Crown Consulting, Incorporated

1400 Key Blvd, Suite 1100

Arlington, VA 22209

Point of Contact:

Tim Nolan

P.O. Box 1892

Silverthorne, CO 80498

tnolan@crownci.com

315-767-3913

January 20, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE

Washington, D.C. 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

Crown Consulting, Incorporated (CCI), pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and Section 333 of the FAA Modernization and Reform Act of 2012, applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its 

small Unmanned Aircraft Systems (sUASs) in the national airspace system (NAS), so long as such 

operations are conducted within and under the conditions outlined in this petition for exemption, or as 

may be established by the FAA as required by Section 333. CCI petitions for an exemption from the 

requirements of:

• 14 CFR Part 21

• 14 CFR 45.23

• 14 CFR Part 61.113(a) and (b)

• 14 CFR Part 91:

i. 91.7 (a)

ii. 91.9 (b) (2)

iii. 91.103(b)(2)

iv. 91.105

v. 91.109

vi. 91.119

vii. 91.121viii. 91.151

ix. 91.203 (a) & (b)

x. 91.205 (b)

xi. 91.215

xii. 91.401-417

CCI is a multi-disciplined analytics, information solutions, management, and engineering services firm. 

Our principal clients are the Federal Aviation Administration (FAA), National Aeronautics and Space 

Administration (NASA), and US Department of Energy (DOE). Our work includes field engineering 

services for the FAA, focusing on designing and installing VHF and UHF radio and fiber optics (FOTS) 

networks for air traffic and airport communications.
CCI plans to use unmanned aircraft systems (UAS) for aerial inspection and documentation services 

(video and still photography) for its field engineering services projects and other engineering, 

construction, surveying, data collection, video/still photography, and search and rescue projects located

across the United States. The UAS will reduce the need to physically climb radio towers, to operate 

cranes, and to operate manned aircraft in close proximity to the ground and obstacles. UAS based 

inspections and surveys will provide more accurate data in a manner that is safer, more economical, and 

more efficient with a reduced impact on the environment. Because CCI plans to utilize the UAS in many 

of its FAA field engineering projects, the operations will also directly translate to measurable savings for 

the FAA and ultimately taxpayers.

Petitioner Information:

Crown Consulting, Incorporated

1400 Key Boulevard, Suite 1100, 

Arlington, VA 22209

Phone: 703-650-0663

Fax: 703-243-1280

Point of contact:

Tim Nolan

315-767-3913

tnolan@crownci.com

CCI’s Chief UAS Pilot is a retired USAF pilot with over 3000 hours of flight time and an air transport 

pilot license. Additional CCI UAS pilots will hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate.

Relief sought:

CCI proposes to use the following UAS:

DJI Phantom 2, 

DJI Phantom 3, and

DJI Inspire 1.

CCI will employ the UAS for the following uses:

• Inspections 

• Aerial surveys and mapping

• Obtaining still photographs, video and other data collected via onboard sensors

• Search and rescue

These particular aircraft have four rotors and four motors in a quadcopter configuration (X4). They weigh

less than 55 lbs. including payload, can fly under normal conditions at a speed of no more than 30 knots. 

They are equipped with GPS and an auto−return function to the predetermined safe landing area. We will 

operate these UAS only in line of sight. We will conduct all operations in a manner to insure that the UAS 

will “not create a hazard to users of the national airspace system or the public.” (Reform Act Section 333 

(b)).

Public benefit:

a. Use of UAS 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., physically climbing 

radio masts, crane accidents during infrastructure inspections).
ii. Reduces the cost of time obtaining such information, which benefits consumers and the 

economy.

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

aircraft.

Equivalent level of safety maintained:

CCI will maintain an equivalent or superior level of safety to current practices (both aviation practices 

and ground based practices, i.e., climbing radio masts or inspecting infrastructure using cranes) by 

following these procedures:

a. CCI will comply with maintenance and inspection requirements of the manufacturer. All repair and 

maintenance work will be conducted or approved by qualified personnel, and will require a test flight 

after such work.

b. All flight operations will be conducted by at least two individuals (PIC and visual observer(VO)) 

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. The flight crew will include a 

sensor operator when necessary. 

c. The PIC will possess the following credentials for commercial operations:

1. An Airman Certificate issued under 14 CFR 61 screened by the TSA

2. A medical certificate issued under 14 CFR 67, or a valid U.S. driver’s license.

3. Meets the flight review requirements under 14 CFR 61.56

4. Will have completed training and demonstrated competence in the operation of the UAS 

to include normal operations (take off, landing, traffic/obstacle avoidance, and mission 

operations) and contingency operations (lost link, emergency landing, 

degraded/emergency operations).

5. Will have a minimum of 1000 hours total flight time and 10 hours flight time on UAS 

type, or 50 hours total flight time and 25 hours flight time on UAS type.

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

e. All flight operations will comply with the following:

1. All guidance from the FAA, local flight safety district office, and 

2. The manufacturers’ user manuals.

3. CCI Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals 

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

4. Conducted in visual meteorological conditions.

5. The UAS will 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.

6. All flights will take place during daylight hours.

7. PIC and VO will maintain visual line of sight (VLOS) with the UAS at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability.

8. Pre-flight inspections (including ground control station, if any) for UAS airworthiness 

and safety risk assessments will be conducted prior to each flight.

9. Flight altitudes will remain below 400 feet above ground level.

10. Flight ground speeds will not exceed 50 knots.

11. Maximum flight time for each operational flight will be 50 minutes.

12. Flights will be terminated at 20% battery power reserve should that occur prior to the 50 

minute limit.

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

place within the distances specified (in the “blanket” COA) surrounding airports without 

prior permission of the cognizant authority.
14. When flying UAS within the distances specified (in the “blanket” COA) of an airport, 

shall submit a plan of activities to the local Flight Standards District Office (FSDO) at 

least 3 days before the planned flight in accordance with FAA guidelines.

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

ground without their prior permission. All Flight operations shall 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 shall 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; or

c. Flight operations closer than 500 feet from participating persons consenting to be 

involved are necessary for the filming production, as specified in the enclosed 

MPTOM.

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

17. No pilot shall be permitted to operate unless the pilot demonstrates the ability to safely 

operate the UAS in a manner consistent with the enclosed MPTOM including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. 

18. PIC qualification flight hours and currency shall be logged in a manner consistent with 14 

CFR § 61.51(b).

19. Flights for the purposes of training PICs and VOs (training, proficiency, and experiencebuilding) and determining the PIC's ability to safely operate the UAS shall only be 

conducted during dedicated training sessions. During such training, proficiency, and 

experience-building flights, all persons not essential for flight operations shall be 

considered nonparticipants, and the PIC shall operate the UA with appropriate distance 

from nonparticipants in accordance with 14 CFR § 91.119.

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

21. CCI will maintain liability insurance.

22. Any applicable local FSDO requirements.

23. 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.