REINVENTING AVIATION

CANADA.&USA.&EUROPE.

LATIN&AMERICA.&ASIA.

1&855&ING&UAVS

www.ingrobotic.com&

CANADA&@ CORPORATE

Unit 112, 1455 Youville Dr., Ottawa, ON, Canada, K1C 6Z7

Tel:&1&855&464&8287

07 July 2015

Attn: 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 

20590

RE: ING ROBOTIC AVIATION

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF RESPONDER

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

SUMMARY

ING Robotic Aviation, a Canadian UAV Company located in Ottawa ON, Canada seeks 

exemption from the requirements of 14 C.F.R sections 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System (ING Robotic Aviation owned Responder Robotic Aircraft) pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit ING Robotic Aviation to operate or sell its Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography (collecting aerial sensor data)

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

ING Robotic Aviation has for over 10+ years provided their clients (which include private sector 

businesses and non-profits, along with provincial and federal agencies) with expertise and 

knowledge in delivering data-driven aerial sensing solutions in harsh conditions globally. ING 

Robotic Aviation sells services and products that deliver airborne sensing solutions and much 

more. We have flown the equivalent of 81 times around the planet. We have the right solution 

for our customers in mapping, inspections, and monitoring. We are focused on getting them the 

right information, in the right hands, at the right time. The objective of ING Robotic Aviation and 

our Unmanned Aircraft System (ING Robotic Aviation owned Responder Robotic Aircraft) aerial 

operations is to provide a more affordable, high-quality aerial remote sensor collection and 

analysis system for a variety of governmental, commercial, and public uses specifically 

targeting:

• Mapping

• Land management / surveying

• Oil & Gas 

• Utilities

• Forestry

• Mining

• Precision Agriculture 

• Construction
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• Defence & Public Safety

ING’s flight operations teams are fully qualified operators that understand all the rules and 

regulations concerning the flight of Robotic Aircraft such as Responder.

BACKGROUND

Unmanned Aircraft Systems: Responder, UAS

ING Robotic Aviation seeks an exemption to operate or sell its Responder Robotic Aircraft 

system for compensation or hire within the NAS. The Responder Robotic Aircraft is a vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing a laptop system. The Responder specifications and limitations are listed in the tables 

below. The Responder Robotic Aircraft is equipped with one main rotor; driven by a Lithium 

Polymer battery powered electric motor. 

RESPONDER UAS SPECIFICATIONS

Overall Length (With Canopy) 1245mm (49 inch)

Main Rotor Diameter 1610mm (63 inch)

Main Rotor Blades 710mm (28 inch)

Overall Height (With Canopy) 534mm (21 inch)

Overall Width 406mm (16 inch)

Tail Blade Length 120mm (5 inch)

Tail Rotor Diameter 317.5mm (12.5 inch)

Maximum Payload Up to 3Kg (6.61 lbs.)

Responder Weight (with EO/IR Payload)

8.8 kg (19.5 lbs.)

Carrying Case Dimensions (Exterior) 144.9 x 47.9 x 100.6 cm

57 x 19 x 40 inch

Carrying Case Weight (without Eqpt) 44.54 Kg (98 lbs.)

Gimbal Performance 2 x axis stabilized Gimbal (roll and pitch 

axis)

RESPONDER UAS LIMITATIONS

Maximum Take-Off Weight (MTOW) 10 Kg (22.04 lbs.)
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Maximum Wind Condition 28 Km/Hr. (15 knots) 17.4 mile/Hr.

Ceiling 3000M (1.86 Miles) ASL 

Outside Operating Limits -20 to +50 Degree Celsius

(14 to 122 Fahrenheit)

Weather No Precipitations

Endurance Cruise Operational: 40 Minutes*

Hover Operational: 30 Minutes*

Additional Reserve for Safety and Battery 

Longevity: 5 Minutes*

Flight Performance (can be effected by 

mechanical performance)

• Hovering Accuracy:

- Vertical +/- 1.0m (3.2 ft.)

- Horizontal +/- 2m (6.56 ft.)

• Max Speed: +/- 72 Km/h (44.75 

Miles/Hr.)

• Cruise Speed: 50 Km/h (31 

Miles/Hr.)

• Left / Right Speed: +/- 56.7 Km/h 

(35 Miles/Hr.)

Radio Line of Sight (From Operator) 10 Km2 (6.25 Miles)

Takeoff & Landing Suitable Area – Preferably 100m x 100m 

(328 ft. x 328 ft.) wide 

*ENDURANCE TIMES ARE VALID WITH THE 1.2 KG NIKON D800 IN THE 

GIMBAL.

PERFORMANCE AND RANGE MAY BE AFFECTED BY ENVIRONMENTAL 

AND OPERATIONAL CONDITIONS. 

OPERATORS ARE ADVISED TO ADJUST THEIR PERFORMANCE 

EXPECTATIONS ACCORDINGLY IN ORDER TO MAINTAIN SAFE 

OPERATION AND PERFORMANCE OF THE AIRCRAFT.
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Figure 1: Responder Ground Control Station

Figure 2: Responder Robotic Aircraft
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BASIS FOR PETITION

The petitioner, ING Robotic Aviation, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the Responder Robotic Aircraft, UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, ING Robotic Aviation’s operation of his Responder Robotic 

Aircraft meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, ING Robotic Aviation requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

ING Robotic Aviation submits that the requested relief is proper since an equivalent level of 

safety will be ensured. ING Robotic Aviation will use experienced (or well trained personnel for 

customers that would purchase Responder) or technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS using the methods, techniques, and practices prescribed 

in the operating documents (i.e., Maintenance Schedule, Maintenance Log, and as per the

Responder Operator Handbook). Furthermore, ING Robotic Aviation will document and maintain

all maintenance records for the Responder Robotic Aircraft. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by ING Robotic Aviation to the extent necessary 

to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the Responder Robotic Aircraft in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

ING Robotic Aviation seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the Responder Robotic Aircraft do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, ING Robotic Aviation submits that they 

will ensure that the Responder Robotic Aircraft is in an airworthy condition, prior to every flight, 

by determining that the UAS are in compliance with the operating documents (i.e., Maintenance

Schedule, Maintenance Log, and as per the Responder Operator Handbook), and that the 

aircraft are in a condition for safe flight. 

ING Robotic Aviation also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the Responder Robotic Aircraft will not have a typical barometric altimeter 

onboard. However, altitude information of the Responder Robotic Aircraft will be provided to the 

PIC via Global Positioning System (GPS) equipment and radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with ING Robotic Aviation’s operation of the Responder Robotic 
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Aircraft within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, ING Robotic Aviation seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. ING Robotic Aviation submits 

that safety will not be affected by operation of the Responder Robotic Aircraft during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 40 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, ING Robotic Aviation provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

Ian Glenn

President 

ING ROBOTIC AVIATION

Unit 112, 1455 Youville Drive

Ottawa, ON 

K1C 6Z7

Canada

Mobile: (613) 265-3960 

Fax: -951-653-3201

ian.glenn@ingrobotic.com

B. The Specific Sections Of 14 C.F.R. From Which ING Robotic Aviation Seeks 

Exemption. 

1. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC 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. 

2. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 
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(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that 

for at least 20 minutes. 

5. ING Robotic Aviation Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft:

(a) 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 [.] 

6. ING Robotic Aviation Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter [.] 

7. ING Robotic Aviation Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 
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8. ING Robotic Aviation Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), states the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(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. 
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C. The Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic 

Aviation Seeks The Relief. 

1. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation

Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC 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. 

As set forth more fully below, ING Robotic Aviation submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the Responder Robotic Aircraft unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate either the Responder Robotic Aircraft in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures.

Further, ING Robotic Aviation submits that all flights of the Responder Robotic Aircraft, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to ING Robotic 

Aviation’s business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow ING Robotic Aviation to determine that the Responder Robotic Aircraft is in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., ING Robotic Aviation Aerial Operations Manual, Maintenance

Schedule, Maintenance Log, and as per the Responder Operator Handbook). 

ING Robotic Aviation seeks the requested relief because the Responder Robotic Aircraft do not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

ING Robotic Aviation will ensure that the Responder Robotic Aircraft is in airworthy condition 

based upon its compliance with the operating documents (i.e., Maintenance Schedule, 

Maintenance Log, and as per the Responder Operator Handbook) prior to every flight, and 

further, determine that the aircraft is in condition for safe flight, as stated in the conditions and 

limitations below.
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3. Extent Of Relief ING Robotic Aviation Seeks Seeks And The Reason ING Robotic 

Aviation Seeks Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations 

of the Responder Robotic Aircraft, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information from the UA to 

the PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), ING Robotic Aviation Seeks the requested relief because the Responder Robotic 

Aircraft’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the Responder 

Robotic Aircraft is equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation

Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered Responder Robotic 

Aircraft during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 40 minutes. ING Robotic Aviation seeks the requested relief 

because without an exemption from Section 91.151(b), the flight time duration of the battery 

powered Responder Robotic Aircraft will severely constrain the practicality of any aerial video or 

still photo flight operations that ING Robotic Aviation proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the Responder Robotic Aircraft, 

the Responder Robotic Aircraft operating documents, and ING Robotic Aviation’s proposed 

operating limitations, ensure that ING Robotic Aviation will safely operate the battery powered 

Responder Robotic Aircraft during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 40

minutes.

5. Extent Of Relief ING Robotic Aviation Seeks And The Reason ING Robotic Aviation

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & 

(b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, ING Robotic Aviation requests relief from these 

Sections because the Responder Robotic Aircraft do not require airworthiness certificates. As 

set forth more fully below, Responder Robotic Aircraft meet the conditions of FMRA Section 333 

for operation without an airworthiness certificate. Accordingly, ING Robotic Aviation will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., 
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ING Robotic Aviation Aerial Operations Manual, Maintenance Schedule, Maintenance Log, and

as per the Responder Operator Handbook). Furthermore, ING Robotic Aviation will document 

and maintain all maintenance records for the Responder Robotic Aircraft. 

D. The Reasons Why Granting ING Robotic Aviation Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing ING Robotic Aviation to 

safely, efficiently, and economically perform aerial video and photography for Mapping, Land 

management / surveying, Oil & Gas, Utilities, Forestry, Mining, Precision Agriculture and for 

Defence & Public Safety over certain areas of the United States. 

Additionally, use of the Responder Robotic Aircraft will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of ING Robotic 

Aviation’s proposed operation of the Responder Robotic Aircraft will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The Responder Robotic Aircraft is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of a Responder Robotic Aircraft would reduce the amount of manned aircraft in 

the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the 

air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The Responder 

Robotic Aircraft do not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft that 

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of Responder Robotic Aircraft. 

Conducting aerial acquisitions with the Responder Robotic Aircraft, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial video and still photography flight operations. By using battery 

power and electric motor, the Responder Robotic Aircraft produce no air pollution, and is the 

most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while 

burning approximately 20-30 gallons per hour of leaded aviation fuel. The Responder Robotic 

Aircraft, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, 

as the UAS is propelled by a battery powered electric motor, rather than an internal combustion 

engine. 

By using the Responder Robotic Aircraft to perform aerial acquisitions, the substantial risk to life 

and property in the air and on the ground, which is usually associated with traditional manned 

aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the 
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lack of flight crew members located onboard the aircraft, the Responder Robotic Aircraft

(weighing approximately 19.5 pounds at its maximum gross weight with diagonal dimension of 

63 inches, and with no fuel on board), has less physical potential for collateral damage to life 

and property on the ground, and in the air, compared to the manned aircraft that typically 

conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The Responder Robotic

Aircraft Will Benefit The Economy. 

In addition to being safe and efficient, the Responder Robotic Aircraft is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of 

the Responder Robotic Aircraft will allow United States based companies, to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology 

in order to remain competitive. Operating the battery powered Responder Robotic Aircraft is one 

such technology that not only allows companies greater operational flexibility compared to 

manned aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the Responder Robotic Aircraft, companies can remain competitive and profitable, 

and therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the Responder Robotic Aircraft, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in the 

United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

ING Robotic Aviation’s proposed operation of the Responder Robotic Aircraft will not implicate 

any privacy issues. Specifically, the Responder Robotic Aircraft will be operated only in 

compliance with operating documents (i.e., ING Robotic Aviation Aerial Operations Manual, 

Maintenance Schedule, Maintenance Log, and as per the Responder Operator Handbook) 

which requires property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude requirements 

of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which ING Robotic Aviation Seeks Exemption. 

1. Reasons Why The Responder Robotic Aircraft Meet The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, ING Robotic Aviation’s operation of the Responder Robotic 
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Aircraft meet the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states 

the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required 

for the operation of unmanned aircraft systems identified under paragraph 

(1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system. 

In seeking this exemption, ING Robotic Aviation submits that the Responder Robotic Aircraft

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the Responder Robotic Aircraft; (b) the pilot certification requirement; and (c) 

the specific operating limitations. 

a. The Specifications Of The Responder Robotic Aircraft Demonstrate Its Safe 

Characteristics.

The Responder Robotic Aircraft does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The Responder Robotic Aircraft. 

The technical specifications of the Responder Robotic Aircraft is set forth by the Responder 

Robotic Aircraft Operator Handbook, attached hereto as Appendix B.

ii. The Responder Robotic Aircraft Global Positioning Modes Enable The UAS To 

Remain Within A Defined Operational Area. 

The Responder Robotic Aircraft may be operated in both manual and global positioning flight 

modes. A complete description of the flight and navigational modes of the Responder Robotic 

Aircraft is provided at pages 147 through 154 in the Responder Robotic Aircraft Operator 

Handbook attached hereto as Appendix B.
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iii. The Responder Robotic Aircraft is Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the Responder Robotic Aircraft will remain stationary, in flight, for 

3 seconds or more. If, after 3 seconds, the Responder Robotic Aircraft does not reacquire 

control link data from the GCS, the UAS will assume that the Control Link is lost and the will 

return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position 

and shutdown. 

A complete description of the Failsafe Functions of the Responder Robotic Aircraft are set forth 

at pages 48 through 59 of the Responder Robotic Aircraft Operator Handbook, attached hereto 

as Appendix B.

iv. The Responder Robotic Aircraft GCS And Its Operation.

A complete description of the operation and specifications of the Responder Robotic Aircraft

GCS and flight control software is provided at pages 90 through 146 of the Responder Robotic 

Aircraft Operator Handbook. The Responder Robotic Aircraft User Manual is attached hereto 

as Appendix B.

b. Flight Operations Of Responder Robotic Aircraft Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

ING Robotic Aviation staff (or qualified customer’s operator Trained by certified ING Robotic 

Aviation’s Instructor) will be the only persons to act as a pilot in command (PIC) of the 

Responder Robotic Aircraft. Additionally, a safety observer will assist him at all times during 

flight time. 

c. Flights Of Responder Robotic Aircraft Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, ING Robotic Aviation proposes to commercially operate the 

Responder Robotic Aircraft for the special purpose of conducting aerial video and photography 

over certain areas of United States, pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: Responder Robotic Aircraft. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography. 

 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by ATC. All altitudes reported to ATC 

must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other 
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than corrective lenses, as specified on the PIC’s FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. It 

is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to the grant 

of exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft is prohibited from operating until the necessary maintenance 

has been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station must be included in the preflight inspection. All maintenance 

and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 
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13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in 

the aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the exemption. 

However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 

C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions (VMC). 

If flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

21. The UA may 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. 
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22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential 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 must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of operating 
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closer to those objects and determined that it does not present an undue 

hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 

must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety.

ING Robotic Aviation submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Responder 

Robotic Aircraft unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the Responder Robotic Aircraft in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering ING Robotic Aviation’s proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those 

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the Responder Robotic Aircraft, ING Robotic Aviation submits that 

the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for ING Robotic Aviation’s specific proposed flight 

operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11158, 11159, 11160, 11161). 

ING Robotic Aviation will not allow any PIC to operate the Responder Robotic Aircraft unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the Responder 

Robotic Aircraft training and currency requirements, that the PIC is able to safely operate the 

Responder Robotic Aircraft in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS to be used for operations 
ING Robotic Aviation Inc. Request for Exemption Page 19 of 28

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under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during ING Robotic Aviation’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; 

i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and 

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to 

the hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. 

The FAA also finds that prior documented flight experience that was obtained in 

compliance with applicable regulations would satisfy this requirement. Training, 

proficiency, and experience-building flights can also be conducted under the grant of 

exemption to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. Accordingly, ING Robotic Aviation will ensure safe 

operations by not allowing any PIC to operate the Responder Robotic Aircraft unless that 

PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that 

the PIC is able to safely operate the Responder Robotic Aircraft in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, ING Robotic Aviation will ensure that the Responder Robotic Aircraft is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 
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4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of Responder Robotic Aircraft will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path and altitude. This altitude information, combined with 

ING Robotic Aviation’s operation of the Responder Robotic Aircraft within visual line of sight, at 

or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the Responder Robotic 

Aircraft; (2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, ING Robotic Aviation will ensure that it will safely operate the 

battery powered Responder Robotic Aircraft during daylight hours in VFR conditions, with 

enough battery power to fly for a total duration of 40 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the Responder Robotic Aircraft; 

the limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the Responder Robotic Aircraft provide audible and 

visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first 

warning occurring at approximately 33% remaining battery power, and again at approximately 

10% remaining battery power. At the critically low battery level, the Responder Robotic Aircraft

will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of 

the UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 
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In seeking this exemption, ING Robotic Aviation submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because ING 

Robotic Aviation will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., ING Robotic Aviation Aerial Operations Manual, Maintenance

Schedule, Maintenance Log, and as per the Responder Operator Handbook). Furthermore, ING 

Robotic Aviation will document and maintain all maintenance records for the Responder Robotic 

Aircraft. 

Since the Responder Robotic Aircraft will be inspected as prescribed by the operating 

documents, ING Robotic Aviation will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the Responder Robotic Aircraft

Operator Handbook is attached hereto as Appendix B; a copy of the Responder Robotic Aircraft

Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because ING Robotic Aviation

will use trained technicians to perform maintenance, alterations or preventive maintenance on 

the UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the Responder Robotic 

Aircraft will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the schedule maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of ING Robotic Aviation’s proposed operating limitations, the operating 

documents, and the technical aspects of the Responder Robotic Aircraft, ING Robotic Aviation

submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 C.F.R. § 21.16 entitled Special Conditions, ING Robotic Aviation requests that the FAA 

prescribe special conditions for the intended operation of the Responder Robotic Aircraft, which 

contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited 

purpose of conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to 
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national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the 

safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the Responder Robotic Aircraft, since the airworthiness regulations of 

14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or 

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for ING Robotic Aviation’s intended operation of the Responder 

Robotic Aircraft, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which ING Robotic Aviation Seeks Exemption: 

ING Robotic Aviation seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption ING Robotic Aviation Seeks: 

This exemption will permit ING Robotic Aviation to commercially sell or operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support ING Robotic 

Aviation’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, ING Robotic Aviation’s request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 
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As discussed in detail above, ING Robotic Aviation will operate the Responder Robotic Aircraft

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise 

pose a threat to national security. 

CONCLUSION

As set forth herein, ING Robotic Aviation seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the Responder Robotic Aircraft commercially, without an airworthiness certificate, 

for the limited purpose of conducting aerial video and photography over certain areas of the 

United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing ING Robotic Aviation to safely, efficiently, and economically operate 

the Responder Robotic Aircraft commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, ING Robotic Aviation respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit ING Robotic Aviation to operate the Responder Robotic Aircraft

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States.

Dated: July 06, 2015

Respectfully submitted,

Ian Glenn

President 

ING ROBOTIC AVIATION

Unit 112, 1455 Youville Drive

Ottawa, ON 

K1C 6Z7

Canada

Mobile: (613) 265-3960 

Fax: -951-653-3201

ian.glenn@ingrobotic.com
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Appendix A – Glossary of Abbreviations

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
ING Robotic Aviation Inc. Request for Exemption Page 25 of 28

REINVENTING AVIATION

Appendix B – Link to the Responder Robotic Aircraft Operator Handbook: Click 

on the link below.

https://drive.google.com/drive/folders/0Bx1wELzc9uFIfjExZTJ3RkM3Nk1tWW9ueHJvdE

JoeGxuUVZqa0JzdUxmRklkUlRfam5UX0U
ING Robotic Aviation Inc. Request for Exemption Page 26 of 28

REINVENTING AVIATION

Appendix C – Link to the Responder Robotic Aircraft Logbook: Click on the link 

below.

https://drive.google.com/drive/folders/0Bx1wELzc9uFIfmI5RTFqUDZmZThyeURyelBDe

XVFeS1XNm1TR0d3anFFRDFLbVJ3OWRPbDg
ING Robotic Aviation Inc. Request for Exemption Page 27 of 28

REINVENTING AVIATION

Appendix D – Responder Aircraft Maintenance Log

Form: 

Aircraft Maintenance Log

Rev: 1.1

THIS PAGE IS INTENTIONNALY LEFT BLANK
ING Robotic Aviation Inc. Request for Exemption Page 28 of 28

REINVENTING AVIATION

REFERENCE: RESPONDER OPERATOR HANDBOOK

Top Level Assembly

(i.e.: Responder, GCS, GSE Etc...)

Enter Product Type

 

Module/Component Level

Discrepant Module or 

Component:

 

 

Reported By:

 

Print Name Date

Discrepancy

Corrective Action

Module or Component Replaced:

P/N Off: S/N Off: 

P/N On: S/N On: 

Repair Statement: IAW

Corrected 

By:

 

Print Name Signature Date

Functional Checks Required? Yes No

(If yes, section below shall be completed in order to close Form)

Functional Checks Completed 

Completed 

By:

 

 

Print Name Signature Date