May 19, 2015

Exemption No. 11618

Regulatory Docket No. FAA–2015–0559

Mr. Andrew J. Wilkens

Owner

Uneek Perspective

1506 6th Avenue

P.O. Box 1126

Sterling, IL 61081

Dear Mr. Wilkens:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted March 6, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Uneek Perspective (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct aerial photography, videography, and inspection.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined 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.

Airworthiness Certification

The UAS proposed by the petitioner is a Yuneec Electric Aviation Model Q500 Typhoon.
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The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. 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 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested 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, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In 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), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Uneek Perspective is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Uneek Perspective is hereafter referred to as the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Yuneec Electric 

Aviation Model Q500 Typhoon when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft 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 permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

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

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

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

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 
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operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. 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) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator 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 must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must 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 must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. 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. 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. The operator may 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 this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 
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qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. 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 may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an 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, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

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

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must 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 any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. 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

b. 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

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 must be reported 

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

reported to the National Transportation Safety Board (NTSB) per instructions 

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

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

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

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
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Uneek Perspective

Andrew J. Wilkens

1506 6th Ave

P O Box 1126

Sterling, IL 61081

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (b); 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); 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 

CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam:

I recently started a business to provide aerial photography and video as a service to private entities, 

local businesses, tourism organizations and local government bodies. However, current regulations 

prohibit the use of UAS aircraft for commercial use. As a result, I’ve had to turn down every 

opportunity to conduct operations pursuant to further my business and leaving me indefinitely

grounded. Permitting my company to use UASs for commercial purposes would allow me to 

conduct my business, add a service to my community and local businesses, as well as allow me, 

financially, to donate my services to local law enforcement for their efforts, as needed. I’ve been 

involved in model aviation for nearly 20 years, in accordance with Advisory Circular 91-57. I’ve 

also been involved in conventional airplane flight since 1999. I’ve progressed to professional flight, 

earning an Airline Transport Pilot Certificate for Multi-Engine Land, a Commercial Pilot Certificate 

for Single Engine Land, Instrument Airplane, and a Certified Flight Instructor Certificate Instrument 

Airplane. Prior to FAASTeams being formed and my progression to a commercial airline, I 

participated as a safety counselor for the Louisville FSDO. I believe I have an extensive 

understanding of the operation of conventional aircraft, classes and special use airspace, as well as an

extensive understanding of the FAA’s stance on safety being the number one priority for every flight. 

I will apply that same safety culture to the use of UASs.

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

14 CFR Part 11, Uneek Perspective, operator of an Unmanned Aircraft System (UAS), hereby applies 

for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation 

of its UAS, 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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 
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sensors, would operate in the following manner:

 Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers.

 Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the 

safe operation of a UAS to enhance the safety of the National Airspace System (NAS) as well 

as for the protection of the persons and property.

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will 

provide safety enhancements to the already safe operations in the industry presently using 

conventional aircraft. 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.”

The name and address of the applicant is:

Uneek Perspective

Attn: Andrew J. Wilkens, Owner

Ph: 909-912-9175

Email: uneekperspective@yahoo.com

Address: 1506 6th Ave, P O Box 1126, Sterling, IL 61081

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103
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14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Uneek Perspective will operate the Yuneec Electric Aviation Model Q500 Typhoon UAS, with a 

total weight of 1700g or 4.75 lbs. The dimensions are 420mm x 420mm x 240mm or 16.54 inches x 

q6.54 inches x 9.45 inches. Under still air the maximum speed is no more than 6.7 m/s or 15 mph 

with a cruising speed of 6.7 m/s or 15 mph. The Yuneec Q500 Typhoon has the ability to hover and 

move along a vertical and horizontal plane simultaneously. The Yuneec Q500 Typhoon has four 

motors, motor model YUNM4234 KV700, powered by a 5400 mAh 3s 11.1v Lithium Polymer 

battery. There are four counter rotating propellers, propeller models YUNQ500115A and 

YUNQ50011B, in use. The Yuneec Q500 Typhoon will be controlled with a Yuneec model ST10, 

10 channel remote controller with an operating frequency of 2.400GHz – 2.483GHz. The live video 

feed will have an operating frequency of 5.728GHz – 5.850GHz. The applicant will operate the 

UAS in line of sight within a closed off and predetermined area owned and/operated by the property 

representative.

Given the small size of the UAS and the controlled environment provided the proposed operations 

will adhere to the Reform Act’s safety requirements. The approval of this application presents no 

national security issues. Regarding the level of safety surrounding the proposed operations and the 

public benefit, reduction in environmental impacts, including but not limited to reduced emissions 

and noise, the grant of the requested exemption is in the public interest. Accordingly the applicant 

requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed below are for an equivalent or higher level of safety because of 

these limitations of our operations, will further enhance the safety of the persons and/or property and 

those flying conventional manned aircraft.

These limitations and conditions to which the applicant agrees to adhere to when conducting 

commercial operations under the FAA issued exemption include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 50mph.

 A Visual Observer (VO) may be utilized when the Pilot in Command (PIC) deems necessary 
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to assist with the safe operation of the flight.

 Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO).

 Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 30 minutes of flight time, or 25% battery power reserve, whichever occurs first.

 Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) 

and not more than 200 feet above an elevated platform from which filming is planned.

 Minimum crew for each operation will consist of the UAS Pilot, and may include a Visual 

Observer (VO).

 The UAS pilot will be a designated Pilot in Command (PIC) and at least hold a satisfactory

Sport Pilot’s written exam along with a meeting and complying with the medical 

requirements for a Sport Pilot’s Certificate. If the PIC feels another operator to be qualified 

with the necessary skills to be PIC & possess the satisfactory Sport Pilot written exam, able 

to meet and comply with medical requirements of the Sport Pilot Certificate, that person may 

be designated PIC provided they have a minimum of 20 hours of flight time with the UAS.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight 

consisting of all the days’ production activities.

 All flights will occur under Day Visual Meteorological Conditions (DVMC) only.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport.

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight and other 

pertinent information. If requested by the airport manager or ATC facility, a Flight Service 

Station will be contacted for appropriate filing of a Notice to Airmen (NOTAM) of 

authorized UAS activities, location in relation to the closest published VHF Omnidirectional 

Range (VOR), radial, distance, and altitude block of the UAS activity.

 The operator will attempt to obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 50 feet of 

the flight operation, and the radius may be reduced to 20 feet based upon an equivalent level 

of safety determination, with the exception of one person standing next to the PIC for 

observation of photo/video performance, so long as the flight is not conducted over the PIC. 

With the advanced permission of the FSDO, operations at closer range of additional persons

may be approved.

 The PIC and VO will have been trained in operation of UAS and receive up-to-date 
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information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 Written and/or verbal permission and permits will be obtained from territorial, state, county 

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

agencies.

 If the UAS loses communications with the remote controller, the UAS will have the 

capability to return to a pre-determined location within a designated location and land 

autonomously.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, 

or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, 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 the Applicant, 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. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the particular 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 (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by both the operator and under the requirements and in compliance 

with local public safety requirements. These safety enhancements provide a greater degree of safety 

to the public and property owners than conventional operations conducted with airworthiness 

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria 

demonstrates that there is no credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and

inability to carry a substantial external load. 

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

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated 
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aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light-sport," "experimental," or "provisional," as applicable. 

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, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as required 

by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification of 

the UAS as “Experimental.” 

14 C.F.R. § 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or property for compensation or hire. 

Uneek Perspective may achieve an equivalent level of safety as achieved by current Regulations 

because the applicant’s UAS do not carry any pilots or passengers nor property. The risks attendant 

to the operation of UAS is far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR 61. The PIC of the UAS will have a Private Pilot Written Exam completed satisfactorily

along with a current Third Class or higher Medical exceeding the current safety levels in relation to 

14 CFR 61.113 (a) & (b). I feel the operation and limitations set forth in the FOM will equate to the 

safe operation of the UAS.

14 C.F.R. §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, should this exemption be granted, 

no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft for 

maintenance and use of safety check lists prior to each flight an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which 

an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof. 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 flight manual at the ground 

control point where the pilot flying the UAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action.
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This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under 

Normal Procedures including but not limited to reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. 

14 C.F.R. §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. UAS 

and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control 

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

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. The equivalent 

level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft 

and by the size and speed of the aircraft. 

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. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will 

never operate at higher than 400 AGL with the exception that in circumstances where the UAS is 

used to survey or photograph a structure whose height exceeds 400 feet AGL, the UAS will not be 

operated more than 200 feet above the highest point on the structure. It will however be operated in a 

restricted area with security perimeter, 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 UAS 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 participants in the 

filming activity, all affected individuals will be aware of the planned flight operations. Compared to 

flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed 

herein and the lack of flammable fuel, any risk associated with these operations is far less than those 

presently presented with conventional aircraft operating at or below 500 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 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 
8

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 

operator, pursuant to the safety check list and live flight data monitoring, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

The battery powering the UAS provides approximately 25 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 

minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or 

twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the UAS, 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 UAS flights to 10 minutes would 

greatly reduce the utility for which the exemption will be granted. Applicant believes that an 

equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of battery 

power— whichever happens first. This restriction would be more than adequate to return the UAS to 

its planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph 

(a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or 

cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, 

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 
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point where the pilot flying the UAS will have immediate access to them, to the extent they are 

applicable to the UAS. 

14 C.F.R. §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 section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant 

to the flight manual and operating handbook. An equivalent level of safety will be achieved because 

the UAS is very limited in size and will carry a small payload and operate only in restricted areas for 

a limited period of time. If mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. 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. Moreover, 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. 

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

performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, the 

operator will ensure that the UAS is in working order prior to initiating flight and perform required 

maintenance needed.

Additional Information

The applicant, Andrew J. Wilkens, has been involved in the building and piloting of remote 

controlled aircraft for nearly 20 years. Also the primary pilot, Andrew, has an in-depth 

understanding of the capabilities and safety concerns involved in using this technology as an asset to 

the community. In addition, Andrew J. Wilkens holds an Airline Transport Pilot Certificate for 

Multi-Engine Land Airplanes and Commercial Pilot Certificate for Single Engine Land, Instrument 

Airplane, is a Certified Flight Instructor for Instrument Airplane, as well as holds a first class 

medical. Satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provide more 

than adequate justification for the grant of the requested exemptions allowing the commercial 

operation of the applicant’s UAS.

Sincerely,

Andrew J. Wilkens, Owner

Uneek Perspective