Electronic Submission

Monday, October 26, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Sir or Madam:

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

referred to as FMRA) and 14 CFR Part 11, UAV Flight Ops, LLC (herein referred to as 

UAV Flight Ops or Operator) hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of UAS for the acquisition of 

aerial data, so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA.

As detailed in this document and the attached Appendix of UAS, the requested 

exemption would permit the operation of UAS platforms previously approved by the FAA 

for commercial operations in the United States. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national 

airspace system.” Section 333(c) Reform Act.

The petitioner feels that good cause exists for not publishing a summary of the petition 

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

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

The name and address of the applicant/petitioner is:

UAV Flight Ops, LLC

Captain Mark H Meyer, ATP

CEO & Director of Flight Operations

10764 S. 93rd E. Ave.

Tulsa, Oklahoma 74133-6176

Tel: 918-899-1932

Email: Director@UAVFltOps.com

Page 1 of 21

UAV Flight Ops

An Unmanned Aerial Systems Service Provider
AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This

statutory authority includes exempting civil aircraft, as the term is defined under §40101

of the Act, including UAS, from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections §44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may

operate in the national airspace system without creating a hazard to the user, the public,

or a threat to national security. In making this determination, the Secretary must 

consider:

• The UAS’ size, weight, speed and operational capability;

• Whether the UAS operates within the visual line of sight of the operator;

• Whether the UAS operates outside of highly populated areas and away from 

close proximity to airports.

In addition, Reform Act 333(a). If the Secretary determines that a UAS “may operate 

safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system.” Id. 333(c).

Regulations from which the exemption is requested:

14 CFR 61.23(a) & (c)

14 CFR 61.101(e)(4) & (5)

14 CFR 61.113(a) & (b)

14 CFR 61.315(a) 

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)(1)

14 CFR 91.203(a) & (b) 

14 CFR 91.405(a)

14 CFR 407(a)(1) 

14 CFR 409(a)(1) & (2) 

14 CFR 417(a) & (b)

Page 2 of 21
The Basis for Grant Request

Previously, the FAA has issued a Grant of Exemption No. 12646 to Measure, a 32 

Advisors Company, LLC (see Docket No. FAA−2015−1602) in circumstances similar in 

all material respects to those presented in this petition. In addition, Grants of 

Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to 

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

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

−2014−0642), were granted based upon the enhanced safety achieved using an 

unmanned aircraft (UA) carrying no passengers or crew, rather than a manned aircraft, 

thus providing the FAA with good cause to find that the UAS operation was in the public 

interest.

BACKGROUND ON UAV FLIGHT OPS

UAV Flight Ops is an Unmanned Aerial Systems Service Provider. It is owned, 

operated, and staffed by a group of highly experienced active and retired airline pilots. 

UAV Flight Ops provides consulting services to a wide range of clients, highlighting 

current UAS technology applications. The UAV Flight Ops business model is predicated 

on the implementation of a means-end approach. Defining operational requirements, 

matching the appropriate technological UAS solution, developing business use case 

scenarios, and demonstrating the Return on Investment (ROI) for UAS operations in a 

number of industries. All with a goal of safely delivering specific, low risk, and cost 

effective actionable data to clients in a regulatory compliant manner. 

UAV Flight Ops then services those needs by providing wet lease practical solutions 

appropriate for the client. The UAV Flight Ops custom solution approach allows each 

client to take advantage of the latest drone technologies in a safe, responsible and cost 

effective manner. Providing the client with the ability to safely match the needed aerial 

data collection instrument(s) with the most appropriate UAV for the job.

UAV Flight Ops was founded specifically to help clients avoid expense mistakes and 

large capital outlays. Assisting clients with crew selection, training and safety issues, 

regulatory burdens, while providing deferred liability from the operating risks naturally 

inherent when establishing their own drone programs. As a simple alternative 

approach, clients can purchase drone support operations in a way that better fits their 

operations and cost profiles. Ensuring standardized, regulatory compliant operations 

utilizing trained aviation professionals.

UAV Flight Ops believes in a risk-based and technology agnostic approach to 

operations in the national airspace. We believe that approval for any operation should 

be based on an analysis of the specific needs and the risks associated with a specific 

task and matching those needs with a fully integrated solution, operated by 

professionals.

Page 3 of 21
UAS AND OPERATIONAL DESCRIPTION

UAV Flight Ops seeks to commercially operate a variety of UAS weighing less than 55 

pounds, including payload, in the United States for the purpose of acquiring aerial data. 

The Appendix attached to this exemption petition lists the aircraft that UAV Flight Ops 

contemplates offering to our clients and operating for them. In prior, similar exemptions 

the Secretary has approved every UAS platform included in the Appendix.

As the operator of these aircraft, UAV Flight Ops is committed to the following conditions 

and limitations on its operations. UAV Flight Ops understands that failure to comply will 

be grounds for the immediate suspension or rescission of any exemption granted.

1. Operations are limited to the UAS listed in the Appendix and those UAS 

previously approved by the Secretary when weighing less than 55 pounds 

including payload. Proposed operations of any aircraft not listed in the Appendix 

will require a new petition or a petition to amend this exemption.

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

not contemplated and would require a new petition and exemption.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour) using either groundspeed or calibrated airspeed to determine compliance 

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

airspeeds greater than the maximum aircraft operating airspeed recommended 

by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in 

Command (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 U.S. driver’s license.

6. All operations will utilize a visual observer (VO). 

6.1. The aircraft will be operated within the visual line of sight (VLOS) of the PIC 

and VO at all times. 

6.2. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. 

6.3. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. 

6.4. The PIC must ensure that the VO can perform the duties required of the VO.

7. All operating documents needed to operate the UAS and will be accessible 

during UAS operations and made available to the Administrator upon request.

Page 4 of 21
7.1. The operator will also present updated and revised documents if it petitions 

for extension or amendment.

7.2. If a discrepancy exists between the conditions and limitations in any granted 

exemption and the procedures outlined in the operating documents, the 

conditions and limitations in any granted exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. 

7.3. The operator may, in the normal course of business, update or revise its 

operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator 

or any law enforcement official upon request. 

7.4. The operator must also present updated and revised documents if it 

petitions for an extension or amendment to any previously granted 

exemption(s). 

7.5. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted this exemption, then the operator must petition 

for an amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS−80) will be contacted if questions arise regarding updates or 

revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that might affect the 

UAS operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight prior to conducting further 

operations under this exemption. 

8.1. Functional test flights may only be conducted by a PIC with a VO present 

and must remain at least 500 feet from other people. 

8.2. The functional test flight must be conducted in such a manner so as to not 

pose an undue hazard to persons and property.

8.3.All functional test validations must be recorded in the aircraft’s maintenance 

log and signed off, electronically or otherwise, by the PIC conducting the 

tests.

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

is in a condition for safe operation.

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

UAS is in a condition for safe flight.

10.1. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment. 

10.2. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary 

Page 5 of 21
maintenance has been performed and the UAS is found to be in a condition 

for safe flight.

10.3. All maintenance and all component replacements, including payloads, must 

be recorded in the aircraft’s maintenance logbook.

11. UAV Flight Ops will follow the UAS manufacturer’s maintenance, overhaul, 

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

components.

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

safety bulletins.

13. The PIC must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. 

13.1. The PIC must also hold a current FAA airman medical certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, 

a territory, a possession, or the Federal government. 

13.2. The PIC must also meet the flight review requirements specified in 14 CFR 

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

14. UAV Flight Ops will not permit any PIC to operate unless the PIC demonstrates 

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

will be operated under any granted exemption. 

14.1. Training will include skills necessary to safely acquire aerial data, and will 

include training on evasive and emergency maneuvers. With special focus 

on maintaining appropriate distances from persons, vessels, vehicles and 

structures. 

14.2. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). 

14.3. UAV Flight Ops will operate flights for the purposes of training pilots, PICs 

and VOs, (training, proficiency, and experience building) and determining 

the PIC’s ability to safely operate the UAS.

14.4. Training operations may only be conducted during dedicated training 

sessions. 

14.5. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91.119.

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

15.1. All operations will be conducted under visual meteorological conditions 

(VMC). 

Page 6 of 21
15.2. Flights under special visual flight rules (SVFR) are not authorized.

16. The aircraft will not operate within 5 nautical miles of an airport. 

16.1. The 5 nautical mile distance is defined as a straight line distance from the 

airport reference point (ARP) as denoted in the current FAA Airport/Facility 

Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart.

16.2. Any flight within the above mentioned airport exclusion zone must be 

preceded by a letter of agreement with that airport’s management or as 

otherwise permitted by a COA.

16.3. In all cases, when flying within 5 nautical miles of an airport, two way radio 

communications must be established and maintained between the PIC and 

the appropriate controlling authority for the airspace in use, before takeoff 

and during all flight operations.

17. The aircraft will not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

18. If the UAS loses communications or loses its GPS signal, the aircraft must return 

to a pre-determined location within the bounds of pre approved controlledaccess property.

19. The PIC will abort the flight in the event of the intrusion of non-participants into 

the safety zone, degraded weather conditions, unpredicted obstacles, or other 

emergencies. The PIC will land at the safest location possible, in-point-of-time.

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the UA 

to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power or fuel recommended by the manufacturer if 

greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the 

blanket COA does not cover the intended operation.

22. All aircraft operated 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.

23. Documents used by UAV Flight Ops to ensure the safe operation and flight of 

the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating. These documents will be made available to the 

Administrator or any law enforcement official upon request.

Page 7 of 21
24. The UA will remain clear and give way to all manned aviation operations and 

activities at all times.

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

however, specific requests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

26.1. Barriers or structures are present that sufficiently protect nonparticipating 

persons vessels, vehicles or structures.

26.2. The operator must ensure that nonparticipating persons remain under such 

protection. 

26.3. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations must cease immediately 

in a manner ensuring the safety of nonparticipating persons; and

26.4. The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption.

26.5. An exception is requested when the owner/controller of any vessels, 

vehicles or structures has granted permission for operating closer to those 

objects and the PIC has made a safety assessment of the risk of operating 

closer to those objects and determined that it does not present an undue 

hazard.

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

conducted with the permission from the property owner/controller or authorized 

representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS−80) within 24 hours.

29. Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, establishes the procedural requirements for the issuance of airworthiness

certificates as required by FAR §91.203(a)(1). Given the size and limited operating area

associated with the aircraft to be utilized by UAV Flight Ops, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. 

Page 8 of 21
The Federal Aviation Act (49 USC §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 UAS. 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 operating with an airworthiness 

certificate without the restrictions and conditions proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high

“limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance

to a cabin, cockpit or pilot station. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

the word “Experimental” can be placed. Given the size of the UAS, 2 inch lettering may 

be impossible. UAV Flight Ops will mark the UAS as practicable.

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

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because 

the UAS will not carry a pilot or passengers, the proposed operations can achieve the

equivalent level of safety of current operations by requiring the pilot operating the

aircraft to have completed a UAS flight-training course. 

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely 

controlled. The area of operation is controlled and restricted, and all flights are planned 

and coordinated in advance. The UAS has the ability to land safely, on a moments 

notice, in extremely confined spaces if necessary. The risks associated with the 

operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations 

of the UAS as requested exceeds the present level of safety achieved by 14 CFR 

61.113(a) and (b).

14 CFR 91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

UAV Flight Ops contemplates operating, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft 

and the operational restrictions put on the aircraft, an equivalent level of safety will be 

provided.

Page 9 of 21
14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements. 

 The UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft. The equivalent level of safety 

will be maintained by keeping the Operating Manuals at the ground control point where 

the pilot flying the UAS will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to

ensure the safety of flight. An exemption is needed from this requirement, as the pilot

will take separate preflight actions, including checking for weather conditions, checking

flight battery or fuel requirements, checking takeoff and landing distances, and all other

actions in the Operating Manual and safety checklists. These actions will provide an

equivalent level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. 

By design, UAS 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. The equivalent level of safety is provided by the fact that neither 

a pilot nor passengers will be carried in the aircraft, the ability to control the UAS via 

radio signals from the controller and by the size and speed of the aircraft.

14 CFR 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will

never operate at altitude higher than 400 AGL and all operations will occur during

daylight hours under Visual Meteorological Conditions (VMC) only.

The equivalent level of safety will be achieved given the size, weight and speed of the

UAS as well as the location where it is operated. No flight will be taken without the

permission of the property owner. Because advance notice to the property owner and 

any onsite personnel, as well as the precautions outlined below, all affected individuals 

will be aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating persons

(persons other than the pilot in command (PIC) or visual observer (VO)), vessels,

vehicles and structures, unless operations do not present an undue hazard.

Page 10 of 21
The UAS will remain within visual line of sight of the PIC or VO. Flight operations will

be conducted at least 5 miles from an airport. The PIC or VO will provide notification to

the local Flight Standards District Office and airport controller of all operations within 5

miles of an airport. The FAA will have advance notice of all operations through the filing

of notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS

proposed herein, any risk associated with our operations is far less than those presently

presented with helicopters and other conventional aircraft operating at or below 500 feet

AGL. In addition, the low-altitude operations of the UAS will ensure separation between

these UAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the 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 UAS 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 PIC confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

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

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions.

Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of a

variety of UAS during daylight hours in visual flight rules (VFR) conditions to continue

until 90 percent of remaining battery power or fuel reserves remain. UAV Flight Ops 

seeks the requested relief because without an exemption from Section 91.151(a)(1), the 

flight time duration of the selected aircraft will be reduced and severely constrain the 

practicality of any aerial acquisition of data that UAV Flight Ops proposes to conduct 

pursuant to this Petition.

The technical specifications of the proposed UAS, their Operations Manuals, and

UAV Flight Ops’s proposed operating limitations, ensure that UAV Flight Ops will safely 

operate the selected aircraft during daylight hours in VFR conditions until 90 percent of 

remaining battery power or fuel reserves remain.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot.

Therefore, there is no ability or place to carry certification and registration documents or

to display them on the UAS. An equivalent level of safety will be achieved by keeping

these documents at the ground control point where the pilot flying the UAS will have

immediate access to them, to the extent they are applicable to the UAS.

Page 11 of 21
14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance inspections

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to UAV Flight Ops. Maintenance will be 

accomplished pursuant to the User Guide or Operating Manual. An equivalent level of 

safety will be achieved because these UASs are limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise, the UAS can land immediately in a very small space and will be operating 

from no higher than 400 feet AGL. The PIC will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance and keep a log of any 

maintenance performed. Moreover, the PIC is the person most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety.

Furthermore, the Director Of Flight Operations will ensure that all UAV Flight Ops pilots 

adhere to UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life 

limit requirements for the aircraft and aircraft components. As well as strict compliance

with all manufacturer safety bulletins. 

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition

of data enhances safety while reducing risk. Manned aircraft, in certain applications 

such as pipeline monitoring, create a greater risk because the aircraft are much larger 

and carry humans onboard. In contrast, a UAS weighing 55 pounds or less will carry no 

passengers or crew and, therefore, will not expose the UAS operators or people and 

property on the ground to the risks associated with manned aircraft flights. In addition, 

additional streams of aerial data will allow large commercial entities to make decisions 

about how to best deploy ground resources and ensure the safety and costeffectiveness of their operations. 

EQUIVALENT LEVEL OF SAFETY

UAV Flight Ops proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current and proposed regulatory structure.

Page 12 of 21
PRIVACY

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

prior consent and knowledge. Images or video taken of individuals will have consented 

to being filmed or otherwise they will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which

they will operate, our petition presents no national security issue.

FEDERAL REGISTER SUMMARY

Docket No.: No. FAA-2015-____

Petitioner: UAV Flight Ops, LLC

Part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119,

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of

Title 14, Code of the Federal Regulations (14 CFR).

Description of Relief Sought: UAV Flight Ops is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems.

Based upon the foregoing, UAV Flight Ops requests that the FAA grant it the necessary

exemptions under Section 333 of the FAA Reform Act as requested herein to allow for

commercial operations of UAS within the United States.

Sincerely,

Captain Mark H Meyer, ATP

CEO & Director of Flight Operations

UAV Flight Ops, LLC

10764 S. 93rd E, Ave.

Tulsa, OK 74133-6176

ENCLOSURE - Attachment 1, Appendix of UAS - List of UAS platforms requested.

Page 13 of 21
Attachment 1

Appendix of UAS

The petitioner is requesting relief from 14 CFR part 21, Certification procedures for 

products and parts, Subpart H—Airworthiness Certificates and any associated noise 

certification and testing requirements of part 36.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and 

limited operating area associated with the following aircraft and their operation. 

Requested UAS platforms, are all previously approved by the FAA for commercial 

operations in the United States.

The following list of aircraft meet the conditions of Section 333

1. 2AgEagle

2. 3D Robotics Aero-M

3. 3D Robotics Iris

4. 3D Robotics Iris+

5. 3D Robotics X8

6. 3DRobotics Fixed Wing

7. 3DRobotics Multirotor

8. 3DRobotics Quadrotor

9. 3DR Solo

10. 3DR Spektre

11. 3DRobotics Spektre Industrial Multi-Rotor Aerial Vehicle

12. 3D Robotics Solo

13. 3DRobotics X8+

14. 3D Robotics X8-M

15. 3D Robotics Y6

16. Aerial Mob Heavy Lifter

17. Aerial Mob Light Lifter

18. Aerial Remote Mineral Detection System (ARMDS)

19. Aerialtronics Zenith with intergrated Airware system

20. Aerialtronics Altura Zenith ATX8

21. Aerigon

22. Aerobo

23. AeroCine Kopterworx Hammer X12

24. Aeromao AeroMapper 300

25. Aeromao Talon

26. Aeromao Aeromapper 300

27. Aeromao Aeromapper EV-2

28. AeroVironment Shrike

29. AeroVironment Puma

Page 14 of 21
Appendix of UAS - Continued

30. Aeronavics X4 Titanium

31. Aeryon Sky Ranger

32. Aervonics Sky Jib frame with a DJI A2 flight system

33. Aero-M

34. Aeryon Scout

35. Aeryon SkyRanger

36. AgEagle

37. AgEagle Robotic

38. AgScout

39. AgScout Mini

40. Agribotix Hornet Drone

41. Agribotix Enduro Quad

42. AgriView VK Ranger EX

43. Aibot

44. Aibotix X-6

45. Air Rover AR-3000

46. AirCover QR-425s

47. AirRobot AR 180

48. AirRobot AR 100

49. AirRobot AR200

50. Air-X

51. Align M690

52. Altavian Nova

53. Altavian Nova F6500

54. Altavian Nova R8400

55. Altus X-4

56. Altus X-8

57. American Drones, LLC Eagle

58. Apprentice

59. Arch Aerial OCTO multi-rotor UAS

60. Arris hexacoper

61. AR-960 Hex Rotor

62. AR-540 Quad Rotor

63. ARF-MikroKopter OktoXL

64. ARF-MikroKopter OktoXL +

65. ArrowLite

66. AscTec Falcon

67. AscTec Falcon 8

68. Astraeus Aerial Cinema System V.3CS

69. Atlantic RC Aircraft LC04

70. Auburn Trimble UX5

71. Auburn War Eagle

72. Auburn EasyStar

73. Auburn

Page 15 of 21
Appendix of UAS - Continued

74. AV44

75. Bixler 3DR Plane

76. Blade 350QX

77. Bixler 2

78. Boomerang Carbon Fiber Frame (The Identified System)

79. Bormatec Maja UAV

80. BOSH Technologies Super Swiper

81. Bumblebee-S

82. C-Astral Bramor gEO

83. CarbonCore Octocopter 1000

84. Carbon Core Cortex Quadcopter

85. CCO w/Wkm M

86. Chameleon Pro

87. CinesStar

88. Cinestar 6

89. Cinestar X8

90. Cinestar 8

91. Cinestar 8 HL

92. Cinestar 8 Okto XL

93. Coaxial Quad Multirotor VAO1-V1

94. Coaxial Quad Multirotor VAO2-V2

95. CopelandRED LLC Delta Wing Aircraft

96. CyberQuad Maxi

97. DJI Flame Wheel F450

98. DJI Flame Wheel F550

99. DAx8

100. DJI Inspire

101. DJI Inspire 1

102. DJI Inspire 2

103. DJI M P330z

104. DJI Phantom

105. DJI Phantom 1

106. DJI Phantom 2

107. DJI Phantom 2+

108. DJI Phantom 2 Vision

109. DJI Phantom 2 Vision+

110. DJI Phantom Vision +

111. DJI Phantom 3

112. DJI Phantom FC40

113. DJI Spreading Wings S900

114. DJI Spreading Wings S1000

115. DJI Spreading Wings S1000+

116. DJI S800

117. DJI S800 EVO

Page 16 of 21
Appendix of UAS - Continued

118. DJI T600

119. Draganflyer Guardian

120. Draganflyer X4ES

121. Draganflyer X4P

122. Draganflyer X6

123. DT-18

124. DYS D800-X8

125. Eagle VTOL

126. Eagle V2

127. E-Flite Apprentice

128. Event 38 E384

129. F-450

130. Falcon VTOL

131. Fire Fly 6

132. First Aerial Responder UAV

133. Flame Wheel G4 7.8 Skycrane

134. Flying-Cam 3.0 SARAH

135. Foxtech Kraken 130 V2

136. FreeFly Systems ALTA RTF

137. FreeFly Systems Octocopter Airframe (Legacy)

138. G4

139. G4 models

140. GeoStar

141. GerMAP G220

142. GerMAP G180

143. goFarm GF-1

144. Gryphon Dynamics X8

145. GT80X

146. Harris 18 HL

147. HEFF

148. Helicopters West DJI Inspire

149. Helicopters West SkyJib 8

150. Helios 960

151. Hawkeye Mk-III

152. HexaCrafter HC-1100 85.

153. HexaCrafter HO-1250

154. HH Blade 350QX2 AP

155. Hobbyking “Bixler” Fixed Wing Trainer

156. HoneyComb AgDrone

157. Horizon Hobby Blade 350 Qx2 quadcopter

158. Hoverfly LiveSky, BigSky 60 and H-Frame

159. Hubsan X4 micro drone

160. HVP 14301 Multi Rotor

161. Identified System

Page 17 of 21
Appendix of UAS - Continued

162. IMT Global xFold Cinema

163. Indago

164. InovalDrone:Inova One

165. InstantEye Mk-2

166. InstantEye Mk-2 Gen2

167. Intuitive Aerial Aeragon

168. K130 Octocopter

169. KongCopter X8

170. Kopterworx Hammer X12

171. Latitude HQ-4 Hybrid Multirotor

172. LB700

173. Leading Edge Precision Vision 10

174. Leptron Avenger

175. Lewis Realty Associates Hexacopter 650

176. Liberty 1

177. Lockheed Martin Desert Hawk III

178. Lockheed Martin Indago

179. Matrix quad copter

180. MaxFlight

181. MD4-200

182. MD4-1000

183. Mikrokopter 2.5

184. MLB Company Super Bat

185. MU-1H

186. Multirotor G4 7.8 Skycrane

187. Nighthawk

188. Nighthawk VTOL

189. OktoXL 6S12

190. PAG X4

191. Parksone Radian RTF

192. Parrot Bebop drone

193. Parrot PF 725100 Bebop Drone 14MP

194. Parrot Skycontroller

195. Patriot X4

196. Patriot X8

197. Finwing Penguin V2

198. Birdseyeview FireFly 6

199. Phoenix

200. Phoenix VTOL

201. Phoenix 60

202. Phoenix 60LE

203. Pixhawk

204. Precision Drone Pacesetter

205. PrecisionHawk

Page 18 of 21
Appendix of UAS - Continued

206. PrecisionHawk Hawkeye Mk-III

207. PrecisionHawk Lancaster

208. Precision Lancaster MK3

209. Prioria Hex

210. Prioria’s Maveric

211. Pulse Aerospace, PA 01 Vapor

212. Pulse Aerospace Pulse Vapor 35

213. Pulse Vapor

214. Puma AE DDL

215. PV 14817 Multi Rotor

216. PV HL1

217. PV HL2

218. Q1

219. Quadcopter LLC MikroKopter

220. Quiet UAV

221. Qube

222. R/C Rotors and Aerial Media: Matrix Prof. Multi Rotor Frame & 

Octo Heavy Lift Prof. Multi Rotor

223. Frame Ronin Edition Microdrones:MD4-1000

224. RCTimer Hexacopter

225. RDASS

226. REHawk 500

227. REHawk 680

228. RF-70

229. Riegl RiCopter

230. RITEWING Z3 Spade 47”

231. Ritewing Drake 60”

232. RITEWING Z3 Spade 70”

233. RITEWING Z4 Spade 52”

234. RMAX

235. Roboflight

236. Rotomotion SR-15

237. RV Jet

238. Scout X4

239. SD02

240. Seahawk 1.2

241. SelectTech Geospacial’s EH-4

242. SenseFly eBee

243. SenseFly eBee RTK

244. SenseFly eXom

245. Sensurion Magpie MP-1

246. Service-Drone Recon One

247. Service-Drone Blackbird

248. SH 900

Page 19 of 21
Appendix of UAS - Continued

249. ShadowHawk

250. Shrike

251. Sirius

252. SkyCatch

253. SkyJib 8 v.2 Heavy Lifter

254. SkyPhilly MI

255. Skywalker Aero

256. Skywalker Flying Wing X8

257. SnapRoll Media SUAS

258. Solutions Phoenix 30

259. SteadiDrone

260. Steadidrone Quad

261. Steadydrone QU4D

262. Steadidrone Mavik

263. SuperX/P2 Multirotor

264. Swift Radioplanes Lynx

265. Tali 500

266. Talon 120LE

267. Tarot FY690S Hexacopter

268. Tarot quadcopter

269. Tarot 680pro

270. Tarot 690

271. Tarot 900

272. Tarot 960

273. Tarot T-15

274. Tarot T15 C/F Folding Octocopter

275. Tarot T18 UAV

276. Tarot T690

277. Tarot T810

278. Tarot T960

279. Tarsier Systems MoAC

280. Tayzu Robotics Titan X8

281. TBS Discovery Pro

282. Team Black Sheep Discovery Pro Tarot T15

283. T-Rex 700E F3C

284. TREX 800E DFC PRO

285. Trimble UX5

286. Trimble UX5 hp

287. Trimble ZX5

288. Turningy Talon 500

289. TUP X8-800

290. Turbo Ace CINEWING 6

291. TurboAce Matrix-G quadcopter

292. Turbo Ace matrix-E

Page 20 of 21
Appendix of UAS - Continued

293. Turbo Ace MATRIX-1

294. UAV Solutions Phoenix 60

295. Universeye Penguin

296. Unmanned Flying Rolling Orb “UFRO”

297. US2 GreenHawk

298. UtiliCopter ITX8

299. VA03-v1

300. VA04-v1

301. VA07-v1

302. Viking UAS Multicopter (VTOL)

303. Viking UAS FF-X4/X8

304. VK-Patriot X4/X8

305. Viking UAS Patriot X4/X8 Multirotor

306. Viking UAS X6 Model 800

307. Viking UAS Viking ONE

308. VK-450

309. Viking Unmanned Aerial Systems, LLC AgriView VK Ranger EX

310. Viking VK-FF-X4

311. VK- Ranger EX- SAR Fixed Wing UAS

312. Volantex Raptor Tarot T-18

313. Volt Aerial Robotics Octane

314. Vulcan frame controlled by a DJI A2 flight controller

315. Vulcan Mantis

316. Vulcan Octocopter

317. Vulcan Raven

318. Vulcan UAV

319. Walkera TALI H500

320. Walkera Scout X4

321. Wookong DJI 5800

322. xCel Drones XD550CDR

323. XFold Rig Quadcopter

324. XFold Rig Hexcopter

325. XFold Rig Octocopter

326. XFold Rig x12 Copter

327. X8-M

— End — 

Page 21 of 21