	Manual	V1.08			

																																										DJI	A2	Flight	Control
#2---DJI	Phantom	2			

			

See	Attached	Flight	Manuals: 			

			 DJI	Phantom	2	User	Manual 			

			 NAZA---M_Flight	Control	System_v1.26 			

			
#3---DJI	Phantom	3			

			

See	Attached	Flight	Manuals: 			

			 DJI	Phantom	3User	Manual 			

			 NAZA---M_Flight	Control	System_v1.26
#4---DJI	FlameWheel	450			

			

See	Attached	Flight	Manuals: 			

			 DJI	FlameWheel	450	User	Manual

																																																											NAZA---M_Flight	Control	System_v1.26