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UAVRG, LLC FAA333Submittal

4/19/2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

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

Reform Act) and 14 C.F.R. Part 11, UAVRG, LLC, an woman owned small business focused on UAS applications

utilizing developing software, inspection, assessments and consulting services, UAVRG, LLC hereby applies for an

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its Small

Unmanned Aircraft Systems (“sUAS”) UAVRG, LLC UAS Platforms DJI Series, Phantom II+, Phantom 3, and Inspire

1. UAVRG, LLC will provide on-demand commercial UAS operations for public and private sectors clients including

the following applications below: • Aerial Videography & Photography/Mapping/Assessment • Agriculture Survey and Assessments • Real Estate Videography & Photography/Mapping/Assessment • Oil Spill Response & Planning Mapping/ Inspection/Assessments • Offshore Platform Inspection/Assessments • Pipeline Mapping/ Inspection/Assessments • Refinery Mapping/ Inspection/Assessments • SPCC Spill Prevention Control and Countermeasures Mapping/ Inspection/Assessments • Damage Assessment • Public Safety Mapping/ Inspection/Assessments/Search and Rescue • Wind Farm Inspections

So long as such operations are conducted within and under the conditions outlined herein or as may be

established by the FAA as required by Section 333.

As detailed in this document, the requested exemption would permit the operation of sUAS under controlled

conditions in airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would provide safety

enhancements to the already best practices safety protocols followed by UAVRG, LLC. Approval of this

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s)

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

airspace system.” Section 333(c) of the Reform Act.
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UAVRG, LLC FAA333Submittal

The name and address of the applicant is:

UAVRG, LLC

16335 Redbud Berry Lane

Cypress, TX 77433

Phone +1-832-497-1985

Justin H Adams, President/COO

Email:jadams@uavrg.com

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

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

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

I. STATUTORY 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 sUASs, 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 U.S.C. §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 sUAS may operate in the National

Airspace System (NAS) without creating a hazard to the user, the public, or a threat to national security. In

making this determination, the Secretary must consider: • The sUAS’s size, weight, speed, and operational capability; • Whether the sUAS operates within the visual line of sight of the operator • Whether the sUAS operates outside of highly populated areas and away from close proximity to airports
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UAVRG, LLC FAA333Submittal

Reform Act §333(a). If the Secretary determines that a sUAS “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).

UAVRG, LLC sUAS are multirotor vehicles, weighing 10 or fewer lbs. including payload. They operate under

normal conditions at a speed of no more than 30 knots and have the capability to hover, and move in the

vertical and horizontal plane simultaneously. The sUAS will operate only in the Pilot’s visual line of sight at all

times and will operate only within the sterile area described in Mission Planning Worksheet, attached as Exhibit

One & Four(hereinafter MissionPlanningWorksheet) Such operations will insure that the sUAS will “not create a

hazard to users of the national airspace system or the public.” Reform Act Section 333 (b).

Given the small size of the sUAS involved and the restricted and sterile environment within which they will

operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress

envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately.

Also due to the small size of the sUAS and the low altitudes and restricted areas in which the sUAS will operate,

approval of the application presents no national security issue.

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act,

as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant

public benefit, including enhanced safety, the grant of the requested exemptions is in the public interest.

Accordingly, UAVRG, LLC respectfully requests that the FAA grant the requested exemption without delay.

II. PUBLIC INTEREST

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through (c) of

the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft

systems may operate safely in the NAS before completion of the rulemaking required under Section 332 of the

Reform Act. By granting an exemption the FAA will fulfill Congress’s intent of allowing UAS to operate with

significant safety precautions in low risk environments.

The use of sUAS on a Public and Private applications can significantly reduce the risk while inspecting, surveying,

or monitoring missions. sUAS can inspect, photograph, and collect data on hard to get to areas that otherwise

would require worker inspection.

Additionally, sUAS could replace the use of helicopters and small aircraft to monitor sites. The sUAS we propose

to fly in this application are under five pounds, and carry no combustible material on board, as opposed to the

much larger conventionally powered small aircraft. Shifting to sUAS from helicopters presents a marked safety

increase for our workers and the public.

Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy used for aerial imaging and

data collection over a construction site. Our sUAS use rechargeable lithium ion batteries, as opposed to fossil

fuels burned in operation of small aircraft that are many hundreds of times heavier.
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III. EQUIVALENT LEVEL OF SAFETY

UAVRG, LLC proposes that the exemption requested herein apply to sUAS that have the characteristics and that

operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher

level of safety to operations under the current regulatory structure because the proposed operations represent

a safety enhancement to the already safe protocols followed on construction sites and imaging and surveying

operations conducted with helicopters and other conventional aircraft.

UAVRG, LLC will be bound by the following limitations when conducting its sUAS operations under an FAA issued

exemption:

1. The sUAS will be less than 10 pounds.

2. Mission Planning to be conducted prior to each Mission Tasking See Exhibit One & Four

3. Flights will be operated within visual line of sight of a pilot with a VO Visual Observer as required.

4. Maximum total flight time for each operational flight will be 20 minutes. The UAS calculates battery

reserve in real time, and will return to its ground station with at least 20% battery power reserve

should that occur prior to the 15 minute limit.

5. Flights being operated never exceeding 400 feet AGL.

6. Crew for each operation will consist of the sUAS Pilot and VO who will keep the sUAS within his

visual line of sight at all times

7. The sUAS Pilot will be minimum holder of Private Pilot Certificate with a Class 3 Medical or Issued

State Driver License.

8. The sUAS will only operate within a planned flight profile, unless conditions warrant a different path

due to changing conditions and environment.

9. All flights will be conducted within set guidelines of weather constraints.

10. All flight will be conducted 5NM outside of designed FAA Airport in AFD.

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s production

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

boundaries of the safety perimeter be present for this briefing.

12. All flights will have prior consent from property owner or designee.

13. Pilots will have been trained in operation of UASs generally and received up-to-date information on

the particular UAS.

14. 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.

15. If the sUAS loses communications or loses its GPS signal, it will have capability to enter “loiter mode”

and hover, reestablish satellite connection, and return to a pre- determined location within the

Security Perimeter and land.

IV. DESCRIPTION OF SPECIFIC REGULATIONS

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

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 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 sUAS a minimum of 100 Cycles of Landing and

Takeoff with min of 50 Flight Hours in Type of craft. Unlike a conventional aircraft that carries the pilot and
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passengers, the sUAS is remotely controlled with no living thing or cargo on board. DJI UAS Platforms are also

operated by an autopilot, which greatly reduces the danger of human error. The area of operation is controlled

and restricted, and all flights are planned and coordinated in advance as set forth in Mission Plan Worksheet.

The sUAS to be operated hereunder is less than 10 lbs. fully loaded, carries neither a pilot nor passenger, carries

no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the

Manual. Like other civil aircraft, operations under this exemption will be tightly controlled and monitored by the

operator, pursuant to the Manual’s requirements, and under the requirements and in compliance with local

public safety requirements, to provide security for the area of operation as is currently done on active

construction sites. The FAA will have advance notice of all operations.

The risks associated with the operation of the sUAS are therefore diminished from the level of risk associated

with commercial operations contemplated by Part 61 when drafted, and allowing operations of the sUAS as

requested with a Pilot who has met the minimum requirements stated in the Manual achieves the level of safety

contemplated by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 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 requirements, checking takeoff and landing distances,

and all other actions in the Preflight Checklist in the Manual. These actions will provide an equivalent level of

Safety. See Exhibit One and Four.

14 C.F. R. 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any

route or altitudes prescribed for helicopters by the FAA. This exemption is for a multirotor craft that flies

similarly to a helicopter, with vertical takeoff and vertical landing, which will typically operate at altitudes of 200

AGL, so an exemption may be needed to allow such operations. The sUAS will never operate at altitude higher

than 400 AGL and will be mission flight profile, where buildings and people will not be exposed to operations

without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location

where it is operated. No flight will be taken without the permission of the property owner or local officials.

Because of the advance notice to the property owner and any onsite personnel as outlined in the Manual, all

affected individuals will be aware of the planned flight operations. Unlike flight operations with aircraft or

rotorcraft weighing far more than the maximum 10 lbs. proposed herein, our sUAS will not carry flammable fuel.

In addition, the low-altitude operations of the sUAS will ensure separation between sUAS operations and the

operations of conventional aircraft that must comply with Section 91.119.
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14 C.F.R. 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available

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

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

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator

before flight.

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. Our sUAS is limited to

operations in sterile and controlled environments as outlined in the Manual, and has a limited range and flight

time which require an exemption from 14

CFR 91.151(a).

The battery powering the sUAS provides approximately 20 minutes of powered flight. To meet the 30 minute

reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length.

Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

UAVRG, LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See

Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)).

Operating the small sUAS, in a tightly controlled area where only people and property owners or official

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not

engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small

UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption

will be granted.

An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery reserve to

ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined by the

onboard monitoring system and the Pilot), whichever happens first. This restriction would be more than

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F,

5745, 10673, and 10808.

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 UAVRG, LLC. Maintenance will be accomplished by the operator pursuant to the flight manual and

operating handbook as referenced Exhibit Two. An equivalent level of safety will be achieved because these

small sUAS are very 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 sUAS can land immediately and will be operating from no higher
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than 400 feet AGL. As provided in the Manual and Checklist, the Pilot will ensure that the sUAS is in working

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

Moreover, the Pilot 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.

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

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14

C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7

(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409

(a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in

construction operations.

Approval of exemptions allowing commercial operations of sUAS in the public/private sector enhances safety

while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much

larger, have combustible fuel, and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 10 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 will carry no passengers or crew and, therefore, will not expose them to the risks

associated with manned aircraft flights.

The operation of small sUAS, weighing less than 10 lbs., conducted in the strict conditions outlined above, will

provide an equivalent level of safety supporting the grant of the exemptions requested herein, including

exempting the applicant from the requirements of Part 21 and allowing commercial operations. These

lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are

far safer than conventional operations conducted with turbine helicopters operating in close proximity to the

ground and people.

Privacy

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

knowledge. Images taken will be of individuals who have also consented to being filmed or otherwise have

agreed to be in the area where aerial photography will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, operating

capabilities, proximity to airports and populated areas and operation within visual line of sight and national

security – provide more than adequate justification for the grant of the requested exemptions allowing

commercial operation of applicant’s sUAS in public/private sector as defined above

Sincerely,

Justin H. Adams

President/COO
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Attachments

Note: Due to file size limitation on Regulations.gov hyperlinks have been provided below

Exhibit One-Mission Planning Worksheet

Exhibit Two – Maintenance Worksheet

Exhibit Three – UAS Flight Log

Exhibit Four – Pre Mission Planning

DJI Phantom Vision 2+V3 Spec

Phantom 2 Vision+ Pilot Training Guide v1.1

Phantom 2 Vision+ Quick Start Guide

Phantom 2 Vision + User Manual v1.8

DJI Phantom 3 Specs

DJI Inspire 1 Spec

DJI Inspire 1 Maintenance Manual V1.0

DJI Inspire 1 Quick Start Guide

DJI Inspire 1 Safety Guidelines

DJI Inspire 1 User Manual
UAVRG, LLC Mission Checklist 

Customer Name

Customer Email

Customer Phone Number 

Flight Location Address

Flight Plan Lat/Long Boundaries 

Nearest Airport 

Mission Planning Yes No NA Comments

Review Proposed Flight Area 

Review Airspace Constraints

Review if flight path is within 5NM of Airport Designated under AFD 

Review if flight path is on or inside Instrument Approach Path 

Review Sunrise Sunset Times for designated flight area

Review NOTAMS 

Review Possible Obstructions

Review UAVforecast.com Seven Day Forecast 

Review Terminal Area Forecast to Nearest Location

Review KP Index Forecast 

Assignment of designated(VO) Visual Observer 

Review Proposed Flight Plan 

Review Flight Limitations 

Review of Flight Maintenance Logs 

Preflight

Verification of All Firmware is update and test flown. 

Review Current Flight Plan 

Review Current Notams 

Review Obstructions 

Review Current WX Nearest Station 

Does Wind Exceed 20kts If Exceeds No Flight 

Does Ceiling Exceed 500' above flight plan height If Exceeds no Flight 

Does Visibility Exceed 3NM

Flight will be at least 500' from nonparticipating person vessels vehicles and structures 

UAS Preflight Inspection 

Check UAS for visual signs of damage, if damage do not fly

Ensure propellers are tightly fastened and not damaged

Check propellers are in correct positions on motors 

Ensure that motors spinn freel and are not damaged 

Flight Controller Batter Exceed 90% Charge 

Flight Controller Range Extender Exceed 90%

UAS System Battery Exceed 90%

Flight Vision System Battery exceeds 90%

Preflight Calibrations of Flight Controller 

Insert Battery into UAS 

Turn on Controller/Range Extender 

Connect Vision Device to UAS Wifi

Establish Go Home Location 

Verify Min of Eight Satellites are seen by UAS

Flight 

Announce Voice Clear Prop

Start Engines of UAS

Validate UAS Startup 

Increase Throttle to lift off 

Increase Power to apx 6'' Hover and establish X,Y,Z Movement in Controls 

Proceed Preplanned Flight 

Flight Plan Execution 

Monitor Flight Telemetry 

Return Flight to designated landing location 

Stop Engines 

Post Flight Inspection 

Inspect UAS for any abnormalities 

Downlink Data 

Remove Battery

Turn off Flight Controller/Range Extender
UAVRG, LLC Maintenance CheckList 

Customer Name 

Customer Location 

Mission Flight #

Date/Time

Checked 

Airframe

Check that all the screws on the frame, gimbal and motor mounts are still securely fastened.

Check that all the ABS parts are still intact and do not show signs of wear or fatigue, particularly the inner mounts

Check the carbon plates and tubes for wear and damage that would reduce the structural integrity of the frame.

Motors

Check that the prop holder is still secure fastened to the motor with all three screws and that the nut and tread that secures the prop is still in good condition.

Check that the motor is still securely fastened to the motor mount with all 4 screws.

Check that the motor runs smooth when turned by hand and that there is not any play in the bearings.

Check that the motors are free of dust and any other foreign particles.

Check that the motor windings do not show any damage or bubbling/melting. Also check that the motor wires are not damaged.

Check that the motor windings do not show any damage or bubbling/melting. Also check that the motor wires are not damaged.

Electronics 

Check that the battery connector is in good condition and that the soldering is still secure. Also make sure the wires are not damaged.

Check that the wires between the ESC and the motors are not damaged.

Check that all the different electronic modules are still securely fastened. Check the ESC, Gimbal Control Board, Receiver, Flight Controller, GPS/Compass, etc.

Check that all the various plugs that connect all the electronics are still securely plugged in.

Check that all the electronics are free of dust or dirt.

Check sensor readings for abnormalities. (Check in Mission Planner, Compass reading, GPS, attitude, etc. See 

Radio 

Check that the control gimbals are free from dust and other particles.

Check that the battery is still in good condition.

Perform a radio range check. (See radio manual for details)

Lipo Batteries

Check that the battery is not punctured or does not have any other physical damage. The battery should also not be swollen at all.

Check that all the cells of the battery are balanced. (Within 0.1V of each other)

Check that the battery connector is in good condition and that the soldering is still secure. Also make sure the wires are not damaged.

Signature 2 

Signature 1 
UAS Type DJI Phantom 2+ 

UAS Serial # PH646044721V3.0

Flight # Mission # Locations Date Time Pilot Observer Max Alt Max Distance Max Speed Distance Traveled Flight Duriation Maintenance Required
UAVRG, LLC Pre-Mission Planning 

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Review Propose Flight Area/NOTAM/TFR/Airspace Constrants
UAVRG, LLC Pre-Mission Planning 

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Insturment Approach VOR/DME Rwy 22 – Alt 2200AGL 
UAVRG, LLC Pre-Mission Planning 

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Sunrise/Sunset/UAVForecast

Terminal Area Forecast Nearest Station 
UAVRG, LLC Pre-Mission Planning 

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Review Flight Plan