The University of Texas at Arlington Research Institute

7300 Jack Newell Blvd S

Fort Worth, TX 76118

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code of Federal Regulations 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 1012 (Public Law 112-95) 

Regarding Commercial Employment of Unmanned Aircraft Systems (UAS)

To whom it may concern,

The University of Texas at Arlington hereby applies for authorization to Section 333 of Public Law 112-

95 commonly known as the “FAA Modernization and Reform Act of 2012” or “The Reform Act”, in order 

to conduct research related activities on unmanned aircraft systems (UAS) within the United States 

National Airspace System (NAS) in support of research, education, and development.

Federal Register Summary 

Pursuant to 14 CFR §11.81, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed:

The University of Texas at Arlington Research Institute seeks exemption from 14 CFR Part 21, 

Subpart H; Part 27; 45.23; 61.23 (a)(c); 61.101 (e)(4)(5); 61.113; 61.315 (a); 91.7 (a); 91.9 

(b)(2)(c); 91.103 (b)(2); 91.105; 91.109; 91.119 (c); 91.121; 91.151; 91.203 (a)(b); 91.405 (a); 

91.407 (a)(1); 91.409 (a)(2); 91.417 (a)(b) to allow employment of Unmanned Aircraft Systems 

(UAS) in support of research, education and development in areas such as unmanned systems, 

human robot interaction, transportation management, emergency response, security, 

agriculture, and manufacturing. Approval of this exemption request will enhance safety by 

reducing risk to the general public and property owners from the substantial hazards associated 

with performing equivalent work with conventional aircraft and rotorcraft. UTA’s exemption

request would permit operation of lightweight, UAS generally in Class G airspace and outside of 

five miles of an airport point of origin. Each flight will have predetermined areas of operation that 

will allow UTARI to operate with an equivalent or greater level of safety.

We look forward to your review of this request and would like to discuss any questions or concerns as 

they arise.

Sincerely,

Michael McNair 

Automation and Intelligent Systems Division Head

University of Texas at Arlington Research Institute (UTARI)

7300 Jack Newell Boulevard South, Fort Worth, TX 76118

T: 817-272-5852

mcnairmk@uta.edu
Glossary of Abbreviations

AGL Above Ground Level

FAA Federal Aviation Administration 

GPS Global Positioning System

NAS National Airspace System

NM Nautical Mile

NPRM Notice of Proposed Rulemaking 

RTH Return-to-Home

sUAS Small Unmanned Aircraft System

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Air vehicle 

UTARI The University of Texas at Arlington Research Institute 

VLOS Visual Line of Sight

VO Visual Observer
INTRODUCTION AND INTEREST OF THE PETITIONER

In recent years, the use of Unmanned Aircraft Systems (UAS) has dramatically increased due to the 

technology developments and the availability of commercial off-the-shelf products. It’s an undeniable 

fact that UAS technology benefits various applications areas, including government entities. Sample 

applications of UAS range from water conservation, oil/gas exploration, agriculture, law enforcement, 

firefighting, transportation monitoring, and entertainment, and others. As the use and number of UAS 

are increasing, safe operation solutions of such aircraft systems in the National Airspace System (NAS)

become more and more important. The University of Texas at Arlington (UTA) and the Automation and 

Intelligent Systems (AIS) Division at the University of Texas at Arlington Research Institute (UTARI) 

focus on research in navigation, safety, collaborative and swarm behavior, control methods, 

communication uncertainties, rapid conflict avoidance, automatic emergency landing, low-cost UAS 

tracking, and sense/detect/ avoid systems for UAS. Results from our research will help to develop 

knowledge and methods that increase the efficiency of UAS operations in a safe manner. UTA is 

requesting support to perform small UAS operations in the national airspace for research, education, 

and development purposes. The outcome of this research will be beneficial for government and nongovernment entities in a wide range of applications and operations that will lead to the benefit of society 

at large.

The remainder of this document details our exemption request and identifies the specific areas where 

we are requesting a waiver. For convenience, hyperlinks to the following sections are available here:

 Overview Characteristics of Proposed UA

 Qualification for Approval Under Section 333 of the Reform Act

 Specific Sections of 14CFR from which Petitioner Seeks Exemption or Relief

 Why Granting this Petition is in the Public Interest

 Summary of Regulations from which Petitioner Seeks Exemption or Relief

 Supporting and Technical Documents
OVERVIEW CHARACTERISTICS OF PROPOSED UA

UA and platform restrictions

The Unmanned Aircraft (UA) flown under this exemption will include multirotor, fixed wing, and dirigible

type Unmanned Aircraft Systems (UAS). They will be maintained and operated in compliance with FAA 

regulations, FAA Modernization and Reform Act Section 333 exemptions, and UTA requirements. 

The specific waivers and adherence to these is identified and requested in this document.

All UA used in UTA operations will:

- be limited to below 55 pounds at takeoff including airframe and all payload. Typical UTA UA are 

below 15 pounds;

- be limited in their physical size. UTA UA will generally not exceed two by two by two meter in 

dimension;

- be limited to speeds below 100 miles per hour. UTA UA are typically flown below 30 miles per 

hour;

- be battery powered and use electric motors for propulsion. UTA UA almost exclusively use 

lithium polymer batteries for their charge density and light weight as opposed to flammable 

liquid fuels;

- Have a base frame made out of sturdy materials. These will typically include some combination 

of aluminum, steel, carbon fiber, and high strength plastics such as nylon. UTA UA, in support 

of research and student competition teams, are almost exclusively aluminum and carbon fiber 

frame platforms, but also include light weight plywood and foam that may be plastic reinforced.

Required Platform Operating Documents 

All purchased UTA UAS are sold with supporting documentation to include information on operation 

and maintenance of the vehicle. These documents will help comprise the Operating Documents of the 

platform. UTA may supplement the manufacturers’ documents for ease of use for system functions of

the platform. The resulting documentation set will include the following items and features, as 

applicable:

- An operations manual. The documents must explain how to properly and safely operate the 

UAS and explain all of its features and controls;

- A maintenance Manual. The documents must explain how to perform all regular maintenance 

along with recommendations for frequency of checks and required maintenance detection;

- A safe operation checklist. This will enable UTARI staff to test that a UAS is in working order at 

any moment;

- A safe pre-flight checklist. This will enable and actively encourage users to test that the UAS is 

in working order and safe condition right before an operation in the NAS;

- How to read the altitude of the UA. This will enable The Operator to verify that the UA is under 

the 400 foot limit for UAS operations during flight;

- Reading orientation markings or lights. The Operator and any VO must keep the UA in naked 

eye sight at all times and be mindful of the orientation and heading. The documents must 

explain how to properly read the visual orientation markers or lights on the platform;

- Reading remote battery indicator. The documents must explain how to properly read the UA 

battery level from the Ground Control Station in order to end the operation at a safe battery 

level;

- Lost communication and GPS behaviors. The documents must explain the UAS’s behaviors 

when communication is lost between the UA and Ground Control Station or the UAS loses GPS 

signal.

Summary of current UAs
The following table identifies the vehicles currently owned by UTA that would initially be covered under

this exemption request. Other vehicles meeting the approved exemption may be added in the future.

Manufacturer/Model 3DR X8 Penguin 1720-Finwing Air Titan 2520-Finwing

Aircraft type Multirotor (8 rotors) Fixed Wing Fixed Wing

Aircraft Weight 5.6 lb. 2.4kg 7.0kg

Dimensions .51 x .35 x .2 meters 1720MM Wing Span 2520MM Wing Span

Flight Time (approx.) 15 minutes 30 minutes 45 minutes

Propulsion Brushless Electric 

motor

Brushless Electric 

Motor

Brushless Electric 

Motor

Power Storage 14.8 VDC LiPo battery 14.8 VDC LiPo battery 14.8 VDC LiPo battery

Airframe Material Aluminum Foam Construction Foam Construction

UTA’s 3DR X8 UA is an octa-copter that cannot exceed 10 pounds at maximum payload during takeoff 

or flight. Its estimated occupied volume is less than 0.05 m3far smaller than any traditional manned 

aircraft. The UA has a recommended flight speed of only 11 miles per hour and is powered by a lithium 

polymer battery that does not have the same level of risk as flammable fuel. The 3DR X8 has a rigid 

aluminum frame that can hold the payload securely. 

3DR has extensive documentation on the X8 platform including instructions on flight and battery safely, 

battery charging, failsafe systems, Ground Control Station setup, flight modes, takeoff and landing, 

status indicators, and maintenance. The X8 has marked front rotor arms to indicate its inflight heading 

to the Operator and VO. The X8 ground station gives location, altitude, battery level, and other 

information to the PIC. In the event of lost link or lost GPS signal the X8 can be set to use three 

different automated emergency modes including fly home and land, reach specified altitude return 

home and land, and land in place. There is a geo fencing mode available with the platform that can 

automatically limit the flight volume including a 328 foot ceiling. 
QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for approval under Section 333 of the 

Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied.

The proposed operations would permit the use of small, relatively low cost, and consumer available 

UAS under controlled conditions in limited and predetermined airspace and would provide an increased 

level of safety beyond that existing when fixed or rotor wing manned aircraft are used to accomplish the 

same purpose.

UAS operations include vehicles that are typically less than fifteen pounds and never exceed fifty five 

pounds. UA will almost exclusively operate below 30 miles per hour and never exceed 100 miles per 

hour. A trained UAS Operator will perform the operations and maintain line of sight with any VOs so 

that they do not create any harm to the public or interference with the NAS. 

These operations are limited in scope and range and will have an equivalent level of safety as 

envisioned and communicated by Congress that the FAA must allow by exception. This exemption will 

not pose any threat to national security, the NAS, or the general public. It will be a public benefit by 

increasing growth of the commercial sector, support research, education and development, and reduce 

environmental impacts in comparison to traditional aircraft. 

The following list of limitations and conditions must be followed by UTA to include its staff, faculty and 

students under UTA sponsored operations and under this FAA exemption

1. Operations authorized by this grant of exemption are limited to rotor, fixed wing, and dirigible

aircraft.

2. UA (aircraft and payload) will weigh less than 55lbs. 

3. UA will be operated at altitudes not greater than 400 feet AGL. Altitudes, when reported to ATC,

will be in feet AGL.

4. UA will be flown at ground speeds not greater than 100 miles per hour.

5. The UAS Operator will receive training from UTA on UAS flight operations, hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. 

6. In addition to holding an FAA issued airman medical certificate, the UAS Operator must 

complete a UTA UAS Training Program. This training will include:

a. A detailed review of manufacturer's operating manuals.

b. A practical demonstration of ability to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption.

c. Maintaining appropriate distances from persons, vehicles, vessels and structures.

d. Operator qualification will have a currency requirement of at least three take-offs and 

landings within the preceding 90 days 

e. How to keep maintenance and flight logs. All UTA operations and maintenance to UTA

UA will be logged in accordance to 14 CFR § 61.51. 

f. Maintaining a safe distance from related and non-related structures, vehicles, and 

people.

g. Battery monitoring and landing. 

h. Limitations and error in human perception.

i. Emergency and evasive maneuvers and giving the right of way to all other unrelated 

aircraft, vehicles, and people.

7. UA will not be operated within 5 nautical miles (NM) of an airport center of origin having an 

operational control tower, or 3 NM of an airport center of origin with a published instrument flight 

procedure but not an operational control tower, or 2 NM of an airport center of origin without a 

published instrument flight procedure or operational control tower, or 2 NM of a heliport with a 

published instrument flight procedure. Flights will only be operated in Class G airspace. If 
operation in other airspace is required, the relevant controlling agency will be notified at least 24 

hours prior to the operation and, if required, any necessary permission obtained 

8. UAS flights will operate within visibility and cloud clearance requirements equivalent to Visual 

Flight Rules (VFR). 

9. UAS operations will not be conducted during night, as defined within 14 CFR § 1.1. 

10. The UA will remain clear of and yield right of way to manned aviation operations. 

11. UA will be operated within visual line of sight (VLOS) of the Operator at all times The Operator

will use human vision unaided by device other than corrective lenses. 

12. UAS operations may employ a visual observer (VO) if the UA is to be flown at a range to which 

human perception may make discerning orientation properly difficult. The VO may be used to 

satisfy the VLOS requirement as long as the Operator maintains VLOS capability. The VO and 

Operator must be able to communicate verbally for the duration of the flight. Electronic 

messaging or texting by either the Operator or VO is not allowed during flight operations. 

13. The VO will perform no duties other than assisting the Operator see and avoid other aircraft, 

obstacles, persons or property. 

14. UAS will be equipped with an autopilot system which will be at least capable of all the functions 

described in this request. The UAS will utilize GPS navigation, failsafe’s, return-to-home (RTH) 

and flight abort safety features. 

15. Prior to each flight the Operator will inspect the UAS to ensure it is in a condition for safe flight. 

Checklists developed from manufacturer operating documents will be the basis for this 

inspection. If the inspection reveals a condition that affects safe operation of the UAS, the 

aircraft is prohibited from operating until necessary maintenance has been performed and the 

UAS is found to be in a safe condition for flight. The Ground Control Station must be included in 

the preflight inspection. 

16. All UAS operations will be conducted over open waters and sparsely populated private or public

property. Permission for flight will be sought in advance from property owners or controlling 

agency. A Ground Control Station will be connected, by radio communication, to the UAS during 

the entire flight, which will give the Operator flight information such as GPS Position, Altitude, 

Air speed, Battery Remaining, and other telemetry information. 

17. Flight boundaries will be established for each flight and such boundaries will be designed such 

that the UA will pass no closer than 500 feet from nonparticipating persons, vehicles or 

structures. 

18. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined 

location within the established flight boundary and land, land in place, or be recovered in 

accordance with manufacturer's operations documents. 

19. The Operator will abort any flight in the event of unpredicted obstacles, occurrence of adverse 

weather or loss of UAS flight control capability in accordance with manufacturer's operations 

documents. 

20. The Operator is prohibited from beginning a flight unless (considering wind and forecast 

conditions) there is enough power to fly the planned operation to the intended landing point and 

land the UAS with 25% of useable battery capacity remaining. 

21. Documents required by 14 CFR § 91.9 and 91.203 will be available to the Operator at the 

Ground Control Station of the UAS whenever the aircraft is operating These documents will be 

made available to the Administrator or any law enforcement official upon request. 

22. Before conducting flight operations, the radio frequency spectrum used for operation and control 

of the UA must comply with Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

23. A Flight Operations and Maintenance Log will be maintained for each UAS. Cumulative flight 

hours, maintenance activities, repairs, alterations and inspections will be noted. 

24. Any UAS maintenance or alterations that affect UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, must undergo a functional test flight the Operator who 

conducts the functional test flight must make an entry in the Flight Operations and Maintenance 

Log.
SPECIFIC SECTIONS OF 14CFR FROM WHICH PETITIONER SEEKS EXEMPTION 

OR RELIEF

14 CFR Part 21, Subpart H: Airworthiness Certificates

Sets forth requirements for procurement of necessary airworthiness certificates.

The FAA has stated that no exemption is needed from this section if a finding is made under Part 11 

and Section 333 of the Reform Act that the UAS selected provides an equivalent level of safety when 

compared to civil aircraft normally used for the same application. The petitioner submits that 

consideration of the size, weight, speed, and limited operating area associated with the aircraft(s) and 

their operation, an equivalent level of safety is obtained and exemption is not required (see Grant of 

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352). If however, the FAA determines that there 

are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an 

exemption is requested.

14 CFR Part 27

Airworthiness Standards: Normal Category Rotorcraft. Sets forth the procedural requirements for 

airworthiness certification of normal category rotorcraft.

To the extent petitioner’s UAS would otherwise require certification under Part 27, petitioner seeks 

exemption for the same reasons identified in the request for exemption from 14 CFR Part 21, Subpart 

H.

14 FR § 61.23 (a) & (c)

Sets forth medical certificate requirements for different exercised permissions.

All UAS personal in UTA operations will hold either a current FAA airman medical certificate or a valid 

U.S driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or 

the Federal government. The FAA has issued many exemptions to this regulation, see Exemption Nos.

11213, 11252, 11275, 11277, and 11278.

14 CFR § 45.23 (a)(b)

Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according 

to certain specifications.

UAS do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, 

two-inch lettering is difficult to place on such small aircraft. UTARI will mark all UASs with a registration 

number or N number as large as practicable were it can easily be found on the UA. The UAS Ground 

Control Station will also keep a copy of all required markings and identification numbers. The FAA has 

issued many exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700.

14 CFR § 61.101, 61.113, and 61.315

Recreational pilot privileges and limitations, Private and Commercial Pilot Privilege and Limitations, and 

what are the privileges and limits of my sport pilot certificate respectfully. 

The proposed UAS are small, lightweight, and relatively slow. They do not hold a pilot, passengers, or 

cargo (other than operational payload). They can employ a high degree of automation to complete 

technical tasks with a reduced margin of error while ground crews maintain situational awareness. As 

stated in the FAA NPRM on sUAS “the FAA believes that the training, testing, proficiency and 

experience requirements for obtaining a commercial pilot license have limited relevance to the nature of 

small UAS operations” and “the FAA decided that imposing such requirements” of a pilots license

“would be unduly burdensome to small UAS operators”. It is the petitioner’s belief that these statements 

are true and that UAS operators will receive training from UTA and carry a government issued driver’s 
license in order to operate without any form of FAA pilot’s license that would largely be non-relevant to 

their operations. 

14 CFR § 91.7 (a)

Civil Aircraft Airworthiness. Stipulates (a) No person may operate a civil aircraft unless it is in an 

airworthy condition.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation requires 

exemption.

14 CFR § 91.9 (b)(2)

Requires that there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual.

As there are no pilots or passengers, and given the size of the UAS, this Regulation is not applicable. 

An equivalent level of safety will be achieved by maintaining a manual at the UAS Ground Control 

Station. The FAA has issued many exemptions to this regulation, see Exemption Nos. 12104, 8607, 

8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827.

14 CFR § 91.9 (c)

Stipulates No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

As stated above (14 CFR § 45.23 (a)(b)) the UA will not be marked in accordance with manned aircraft 

regulations but will be marked with a registration number or N number. The UAS ground station will 

also keep a copy of all required markings and identification numbers. The FAA has issued many 

exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700.

14 CFR § 91.103 (b)(2)

Requires an aircraft flight manual in the aircraft. 

As there are no pilots or passengers, and given the size of the UAS's, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual at the UAS Ground Control Station. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827.

14 CFR § 91.109

Stipulates, in part, that (a) 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

Regulation is non-applicate as by design UA do not have fully functioning dual controls. Flight control is 

accomplished through the use of a control interface that communicates with the aircraft via radio. 

Given the size, speed and limited operational parameters of the UAS, an equivalent level of safe 

training can be performed without dual controls. The FAA has issued many exemptions to this 

regulation, see Exemption Nos. 11066, 11062, 1067A and 11065.

14 CFR § 91.119 (c)

Minimum Safe Altitudes. Stipulates, in part, that, except when necessary for takeoff or landing, no 

person may operate an aircraft below specific altitudes. 

Exemption is required because UAS operations will be conducted at altitudes no greater than 400 feet 

above the surface. The size, speed, weight and limited operational parameters of the UAS allow for an 

equivalent level of safety.

14 CFR § 91.121
Altimeter Settings. Specifies altimeter initialization and reporting.

Altitude will be measured either by barometric sensor or electronic global positioning systems and 

internal gyroscopes to provide spatial coordination. This will report an AGL altitude readout and will 

provide an equivalent level of safety. The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 12656, 11066, 11065, 11062 and 11063.

14 CFR § 91.151

Fuel Requirements for Flight in VFR Conditions. Stipulates that (a) No person may begin a flight in an 

airplane or rotorcraft under VFR conditions unless they can reach the point of intended landing with

various amounts of extra flight time fuel. This includes 20 extra flight minutes of fuel for rotorcraft. 

For the majority of UA this would include most if not more than all of their total fight time and would 

effectively deny their operation. Under this petition UTA UA would not be permitted to fly unless

(including wind and forecast conditions) the operation could be performed with 25% of the usable 

battery capacity remaining in reserve. This restriction would be more than adequate to return the UA to 

its planned landing zone from anywhere in its limited operating area and provide an equivalent level of 

safety. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 12656, 2689F, 

5745, 10673 and 10808.

14 CFR § 91.203 (a) & (b)

Requires for the carrying of civil aircraft certifications and registrations within the aircraft.

As there are no pilots or passengers, and given the size of the UAS's, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining records at the UAS Ground Control Station.

14 CFR § 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a) & (b)

Maintenance Inspections. These regulations require, amongst other things, aircraft owners and 

operators to "have [the] 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."

These regulations require an airworthiness certificate that will not exist. An equivalent level of safety will 

be obtained by requirement that each UAS will have a flight and maintenance log. Maintenance and 

inspections will be accomplished in accordance with manufacturer recommendations. The FAA has 

issued several exemptions to this regulation: see Exemptions Nos. 12656, 11066, 11062, 11067A and 

11065.

WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST

The requested exemption would authorize the University of Texas at Arlington, to include the UTA 

Research Institute and UTA faculty, to work towards serving the greater public good. UTA’s planned 

research activities on Unmanned Aircraft Systems (UAS) include but is not limited to development of 

guidance, navigation and control systems, sense/detect and avoid methods, autonomous navigation 

with obstacle avoidance, collision avoidance, assistive safety technologies for pilots, fault tolerant 

control systems, intelligent navigation techniques in GPS-denied environments, and moving object 

detection, and identification and tracking systems. The research on these topics will be beneficial for 

government entities such as Department of Agriculture, Department of Transportation, State and Local 

Law Enforcement, Federal Emergency Management Agency for applications including, but not limited 

to, area surveillance, traffic, railroad, and highway surveys and monitoring, customs and border patrol, 

crash scene investigation, highway patrol, area security surveillance, firefighting, wildfire management, 

farm management, wildlife tracking and accounting in remote areas, 3-D terrain mapping, disaster area 

surveys and assessment, search and rescue operations. Approval of this exemption would thereby 
enhance safety and help to fulfill the Secretary of Transportation’s responsibilities under Section 333(c) 

of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the 

national airspace system". Approval of this exemption will allow for safer, more efficient and less costly 

UAS operations, and produce much higher benefits to general public.
SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS EXEMPTION

OR RELIEF

14 CFR Part 21, Subpart H 14 CFR Part 27

45.23 (a)(b)

61.23 (a) & (c)

61.101 (e)(4) & (5)

61.113

61.315 (a)

91.7 (a)

91.119 (c)

91.121

91.151

91.405 (a)

91.407 (a)(1)

91.409 (a)(2) 

91.417 (a) & (b)

91.9 (c)

91.9 (b)(2)

91.203 (a) & (b)

91.103 (b)(2)

91.109
SUPPORTING AND TECHNICAL DOCUMENTS

To be available for reference and review:

UTARI 3DR X8 Pilot Operating Manual 

UTARI AscTech Pelican Pilot Operating Manual

UTARI sUAV Specifications and Logbooks 

UTARI MCE sUAS SOP all aircraft