April 28, 2015 

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence Avenue, SW 

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 

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

unmanned aerial systems on land controlled by clients of [WELLS FARGO] to assist in the safe 

evaluation of agricultural operations and crop damage for our clients. 

Dear Mr. Williams: 

[WELLS FARGO] 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 agricultural operations, infrastructure and crop damage for 

our 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 [WELLS FARGO] 

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 ofthe FAA Modernization and Reform Act of2012 

(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. 

Mark S. McAdam 

Vice President, Wholesale Innovation, Research and Development 

Wells Fargo & Company 

7679 Archer Lane N. 

Maple Grove, MN 55311 

Office: 612 2416 

fargo.com 

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 

[WELLS FARGO] is in the business of assessing risk relative to the lands and infrastructures 

present on farm and ranch businesses operated by our clients. We have Clients looking to us to 

assess damage incurred on the farm and ranch properties: damages that can be most safely and 

thoroughly assessed through the operation of sUAS for Infrastructure Safety, Agricultural & 

Maintenance Inspections. As such, [WELLS FARGO] Clients look to us for Safe Operations of 

sUAS. We have developed specific [WELLS FARGO) Safe UA V Operational Procedures. 

Infrastructure Safety Inspection Operations: 

Utility & Infrastructure Inspection specific to crop harvest and delivery from field 

Agriculture Inspection 

As part of this [WELLS FARGO) is requesting FAA Exemption for sUAS operations for safety, 

inspection and image I 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(£) 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 the safety and 

efficiency of infrastructure operations and by providing the FAA with valuable user experience 

on sUAS in a context with appreciable economic and societal benefits. As described more fully 

below, the requested exemption would permit the operation of sUAS under tightly controlled 

conditions, thus ensuring that operations will not have an adverse impact on safety. To the 

contrary, as explained below, [WELLS FARGO] anticipates that use of sUAS will enhance 

safety in infrastructure and agricultural operations. 

Granting an Exemption is in the Public Interest. The safety and efficiency of infrastructure and 

agricultural operations is heavily dependent upon constant analysis of assets, right-of-way, 

infrastructure and other assets/facilities on the farm and ranch land along with the condition of 

the farm and ranch land itself. There are a wide variety of factors that can affect conditions and 

cause problems for infrastructure and agricultural operations that can impact crop yield and soil 

conditions. Even relatively small objects or minor failures can lead to accidents or other 

incidents causing downtime of infrastructure. Extreme weather events can lead to flooding or 

overheating infrastructure, damage to the structural integrity of the buildings themselves and the 

conditions of the surrounding fields. As a result, pursuant to federal regulations and company 

policy, our client's maintenance employees and in the case of an alleged loss, Wells Fargo, 

routinely inspect the infrastructure and agricultural fields at issue. At present, this work is done 

primarily by company personnel in motor vehicles, on foot, in specialized equipment. This is 

often a labor-intensive and sometimes arduous and risky job. While our clients do all they can to 

make these inspections as safe as possible, there is an irreducible element of risk involved 

whenever employees are required to go out on structures ill'l:d distraught farm land. Employees 
., 

may need to climb over or onto structures, which can be slippery, rough, and/or exposed to the 

elements. Equipment moving through inspection zones can increase risk as well, especially in 

remote areas where they can get stuck and the conditions of impact to the soil difficult to obtain 

in flood like conditions. While the use of sUAS for supplemental infrastructure and general asset 

evaluation would not eliminate these risks entirely (as it is an additive safety measure), it would 

reduce the risks to employees by allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely dispersed locations inherent in the field 

of agriculture operations - in most if not all instances far from sizeable population centers -

means that visual inspection in all instances by company personnel can be inefficient. 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 better vantage points; however manned 

helicopters are much more costly, subject to human safety and carry highly explosive jet fuel 

making them impractical for deployment. By using sUAS for supplemental asset evaluation, 

[WELLS FARGO] will be able to substantially upgrade its capacity to detect and address issues 

with the right-of-way and other assets before they become a problem for safe operations. Thus, 

the use of sUAS has the potential to improve efficiency, resulting in faster and safer delivery of 

crop/damage evaluations, and agricultural resources vital to the U.S. economy. 

Granting an Exemption will not Adversely Affect Safety 

[WELLS FARGO] 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. We believe 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 [WELLS FARGO]. 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, we believe it makes more sense 

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

§11.8l(e) requires. 

Granting an exemption will not adversely affect safety. [WELLS FARGO] contemplates 

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

at altitudes under 400 feet AGL well below that which would pose a risk to other aircraft and 

within FAA sUAS requirements. In general, sUAS operations are intended to be conducted in 

areas distant from both congested areas and airports. Moreover, because of the inherent risks 

presented by standard infrastructure operations, our clients have already taken steps to secure 

property against unauthorized public access. For example, substantial stretches of pipeline, 

utilities, railroad track and oil production sites are fenced, elevated, or otherwise secured to 

prevent access. Other long stretches of infrastructure are, as noted above, in very remote 

wilderness areas. The nature of operations anticipated by [WELLS FARGO] requires that the 

sUAS be flown at relatively low altitudes and relatively low speeds. 
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Accordingly, the risk of interference with another aircraft is minimal. [WELLS FARGO] also 

plans to conduct sUAS operations at least five miles from any public airports (including 

heliports). In the event an operation needs to be conducted closer to an airport, [WELLS 

FARGO] 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. sUAS 

PICS will also be instructed as a part of pre-flight planning to contact local crop dusting 

business(s) to ensure the sUAS will not be flown over fields scheduled during dusting operations 

at least three days in advance. 

Approval of exemptions allowing commercial operations of sUASs in the infrastructure and 

agricultural 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 4,000lbs., carrying large amounts of 

jet A 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 company. 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. 

[WELLS FARGO] initially 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. The visual observers will assist the PIC in avoiding objects near the sUAS. 
[WELLS FARGO] intends to use commercially available sUAS Components for sUAS. These 

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

deployed to the field. The sUAS is less than 50 lbs. fully loaded, carries neither a pilot 

nor passenger, and operates exclusively within a secured area. We have 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 USC 44 704, and in consideration of the size, weight, speed, and limited operating 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 

[WELLS F ARGO]'s request is based on the fact that no airworthiness certificate will be issued 

for the UAS. [WELLS FARGO]'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 [WELLS FARGO] 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. [WELLS FARGO] 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, [WELLS FARGO] evaluates the qualification of its PICs 

based on their experience with the VAS to be operated and verifies through testing, in lieu of 

formalized training. 

As such, [WELLS FARGO] does not seek relieffrom 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 the [WELLS F ARGO]'s operations will only be conducted 

within the secured area described herein. 

[WELLS FARGO) 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 features1. 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 and return to home- RTH (landing) if battery were to drop lower than nominal 

level(25%). 

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

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

Mechanical/Physical: 
1. We 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 50 lbs and travel at less than 87 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. UA operated under this exemption will be marked in accordance with 14 CFR part 45 or as 

otherwise authorized by the FAA. 

Personnel: 

I. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal op) 

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

control/communication. 

3. A briefing will be conducted in regard to all planned sUAS operations prior to 

each days activities. It will be mandatory that all personnel who will be performing 

duties within the boundaries of the safety perimeter be contact WF RCIS central operations to ensure 

all required activities have been completed. 

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. 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) will weigh less than 50 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 87 knots. 

3. Flights must be operated at an altitude of no more than 200 feet above ground level (AGL), as 

indicated by the procedures specified in the operator's manual. All altitudes reported to A TC 

must be in feet AGL. 
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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 ofthe 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 I Servos; 

b. Powerplant (motors); 

c. Propellers; 

d. Electronic speed controller; 
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e. Batteries;. 

f. Remote command and control; 

g. Ground control station (if used); and 

h. Any other components as determined by the operator; 

10. Prior to operations conducted for the purpose of infrastructure and agricultural inspections, 

the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.5l(b), a 

minimum of 50 flight cycles and 10 hours of total time as a UAS rotorcraft pilot and at least 10 

hours logged as a UAS pilot with a similar UAS type. 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. 

1 1. 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 and agricultural operations 

inspection, a flight demonstration, administered by an operator-approved and -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. 
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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 (A TO) 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 (NOT AM) 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 \4 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 jurisdic~ion 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 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 and agricultural operations 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 8, 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 NOT AM 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 
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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, [WELLS FARGO] 

provides the following information: 

Contact Information: 

Mark McAdam./ Vice President 

Wells Fargo Bank, NA 

Wholesale Security Strategic Services 

7679 Archer Lane N 

Maple Grove, MN 55311 

Mark.Mcadam@wellsfargo.com 

Regulatory Provisions from which [WELLS FARGO] seeks ari. Exemption 

[WELLS FARGO] believes it 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)(l)&(2) 

14 C.F.R. §91.417(a)&(b) 

[WELLS FARGO] 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 [WELLS 

FARGO] to conduct the operations described here, we request an exemption from any such 

regulatory provisions as well.33 For example, 14 C.F.R. §91.417(a) imposes certain maintenance 

record keeping requirements "as applicable". Since none ofthe underlying requirements (e.g., 

inspection intervals) can be met and will require an exemption, [WELLS FARGO] 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 [WELLS FARGO] 

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 

Ibs. 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 ofthe 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. 

***** 

[WELLS FARGO] anticipates initially using a cadre of 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 crop I Ranch I Orchard I Vineyard infrastructure and Fields in furtherance of 

[WELLS F ARGO]'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 

[WELLS FARGO], and they will be compensated for such work. 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 [WELLS FARGO] clients. 

Accordingly, the risk would be limited to [WELLS FARGO] personnel, who will be 

appropriately outfitted in safety gear, and [WELLS FARGO] client's property on the ground. 

Requiring a commercial pilot certificate would provide no appreciable safety benefit and would 

needlessly impose additional cost on [WELLS FARGO]. Because the contemplated operations 

would not comply with §61.113(b)(1) 

and none ofthe 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 400 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. 

***** 

[WELLS FARGO] submits that the only relief it 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 ofwhy an exemption will not adversely affect safety, [WELLS FARGO] clients has 

exclusive use 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. [WELLS F ARGO]'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. [WELLS FARGO] 

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 Althneter 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 Operations 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 30 minutes of reserve fuel does not raise 

the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it 

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

conditions. [WELLS FARGO] 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, [WELLS FARGO] 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 fuel 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 ofthis 

chapter; or 

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

accordance with part 21 of this chapter. 

***** 

§91.417 (a) & (b) 

***** 

[WELLS FARGO] 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). 

[WELLS FARGO] 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, 

[SIGNATURE AND TYPED NAME I WELLS FARGO]. 

Appendix A 

Summary for Federal Register Publication 

Pursuant to 14 C.F .R. Part 11, the following summary is provided for publication in the 
r Federal Register should the FAA determine that publication is needed. 

Petitioner: Drone Fleet & Aerospace Management, Inc. ([WELLS FARGO]) 

Sections of 14 C.P.R. Affected: 

333 Aircraft Exemption Status 

14 C.P.R. §61.113(a) and (b) 

14 C.P.R. §91.119(c) 

14 C.P.R. §91.121 

14 C.P.R. §91.151 

14 C.P.R. §91.405(a) 

14 C.P.R. §91.407(a) 

14 C.P.R. §91.409(a) 

14 C.P.R. §91.417(a)&(b) 

Description of Relief Sought: 

Petitioner seeks relieffrom the requirements of333 Aircraft Exemption Status, 14 C.P.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 [WELLS FARGO] 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 [WELLS FARGO] 

requires that the sUAS be flown at relatively low altitudes. [WELLS FARGO] expects that in 

most instances, the sUAS will be flown less than 75 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. 
Federal Register should the FAA determine that publication is needed. 

Petitioner: Drone Fleet & Aerospace Management, Inc. ([WELLS FARGO]) 

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: 

Petitioner seeks relief from the reauirements of 333 Aircraft_Exemotion Status. 14 C.F.R ..