Petition	for	Exemption	/	COA	Request

Petitioner:																		Air-Mods	Flight	Training	Center,	Inc

106b Sharon rd.

Robbinsville, N.J. 08691

Phone: (609) 259-2400

Fax: (609) 259-1200

Email: Airmods1191@aol.com

U.S. Department of Transportation, Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 

20590

Description of Relief Sought: 

 The petitioner is seeking an exemption to commercially operate its unmanned aircraft in UAS 

compliance training for the public, aerial photography or television operations, to conduct its own 

research and to develop economic platforms for law enforcement, first responders, and search and 

rescue.

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)

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Dear Sir or Madam:

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

and 14 CFR Part 11, Air-Mods Flight Training Center, S. Lisa Campbell, 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 

sensors, would operate in the following manner:

1. 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. An awareness training syllabus will also 

be offered to the hobbyist to promote general public safety, responsibility, and privacy.

2. 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.

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

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

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

events, cinematography and news gathering.

5. Aerial inspection/photography of residential/commercial utility infrastructure including but 

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

.

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.”

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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

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)

Air-Mods Flight Training Center will operate the following aircrafts:

Hubsan X4 micro drone as an initial trainer craft. The Hubsan X4 is 8cm x 8cm. Under still air 

the maximum speed is not more than 10 m/s or 22mph. The Hubsan X4 has r coreless motors, 

powered by 3.7 V 380 mAh Li-Po battery

The DJI Phantom 2 for further training and operations. The Phantom 2 dimentions are 29cm x 

29cm weighing 1000g. Under still air the maximum sir speed is 10m/s or 22.5 mph. DJI 

Phantom 2 has 4 motors powered by 11.1 V, 5200 mAh3 S Li-Po battery.

The DJI Inspire 1 model T600 for further training and operations. The DJI Inspire 1 dimensions 

are 438mm x 451mm x 301mm and has a weight of 2935g. Under still air the maximum speed 

is no more than 22 m/s or 49 mph with a cruising speed of 11 m/s or 25 mph. The Inspire 1 has 

4 motors, model DJI 3510, powered by a 6 cell 4500 mAh or 5700 mAh Li-Po battery. There are 

4 propellers, model DJI 1345, in use.

Remote controls will use an operating frequency of 2.400 GHz – 2.483 GHz. Any live video 

feed will have an operating frequency of 5.728 GHz – 5.850 GHz.

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AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

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

operations will further enhance the safety of the persons and/or property using conventional 

aircraft.

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

commercial operations under the FAA issued exemption include:

1. The UAS will weigh less than 55 lbs.

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

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

Observer (VO). The applicant will operate the UAS in line of sight within a closed off and 

predetermined area owned and/operated by the property representative.

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

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

5. 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.

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) 

and may include but not limited to a Camera Operator.

7. The UAS pilot will be a designated Pilot in Command (PIC) will hold a Commercial Pilot’s 

License along with a Second or higher Class Medical Certificate. If the PIC feels another 

operator to be qualified with the necessary skills to be PIC & possess a Commercial Pilot’s 

License along with a Second or higher Class Medical Certificate, that person may be designated 

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

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

flight consisting of all the days’ production activities.

9. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

10. 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. Airport common traffic frequency or control tower frequency will be monitored 

during operations.

11. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) no more 

than 72 hours but no less than 48 hours from planned operation.

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12. The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 30 feet of the flight 

operation. With the advanced permission of the FSDO, operations at closer range may be 

approved.

13. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated.

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

15. Written and/or verbal permission and permits as appropriate will be obtained from 

territorial, state, county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies.

16. If the UAS loses communications with the remote controller or loses GPS signal, the UAS 

will have the capability to return to a pre-determined location within a designated location and 

land autonomously.

17. 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. The FAA will have 

advance notice of all operations. These safety enhancements provide a greater degree of safety 

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

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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 

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. Air-Mods Flight Training Center, S. Lisa Campbell, 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 

Commercial Pilot’s License along with a current Second Class or higher Medical exceeding the 

current safety levels in relation to 14 CFR 61.113 (a) & (b). I feel the operation and limitations 

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 

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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.

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 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.

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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 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 30 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 30 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: Except as provided in § 91.715, no person may 

operate a civil aircraft unless it has within it the following:

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(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 

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. The operator will ensure 

that the UAS is in working order prior to initiating flight and perform required maintenance as 

needed.

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Additional Information

The applicant, Air-Mods Flight Training Center / S. Lisa Campbell, has been involved in the 

flight training business over 7 years. Mrs. Campbell is also the current Vice Chairman of the 

Board of “The Flight School Association of North America (FSANA). Her true desire is to 

educate the public as to the safe, responsible and respectful practices involved in the operation 

of UAS.

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.

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, professional and private user education, 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.

Sincerely,

S. Lisa Campbell

Air-Mods FTC

FSANA Board

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