@ lntelinAir. 

9 November 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Petition of lntelinAir, Inc. for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 

To whom it may concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

lntelinAir, Inc. hereby applies for an exemption from Federal Aviation Regulations (FARs), 

identified below, to allow commercial operations of a small unmanned aerial system (UAS). 

This exemption is in accordance with protocols outlined in this petition for exemption, the 

enclosed UAS manufacturer's operations and/or instructions manual, UAS User's Manuals, and 

any other requirements established by the FAA pursuant to Section 333 of the Reform Act. 

This exemption would permit commercial operation by lntelinAir, Inc., which uses all versions of 

the lntelinAir SafeSmart RD-100 UAS, lntelinAir SafeSmart RD-200 UAS, DJI Phantom 3 UAS, 

DJI S900 UAS, DJI Matrice 100 UAS, 3D Robotics IRIS+ UAS, and 30 Robotics Solo UAS to 

conduct UAS imaging, videography, inspections (agricultural and commercial), public safety 

demonstrations, and test flights. 

lntelinAir, Inc.'s operation under the exemption will be subject to strict operating requirements 

and conditions to ensure an equivalent level of safety to currently authorized operations using 

manned aircraft and under conditions as may be modified by the FAA as required by Section 

333.2. 

lntelinAir, Inc. will be operated under controlled VFR conditions at low altitude in airspace that is 

permitted in accordance with lntelinAir, Inc.'s approved Certificate of Authorization (COA). They 

will operate the UAS's with pilots who are current and qualified with a FAA Pilot Certificate and 

only after completing lntelinAir, Inc.'s training program. Finally, when operating within controlled 

airspace, the controlling FAA ATC will approve the airspace in which the UAS will operate in 

advance. 

lntelinAir, Inc. respectfully submits this request for an exemption because it operates UAS's. 

The operations of lntelinAir, Inc. will be conducting will be in lieu of comparatively hazardous 

operations now conducted with fixed wing and rotary conventional aircraft. The FAA can have 

confidence that the operations will be conducted at an equivalent level or greater level of safety. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform 

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Act to "establish requirements for the safe operation of such aircraft systems in the national 

airspace system." 

For your convenience, lntelinAir, Inc. has organized this Exemption request as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

Ill. Qualifications for Approval Under Section 333 of the Reform Act 

IV. Description of Proposed Operations 

V. Regulations From Which Exemption is Requested 

VI. Public Interest 

VII. Privacy 

VIII. Federal Registry Summary 

IX. Conclusion 

I. Petitioner's Description 

lntelinAir, Inc., headquartered in San Jose, California, is a company that provides custom drone 

& autopilot technology designed for flight research and various commercial applications. 

The contact information for Petitioner is as follows: 

lntelinAir, Inc. 

90 Great Oaks Blvd., Suite 202 

San Jose, CA 95119 

II. Relevant Statutory Authority 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain unmanned 

aircraft systems may operate safely in the National Airspace ("NAS") before completion of the 

formal UAS rulemaking, based on the following considerations: 

A. The UAS's size, weight, speed, and operational capability 

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B. Operation of the UAS in close proximity to airports and populated areas; and 

C. Operation of the UAS within the visual line of sight of the operator. 

If the Secretary determines that such vehicles "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". 

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is 

in the public interest. A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety (or 

how it would provide a level of safety at least equal to the existing rules). 

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

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under 

§401 01 of the Act, from the requirement that all civil aircraft must have a current airworthiness 

certificate and those regulations requiring commercial pilots to operate aircraft in commercial 

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

prescribed under subsection (a) or (b) of this section or any of sections. 

Ill. Qualifications for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant factors are 

satisfied. 

The proposed operations would permit lntelinAir, Inc. the use of small UAS under controlled 

conditions in airspace that is: (1) predetermined; (2) controlled as to access; and that (3) 

provides an increased level of safety beyond that existing when fixed or rotor wing aircraft are 

used to accomplish the same purpose. 

lntelinAir, Inc. uses UASs that are multirotors, weighing less than 55 pounds including payload. 

They operate, under normal conditions, at speeds not to exceed 5 m/s. The multirotor has the 

capability to hover and move in the vertical and horizontal plane. lntelinAir, Inc.'s UASs will 

operate in line of sight, during daylight hours, and will only operate within a sterile area. 

lntelinAir, Inc. will operate at or below 400 feet AGL and will file a NOT AM and follow any FAA 

requirements if flight in controlled airspace is required. All required permissions and permits 

would be obtained from territorial, state, county or city jurisdictions, including local law 

enforcement, fire, or other appropriate governmental agencies prior to operating a UAS. 

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

they will operate, this lntelinAir, Inc.'s exemption falls within the zone of safety and demonstrate 

an equivalent level of safety, in which Congress desired the FAA to permit commercial UAS 

operations by exemption pending completion of formal rulemaking . Also, due to the size of the 

UAS's and the confined area in which these UAS's will operate, approval of the application 

presents no hazard. 

90 Great Oaks Blvd #202 1 San Jose, CA 95119 llntelinAir. com 
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Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in 

the public interest. 

IV. Description of Proposed Operations 

To assist the FAA in its safety assessment of lntelinAir, Inc.'s proposed UAS operations, below 

is a summary of operational limitations and conditions that will ensure an equivalent or higher 

level of safety to operations conducted under current regulatory guidelines: 

1. The UAS will weigh less than 55 pounds. 

2. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or visual 

observer. 

3. Maximum total flight time for each operational flight will be limited to the amount of time 

the UAS can be flown and still maintain a reserve battery power of no less than 25%. 

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

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, people not associated with the operation or who 

have not signed a waiver in advance of the operation. 

6. Minimum crew for each operation will consist of the UAS Pilot in Command and a Visual 

Observer when operating with the use of FPV equipment. Additional crewmembers may 

consist of a Pilot and a Camera Operator. 

7. The UAS PIC will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a 

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

territory, a possession, or the Federal government. The PIC will 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." 

8. lntelinAir, Inc. will designate a PIC for each mission. 

9. The UAS will operate only within a confined sterile area. 

10. Prior to the operations at a particular location, a site inspection will have been 

conducted. On the day of the mission the PIC and any required crew members will 

concur on dispatching of the mission. 

90 Great Oaks Blvd #202 1 San Jose, CA 95119 llntelinAir.com 
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11. A briefing will be conducted in regard to the planned UAS operations prior to each day's 

missions. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the sterile area be present for this briefing. 

12. All UAS's will be maintained in compliance with the manufacturer's and Company 

guidelines. 

13. In the event of an 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. Accidents will be reported to 

the NTSB. 

14. Pilot in Command and Visual Observer will at all times be able to communicate by voice. 

15. Pilot in Command, Pilot, Camera Operator, Visual Observer, and Operational Personnel 

will have been trained and tested in accordance to lntelinAir, Inc.'s UAS Aircraft 

Operating Manual. 

16. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental 

agencies. 

17. If the UAS loses communications signal, the UAS will have the capability to return to a 

pre-determined location within the Sterile Area and land. 

18. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer. 

19. The UAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

20. lntelinAir, Inc. will assure no individuals' privacy is violated. 

21 . ATC will be contacted prior to operating in airspace other than G. 

V. Regulations From Which Exemption is Requested 

A. 14 CFR § 91.103: Preflight Action 

B. 14 CFR § 91.113: Right-of-Way Rules 

C. 14 CFR § 91.119(c): Minimum Safe Altitudes 

D. 14 CFR § 91.121: Altimeter Settings 

E. 14 CFR § 91 .151 (b): Fuel Requirements for Flight in VFR Conditions 

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections 

90 Great Oaks Blvd #202 1 San Jose, CA 95119 llntelinAir.com 
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A. 14 CFR § 91.103: Preflight Action 

lntelinAir, Inc. requests an exemption from the preflight actions requirements of 14 CFR 91.113 

that prescribes the preflight actions under which aircraft may operate: 

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

information concerning that flight. 

(a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

fuel requirements, alternatives available if the planned flight cannot be completed, and 

any known traffic delays of which the pilot in command has been advised by ATC; 

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

landing distance information: 

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

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

landing distance data contained therein; and 

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

other reliable information appropriate to the aircraft, relating to aircraft 

performance under expected values of airport elevation and runway slope, 

aircraft gross weight, and wind and temperature. 

lntelinAir, Inc. will not operate UAS's under IFR conditions or when the ceilings are below 1000 

feet and the visibility is below 3 statute miles. lntelinAir SafeSmart RD-100 UAS, lntelinAir 

SafeSmart RD-200 UAS, DJI Phantom 3 UAS, OJI S900 UAS, OJI Matrice 100 UAS, 30 

Robotics IRIS+ UAS, and 30 Robotics Solo UAS have a maximum takeoff and landing radius of 

5 meters. 

Equivalent Level of Safety 

lntelinAir, Inc. will ensure that the weather will be adequate to complete the mission in VFR 

conditions. When lntelinAir, Inc. operates at a high altitude location, the UAS will be test flown at 

gross weight to check performance limitations prior to conducting commercial operations. 

B. 14 CFR 91.113: Right-of-Way Rules 

lntelinAir, Inc. requests an exemption from 14 CFR 91 .113 Right-of-way rules, requiring 

vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule 

of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and 

may not pass over, under, or ahead of it unless well clear. 

lntelinAir, Inc. operates small pilotless UAS's and cannot comply with these rules as they have 

been written. 

Equivalent Level of Safety 

lntelinAir, Inc. operates UAS's at or below an altitude of 400 feet AGL, well below the normal 

90 Great Oaks Blvd #202 1 San Jose, CA 95119 jlntelinAir.com 
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operating altitude of other aircraft. An lntelinAir, Inc. A PIC with extensive aeronautical 

experience and with knowledge of the avoidance rules will oversee each mission. A Visual 

Observer will assist the PIC in looking for aircraft entering the operations area. It's the 

responsibility of the PIC to cease operations and land the UAS immediately whenever any 

aircraft comes into the vicinity creating a potential threat. Operations cannot recommence until 

the threat is clear. 

C. 14 CFR. § 91.119: Minimum Safe Altitudes 

lntelinAir, Inc. requests an exemption from the minimum safe altitude requirements of 14 CFR 

91 .119 that prescribes the minimum safe altitudes under which aircraft may operate: 

1. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft. 

2. Over other than congested areas at 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. 

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when 

it can be operated "without hazard to persons or property on the surface," provided that "each 

person operating the helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA." 

To provide the intended operations, the UAS is normally operated below 400 feet AGL. 

Additionally, due to the nature of the proposed operations, the UAS will maintain a lateral 

distance of at least 1 00 feet from inhabited structures, buildings, vehicles, and vessels, and from 

people not associated with the operation. 

Equivalent Level of Safety 

lntelinAir, Inc.'s multi-rotor aircraft weighs a maximum of 15 pounds, and given the lack of 

flammable fuel, any risk associated with these operations is far less than those that presently 

exist with conventional aircraft. An 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. The UAS will be 

operated in a sterile area, where buildings and people will not be exposed to operations without 

their pre-obtained consent. Because of the advance notice to the property owners and 

participants, all affected individuals will be well aware of the planned flight operations. 

Furthermore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are 

subject to the minimum safe altitude regulations. Finally, the lntelinAir SafeSmart RD-100 UAS 

and lntelinAir SafeSmart RD-200 UAS incorporate a high level of safety because both have an 

autopilot that leverages L 1 robust adaptive control license from University of Illinois, which has 

been validated by NASA and the Air Force. The DJI Phantom 3 UAS, DJI S900 UAS, DJI 

Matrice 100 UAS, 30 Robotics IRIS+ UAS, and 30 Robotics Solo UAS have a strong safety 

record as shown by the previous Section 333 Exemption approvals from the FAA. 

90 Great Oaks Blvd #202 1 San Jose, CA 9511 9 llntelinAir.com 
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D. 14 C.F .R. § 91.121: Altimeter Settings 

lntelinAir, Inc. seeks an exemption from 14 CFR 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required because the 

UAS do not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved in that lntelinAir, Inc. will confirm the altitude of the 

launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the 

GPS altitude indicator to constantly monitor the UAS's altitude, thus ensuring operation at safe 

altitudes. 

E. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions 

lntelinAir, Inc. requests an exemption from 14 CFR § 91.151 (a)'s fuel requirements forflight in 

VFR conditions. Section 91.151 states: 

(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 25 minutes; or 

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

The batteries powering lntelinAir, Inc.'s UAS's provide approximately 15-18 minutes of powered 

flight. To meet the 30 minutes reserve requirement in 14 CFR 91.151 , UAS flights could not be 

conducted. Given the limitations on the UAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a safety margin based on a reserve amount 

of battery life is needed. 

lntelinAir, Inc. will not be conducting any UAS flights at night. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be conducted on-site 

without significant transit time by the UAS. All flights will be planned to terminate with no less 

than 25% reserve battery power still available. This restriction would be more than adequate to 

return the UAS safely to its planned landing zone from anywhere in its confined area of 

operation even in the event of an unexpected occurrence. Operation of the UAS with less than 

30 minutes of reserve fuel does not include the type of risks that Section 91.151 (a) was 

intended to alleviate given the size and speed of the small UAS, and the proximity of the flight 

operation to the landing zone. Moreover, operation will be limited to controlled areas where only 

people and property owners, or official representatives who have signed waivers will be allowed. 

90 Great Oaks Blvd #202 1 San Jose, CA 9511 9 j lntelinAir.com 
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F. 14 CFR § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and {b): Maintenance 

Inspections 

lntelinAir, Inc. also seeks an exemption from the maintenance inspection requirements 

contained in 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 CFR Part 43.14 

and CFR 91.405(a) (stating that each owner or operator of an aircraft "shall have the aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections . . . 

have discrepancies repaired as prescribed in part 43 of this chapter"). An exemption to these 

regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS will not have. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because maintenance and inspections will be 

performed in accordance with lntelinAir SafeSmart R0-100 UAS, lntelinAir SafeSmart R0-200 

UAS, OJI Phantom 3 UAS, OJI S900 UAS, OJI Matrice 100 UAS, 30 Robotics IRIS+ UAS, and 

30 Robotics Solo UAS User's Manuals. The operator will ensure that the UAS is in working 

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

performed. The operator 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. 

If mechanical issues arise, the UAS's size and carrying capacity, and the fact that flight 

operations will only take place in restricted areas for limited periods of time during daylight 

hours, creates less risk than that associated with conventional rotorcraft performing the same 

operation. 

VI. PUBLIC INTEREST 

Granting lntelinAir, Inc. an exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the national airspace in controlled, safe working 

environments such as those propose in this petition. The vision of lntelinAir, Inc. is to help 

facilitate safe integration of UAS's into U.S airspace by assuring the following goals are 

accomplished: 

Training 

To ensure that UAS Operators are properly trained and certified to safely operate their particular 

type of UAS aircraft. Also, training will be conducted in the type of operations they will be using 

their aircraft. 

Research 

To help understand the flight systems of a UAS and provide research on how those systems 

can be approved and how safety can be maximized. 

Agriculture Inspections 

To aid farmers of all types by assessing crops, mapping timber stands, and providing real-time 

data that can aid in industry that require information gathering for expansive plots of land. 

90 Great Oaks Blvd #202 1 San Jose. CA 9511 9 llntelinAir.com 
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Telecommunications Infrastructure Inspection 

lntelinAir, Inc. hopes to use the latest technology to perform critical inspections at the top of 

telecommunication tower. This will make the work of maintenance crews more efficient and 

safer by providing access to a real-time view of the systems at the top of the tower. 

Wind and Turbulence Measurement 

Presently it is very difficult to measure wind and other weather variables without a tower. 

lntelinAir, Inc. intends to measure these variables from a specially designed sensor mounted to 

the UAS. 

VII. Privacy 

lntelinAir, Inc. is committed to protecting privacy. lntelinAir, Inc. knows that many individual have 

concerns about privacy from the operations of UAS 's. lntelinAir, Inc. will inform residents, 

commercial property owners, churches, schools, and governmental organizations of our intent 

to conduct commercial drone operations in proximity to their property. 

VIII. Federal Registry Summary 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

lntelinAir, Inc. seeks an exemption from the following rules: 

14 CFR 91.103; 14 CFR 91.113; 14 CFR 91.119; 14 CFR 91 .121; 14 CFR 91.151(a); 14 CFR 

91.405(a); 14 CFR 91.407(a)(1); 14 CFR; 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

Approval of this exemption request allows lntelinAir, Inc. to conduct commercial operations with 

small and lightweight unmanned aerial systems. lntelinAir, Inc. is committed safety, education, 

and solutions, which enhance safety of UAS operations while reducing risk to the general public 

and property owners. 

lntelinAir, Inc.'s UAS's, weigh less than 55 pounds and are powered by batteries. This 

eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board as compared manned aircraft. The UAS is transported to the designated mission area 

and set up there. The UAS will carry no passengers or crew and, therefore, will not expose them 

to the risks associated with manned aircraft flights. 

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of 

the exemptions requested herein, including exempting the applicant from the requirements of 

several regulations and allowing commercial operations. These lightweight UAS's operate at 

slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer 

than conventional aerial survey and inspection operations conducted with fixed wing aircraft or 

helicopters. 

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned. 

90 Great Oaks Blvd #2021 San Jose, CA 95119jlntelinAir.com 
Sincerely, 

se 

VP Product 

(408) 972-7990 

qreg@intelinair.com 

@ lntelinAir. 

90 Great Oaks Blvd #2021 San Jose, CA 951191lntelinAir.com