U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

July 6, 2015

Virginia Computer Institute, Inc.

Section 333 Petition to Operate

Small Unmanned Aerial Systems

Prepared by: 

Ordaz Jeter, Owner/Petitioner

Virginia Computer Institute, Inc.

861 Concord Rd.

Chatham, VA 24531

703.408.4451

o.jeter@hotmail.com
Petitioner Summary:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 (2012), 126 

Stat. 11 ("Section 333") and the Federal Aviation Administration's ("FAA") general exemption authority 

under 49 U.S.C. section 44701 (f), Virginia Computer Institute, Inc. ("Petitioner") hereby petitions for 

exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27 (Airworthiness 

Standards: Normal Category Rotorcraft), 14 C.F.R sections 61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 

91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2}, and 91.417(a)-(b). 

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of small 

unmanned aircraft systems ("UAS") meeting or exceeding all of the operational and safety requirements 

Congress has set forth in Section 333. 

Petitioner is an Educational / Technology Innovation company that plans to exploit the capabilities of 

Unmanned Aerial Systems to offer a multitude of services, including: 

 Educational and research operations

 UAS Training

 Farming and Agriculture

 Real Estate

 Aerial photography and filmmaking

 Aerial inspection of towers and structures

 Aerial inspection of energy infrastructure

 Safety inspections and aerial surveying

 Construction site inspections and monitoring

 Marine environment monitoring 

 Wildlife and forestry monitoring

 Pipeline inspection and patrolling

 Disaster response, search and rescue

 EMS Fire emergency support

 Transportation infrastructure inspection and monitoring

Statutory Authority:

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for 

seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the 

FAA "shall determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the (comprehensive) plan and rulemaking required by section 332(b}(1) of this 

Act or the guidance required by section 334 of this Act." In Section 332(b}(1), Congress made it clear that 

Section 333 provides a mechanism for "expedited operation authorization" if several factors are met. 

Petitioner meets all requirements to permit FAA approval of commercial UAS operations.
The Petitioner Requests Relief from the Following: 

Section 61.113 (a) and (b) prescribes that –

(a) 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; nor may that person, for compensation or hire, act as pilot 

in command of an aircraft. 

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with 

any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, 

become familiar with all available information concerning that flight, to include -

(a) For 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; 

(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. 

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface. 

(b) Over congested areas. 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. 

(c) Over other than congested areas. 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. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without 

hazard to persons or property on the surface -

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section. 

Section 91.121 requires, in pertinent part, 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." 
Section 91.151 (a) prescribes that 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 30 minutes; or 

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

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as 

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the 

chapter. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and 

currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained 

until the defects are repaired and the aircraft is approved for return to service. 

Unmanned Aircraft System 

The petitioner states that the unmanned aircraft (UA) to be operated under this request is less than 55 lbs. 

fully loaded, flies at a speed of no more than 50 knots, carries neither a pilot nor passenger, carries no 

explosive materials or flammable liquid fuels, and operates exclusively within a secured area. The UAS 

devices are the DJI Phantom, Yuneec Q500 Quadcopter and the 3D Robotics 3DR Solo Quadcopter. The 

quadcopters have 4 motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground 

control. In addition, they have integrated safety features built into the design of the UAS to ensure the 

safety of persons and property within and surrounding the limited operating area. The petitioner further 

describes that, in the event the UAS loses communications or its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and land. It will also have the 

capability to abort a flight in the event of unpredicted obstacles or emergencies.

The petitioner only utilizes safe and reliable UASs. DJI, Yuneec and 3D Robotics are industry leaders in 

small UAS production. Their UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no 

higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. The 

UASs software provides real-time altitude, speed and location information. 

The UASs will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking. Petitioner's UAS will be identified by serial number, registered in accordance with 14 

C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart 

C. Markings will be as large as practicable. 
Pre-flight Inspection, Maintenance 

Before each flight the PIC will perform a series of pre-flight and takeoff checks. After each 60 minutes of 

airtime, the craft will undergo a thorough inspection of all aircraft components, including, but not limited to: 

a. Actuators I Servos 

b. Motors, wiring and connectors 

c. Propellers, smooth, no chips 

d. Electronic speed controller, wiring and connectors 

e. Batteries, wiring and connectors 

f. Remote command and control

g. Ground control station 

UAS Operating Parameters

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in daytime VFR 

flight conditions and all operations will be conducted with the assistance of a second spotter/observer. The 

UAS flights will be limited to a maximum altitude of 400 feet AGL. Altitude is accurately measured by GPS. 

The petitioner further states that an operator will ensure that only consenting production personnel will be 

allowed within 100 feet of the UA operation, and UAS will be kept at least 100' from any inhabited structure. 

Generally the petitioner's UAS will be operated in rural or suburban areas that will permit significantly larger 

safety zones. 

Flight Standards District Offices (FSDOs) will be notified as required prior to operations to describe 

intended coordination for proposed operation(s). Petitioner will obtain an Air Traffic Organization ("ATO") 

issued Certificate of Waiver or Authorization ("COA") prior to conducting any operations under this grant of 

exemption. In fulfilling its requirements under the COA, Petitioner will be required to request a NOTAM not 

more than 72 hours in advance, but not less than 48 hours prior to the operation

Petitioner's UAS will remain clear and yield the right of way to all manned operations and activities at all 

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and 

hangliders). Petitioner will not conduct UAS operations within 5 nautical miles of the geographic center of a 

non-towered airport unless a letter of agreement with that airport's management is obtained and the 

operation is conducted in accordance with a Notice to Airmen ("NOTAM").

Minimum crew for each operation will consist of the UAS PIC and a Visual Observer/Camera Operator 

when appropriate. All required permissions and permits will be obtained in advance from territorial, state, 

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

agencies. In the event of an accident involving a Virginia Computer Institute, Inc. UAS, petitioner will cease 

operations and report the accident to the NTSB and AFS-80.

Pilot in Command (PIC)

Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply with the other 

applicable procedures and requirements stated in§ 91.1 03(a) and (b). Specifically, the PIC will take all 

actions including reviewing weather, flight battery requirements, aircraft performance data, and landing and

takeoff distances before initiation of a flight. The PIC will also account for all relevant site-specific conditions 

in their preflight procedures. Risks presented by sun glare will be mitigated by the PIC's and VO's ability to 

see other air traffic and initiate a return-to-home sequence if needed. 

Radio Frequencies 

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle control in 

unlicensed frequency bands. All devices used will comply with FCC usage and emissions regulations.