U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140 

Washington, DC 20590 

June 12, 2015

Petitioner: 

Oklahoma Aviation, LLC

Shohaib Sumar, CEO

7200 NW 63rd Street, Suite 121

Bethany, OK 73008-5002

Tel.: 405.787.4568

Fax: 405.787.4569

Email: sk@okav.co

Website: www.okav.co

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 11.81, 

Oklahoma Aviation, LLC, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to 

allow commercial operation of its small, unmanned aircraft for photography, videography, advertising, inspection, 

and analyses. All operations will be conducted within and under the conditions and limitations outlined previously 

by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

2. Relief sought: 

a. Oklahoma Aviation, LLC wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial 

purposes to include (but not be limited to) photography, videography, advertising, inspection, and analyses. 
b. This relief is sought because commercial use of sUAS is currently prohibited by law unless performed 

under an exemption. 

c. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds 

including payload and energy sources: 

i. DJI Inspire 1 (see www.dji.com/product/inspire-1)

ii. DJI Phantom 3 (see www.dji.com/product/phantom-3)

iii. DJI Phantom 2 Vision+ (see www.dji.com/product/phantom-2-vision-plus)

iv. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of sUAS technology to obtain imagery, information and data currently obtained by use of manned 

flight or manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure 

inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections). 

ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned 

aircraft. 

b. Oklahoma Aviation, LLC will leverage the knowledge used in our 14 C.F.R Part 135 and Part 141 

operations to instruct and advise others interested in flying UASs to do so safely and legally in the NAS.

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, 

Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer and will require 

a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log 

for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain 

verbal communication capability with each other at all times during the flight, and who will remain 

stationary on the ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the 

TSA.

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A bi-annual flight review under 14 CFR 61.56.

4. Successful completion of a UAS knowledge test in a specified form. 

5. At least 5 hours of flight experience and 3 takeoffs and landings in make and model 

being flown in the prior 90 days. Such cycles and hours may be gained during flights under 

this exemption if a safe distance is maintained from persons in accordance with 14 CFR 

91.119. 

ii. A Visual Observer as necessary.

d. All flight operations will be conducted in accordance with valid Certificates of Authorization. 

e. All flight operations will comply with the following: 

i. The manufacturers’ user manuals. 

ii. Oklahoma Aviation’s Flight Operations and Procedures Manual (FOPM) and Aircraft Flight 

Manuals (AFM) which include lost communication and other emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours. 

iv. sUAS will maintain VLOC at all times.

v. PIC and VO will maintain VLOS at all times. 
vi. Pre-flight inspections (including ground control station, if any) and safety risk assessments will 

be conducted prior to each flight. 

vii. Flight altitudes will remain below 500 feet above ground level. 

viii. Flight ground speeds will not exceed 50 knots. 

ix. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place 

within 5 nautical miles of an airport. 

x. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground 

without their prior permission. 

xi. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. 

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. Oklahoma Aviation, LLC will maintain liability insurance of at least $1,000,000 issued by a major 

aviation insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

xv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined and tested lost link 

procedures. 

Please advise us of any additional information or changes that may be required. 

Sincerely, 

Shohaib Sumar, CFI-I, MEI, ATP

CEO, Oklahoma Aviation, LLC