Cumulus Aviation LLC

FAA 333 Exemption Petition

November 12, 2015 

U.S. Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Cumulus Aviation LLC Petition for FAA Section 333 Exemption: 

Pursuant to the FAA Modernization and Reform Act of 2012, Cumulus Aviation LLC hereby submits a 

Section 333 exemption petition, in accordance with Section 333 of the Reform Act. Cumulus Aviation 

LLC is requesting to commercially operate it's small unmanned aircraft systems (UAS) which are 

currently regulated by the Federal Aviation Administration. 

Purposed Operations: 

Cumulus Aviation LLC desires to utilize unmanned aircraft systems (UAS) to accomplish aerial data 

collection, aerial photography, and closed-set filming. Operations will include aerial surveying and

mapping, remote sensing, agricultural support, real estate photography, aerial film making and 

photography, photography for marketing and advertising, special events photography, building 

inspections, construction site documentation and inspections, wildlife monitoring , forestry 

monitoring, and educational and research operations. 

Operator's contact Information:

Rob Jahnke

Cumulus Aviation LLC 

3554 Riviera Rd

Sartell, MN 56377

List of specific applicable sections of 14 CFR for which exemption is sought: 

14 CFR 21, Subpart H -Airworthiness Certificates 

14 CFR 61.113(a) and (b), Certification: Pilots, Flight Instructors, and Ground Instructors 

14 CFR 91.7 (a), Airworthiness required for operation 

14 CFR 91.103 (b) (2), Preflight action 

14 CFR 91.105, Flight crew members at stations 

14 CFR 91.109, Flight instruction 

14 CFR 91.119 (c), Minimum safe altitudes 

14 CFR 91.121, Altimeter settings 

14 CFR 91.151, Fuel requirements for flights in VFR conditions 

14 CFR 91.405 (a), Maintenance required 

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14 CFR 91.407 (a) (1), Operation after maintenance 

14 CFR 91.409 (a) (2), Inspections 

14 CFR 91.417 (a) and (b), Maintenance records

UAS craft used for operations under this petition may include:

Yuneec Q500 4K, Yuneec Q500+, Yuneec H920, Blade Chroma, DJI Phantom 2, DJI Phantom 3 Pro, DJI 

Inspire, DJI Spreading Wings S900, DJI Spreading Wings S1000, Flamewheel F550 (CA), Turnigy QuadCopter Kit (CA), RcExplorer Tricopter V2.5 (CA), Cumulus Multirotor CM-1 (CA), Cumulus Fixed Wing 

CM-2 (CA), Cumulus VTOL CM-3 (CA), Skywalker X8 (CA), Skywalker X7 (CA), FT Versa Wing (CA), FT 

Blunt Nose Versa Wing (CA), FT Explorer – Fixed wing (CA), FT Explorer – VTOL (CA), Radian – Electric

Sailplane (CA), Radian Pro – Electric Sailplane (CA), Durafly SkyMule (CA), Ritewing Zepher (CA).

* (CA) indicates the craft has been built and/or modified by Cumulus Aviation.

All of these UAS craft weigh less than 55 lbs including payload, and have operating speeds less than 87 

knots (100 mph). Typical operating parameters for these craft are weights less than 5 lb including 

payload and speeds less than 35 knots (40 mph).

Safety:

The equivalent level of safety will be maintained by following FAA operating guidelines for UAS. 

Specifically, flights will be conducted below an altitude of 400 feet with craft that weigh less than 55 

lbs with payload and at speeds below 87 knots (100 mph). All flights will be visual line of sight (VLOS) 

and utilize a visual observer (VO). All craft will remain clear and give way to all manned aviation 

operations and activities at all times. All craft that have undergone maintenance or alterations will be 

flight tested in a safe environment before being returned to service. Each craft will be maintained and 

inspected to ensure that it is in a condition for safe operation. A pre-flight inspection will be 

conducted before each operation. All pilots in command (PIC) of the craft will hold at least a sport pilot 

certificate or above with an appropriate medical certificate or drivers license and a current flight 

review for the certificate held.

Public Interest:

UAS are superior to manned helicopters or airplanes for the proposed operations due to the smaller 

size and weight, lower speeds, lower equipment and personnel cost, reduced noise and much smaller 

environmental impact, all of which promote public safety. The UAS are smaller, lighter and more 

maneuverable than larger aircraft, they operate at lower altitudes with no people on board and will 

thereby reduce risk levels and enhance safety, diminishing the likelihood of death or serious bodily 

injury to crew and people on the ground as well as limiting risk of damage to property on the ground. 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying

no passengers or crew or flammable fuel, creates a much greater margin of safety for the public. The 

enhanced safety achieved using an unmanned aircraft (UA) with the UAS described by the petitioner is 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

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Summary:

Cumulus Aviation LLC seeks an FAA Section 333 exemption from the requirements of 14 CFR 21, 

Subpart H, 14 CFR 61.113(a) and (b), 14 CFR 91.7 (a), 14 CFR 91.103 (b) (2), 14 CFR 91.105, 14 CFR 

91.109,14 CFR 91 .119 (c), 14 CFR 91.121, 14 CFR 91.151, 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 

CFR 91.409 (a) (2), and 14 CFR 91.417 (a) and (b).

The exemption will allow Cumulus Aviation LLC to commercially operate Unmanned Aerial Systems 

(UAS) to accomplish aerial data collection, aerial photography, and closed-set filming.

Sincerely,

Rob Jahnke

Owner/Operator

Cumulus Aviation LLC

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