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RESCUE TRAINING, INC.

9 Mall Terrace

Savannah, GA 31406

U.S. DEPARTMENT OF TRANSPORTATION

Docket Management System

1200 New Jersey Avenue

SE Room W-12-140

West Building Ground Floor

Washington, DC 20590-0001

October 12, 2015

Dear Administrator:

Enclosed please find the petition from Rescue Training, Inc. to the Federal Aviation 

Administration seeking an exemption from the requirements of Title 14 of the Code of 

Federal Regulations concerning the operation of an Unmanned Aircraft System for, 

commercial use and operation within the United States. The proposed exemption, if 

granted, will permit Rescue Training’s commercial use of the Unmanned Aircraft System 

(“UAS”) for the purpose of research and development, UAS training, and public entity 

operational support to include aerial inspections of buildings and land within the United 

States.

Respectfully,

David E. Hall, Jr.

President & CEO

9 Mall Terrace

Savannah, GA 31406

Tel: (912) 692-8911

Email: dave@rescue1.com
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TABLE OF CONTENTS

SUMMARY FOR SEEKING EXEMPTION--------------------------------------------------3 

COMPANY BACKGROUND------------------------------------------------------------------4 

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS---------------------------------- 4 

AIRCRAFT 

GROUND CONTROL STATION 

BASIS FOR PETITION FOR EXEMPTION-------------------------------------------------7

NAME AND ADDRESS OF RESCUE TRAINING, INC. -------------------------7

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RESCUE TRAINING

SEEKS EXEMPTIONS and THE EXTENT OF RELIEF RESCUE TRAINING, 

INC. SEEKS AND THE REASON RESCUE TRAINING, INC. SEEKS THE RELIEF

REASONS IN THAT THE EXEMPTION IS IN THE PUBLIC INTEREST----17

A SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTRAR --------18

ADDITONAL INFORMATION, VIEWS OR ARGUMENTS AVAILABLE 

TO SUPPORT THE REQUEST FOR AN EXEMPTION FOR 

RESCUE TRAINING, INC.----------------------------------------------------------19

PRIVACY ISSUES DO NOT ARISE AT THE GRANT OF THE 

EXEMPTION-----------------------------------------------------------------------------------19 

CONCLUSION--------------------------------------------------------------------------------- 20

GLOSSARY/ABBREVIATIONS------------------------------------------------------------- 20
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SUMMARY FOR SEEKING EXEMPTION

RESCUE TRAINING, INC. (“Rescue Training”), a Georgia Corporation, seeks an 

exemption from the requirements of Title 14 of the Code of Federal Regulations in 

particular an exemption from the following sections:

Part 21 

14 C.F.R. §45.23(b) 

14 C.F.R. §61.113 (a) and (b) 

14 C.F.R. §91.7(a) 

14 C.F.R. §91.9(b) (2) 

14 C.F.R. §91.103 

14 C.F.R. §91.109(a) 

14 C.F.R. §91.119(b) 

14 C.F.R. §91.121 

14 C.F.R. §91.151(a) (1) 

14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) (1) 

14 C.F.R. §91.409(a) (2)

14 C.F.R. §91.417(a) and (b)

Rescue Training seeks to commercially fly an Unmanned Aircraft System (UAS) 

within the United States. The proposed UAVs are small quad copter no more than 20 

pounds fully loaded with equipment to be flown at no more than 400 feet above ground 

level (“AGL”) and not within 5 miles of an airport. The exemption will have a positive 

impact on the public interest by providing services that are not readily available to the 

general public but are in high demand by both private and municipal parties. The 

exemption in particular will allow Rescue Training, Inc. to offer a spectrum of services 

using the UAS including community training workshops and other training programs on 

the proper use and operation of UAVs to ensure safe operation by hobbyists, commercial, 

and public safety first responder users as well as to provide innovative and economically 

beneficial options of building/land data collections to include search and rescue and post 

disaster assessment/operations. 

The Petitioner is dedicated to following the conditions and limitations as imposed 

by the FAA regarding the flight of the UAS and including but not limited to avoid and yield 

right-of-way to all manned operations, file necessary notices and flight plans as well as 

adhere to the city and state imposed regulations to ensure the utmost safety for the general 

public and the operators.
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COMPANY BACKGROUND

RESCUE TRAINING, INC., founded in 1992, is a Georgia Corporation with a primary 

place of business in Savannah, GA and a satellite school in Orlando, FL. It is licensed in both 

states to provide public safety training that concludes with licensure or certification as 

Paramedic or EMT. Additional certified training programs include EMT-TacticalTM, Law 

Enforcement Trauma Care, Tactical Combat Casualty Care (TCCC). These programs are 

conducted for military and public safety entities. In addition, it conducts community 

training programs such as CPR and First Aid to the general public, volunteers, and 

advanced level emergency medical courses to the medical community at both schools.

Rescue Training, Inc. has a strong interest and desire to provide UAV training to 

promote safety in the national airspace. The program developers are David E. Hall, Sr. 

(Ret.) U.S. Army helicopter pilot and David E. Hall, Jr., President & CEO. Rescue Training, 

Inc. is an “Authorized Training Center” of the Unmanned Safety Institute (USI), an affiliate 

of Waypoint Global Strategies, Inc. (FAA–2015–0945). 

Rescue Training proposes to conduct safety training programs for the recreational 

users, commercial users, and public safety first responders to fully understand and comply 

with FAA regulations, laws, and rules pertaining to safe and legal operations of the small 

UAS.

The company is interested in performing Research and Development for a unique 

platform of services to be utilized commercially by emergency management agencies and 

other public safety providers. The company also wishes to provide “on-demand” Public 

Safety Support Operations to local Emergency Management Agencies and other public 

safety organizations requesting those services for such things as utilizing an UAV for search 

and rescue, post disaster assessment, hazmat assessment, and other requested special 

operations.

Rescue Training is dedicated to offering innovative and customized services to 

consumers using the UAS to better serve the community and the public interest by 

providing a safer and economical alternative to current practices of obtaining overhead 

visualization/assessments utilizing helicopters and other services as well as by providing 

UAS safety education for enthusiasts and commercial entities to ensure safer operations of 

the UAS in the National Airspace System (“NAS”).

UNMANNED AIRCRAFT SYSTEM SPECIFICATIONS

I. AIRCRAFT

Rescue Training seeks an exemption to operate the following unmanned aerial vehicles for 

commercial use within the NAS.

1. DJI PHANTOM 2

2. DJI PHANTOM 3

3. DJI INSPIRE 1

4. YUNEEC Q500
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These four quadcopter (UAVs) are very similar in design and capabilities. Each is equipped with an 

on-board flight computer with constant communication with the ground station transmitting live 

data regarding speed, compass direction of flight, and altitude levels amongst its in-flight data. The 

UAS contains a Global Positioning System (“GPS”) tracking device and an on-board camera capable 

of capturing full color, high definition still photos and video. The UAS is also equipped with four sets 

of LED ‘status-lights’ which providing not only an enhanced visual from the ground but assisting the 

Pilot in Command (“PIC”) to confirm battery, GPS and other functionalities of the UAS based on the 

color and status of the lights.

 DJI PHANTOM 2 DJI PHANTOM 3

YUNEEC Q500 DJI INSPIRE 1

TYPHOON Q500 4K

FLIGHT TIME: Up to 25 Minutes

DIMENSIONS: 9.45 in (210mm) x 16.54 in (420mm)

DIAGONAL MOTOR TO MOTOR DISTANCE: 20 in (510mm)

PROPELLER/MAIN ROTOR DIAMETER: 13.0 in (330mm)

WEIGHT WITHOUT BATTERY AND PAYLOAD: 40.0 oz (1130g)

MAXIMUM TAKEOFF WEIGHT WITH CGO3: 60.0 oz (1700g)

BATTERY: 5400mAh 3S 11.1V LiPo (included)

CHARGER: 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included)

TRANSMITTER: 10-channel 2.4GHz with 5.8GHz video downlink (included)

MAXIMUM FLYING ALTITUDE: Default 400 Feet Above Ground Level

(Adjustable via the Q500 GUI)

MAXIMUM ROTATION RATE: 65°/s

MAXIMUM ROLL ANGLE: 35°

RADIO CONTROL FREQUENCY BAND: 2.4GHz

MAXIMUM CLIMB RATE: 2m/s

MAXIMUM DESCENT RATE: 3m/s
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Specifications for each UAV is located in the attached “User Manuals”. Having very similar 

characteristics, all weigh less than 20 lbs and cannot exceed 50 mph.

II. GROUND CONTROL STATION

The ground control (“GCS”) station is the primary takeoff and landing point of the UAS and 

includes a setup, consisting of people and equipment, to promote the utmost safety for all 

persons involved in the operation including the operators, general public, and any objects 

or persons that may come into contact with the zone of operation (“Zone”). Specifically the 

ground station includes:

a. Pilot in Command: A designated pilot with a private pilot’s license, a current 

third-class medical certificate and a deep knowledge and thorough understanding of 

the UAS and its operation as well as numerous hours of experience in operating the 

UAV. PIC will operate the UAS within visual line of sight (VLOS) at all times using 

human vision unaided by any device other than corrective lenses.

b. Flight Coordinator/Visual Observer (“VO”): A second person, other than the 

PIC, with a visual of the UAS at all times and the ability and knowledgeable to assist 

the PIC as needed including verbal as well as physical command of the controls. The 

UAS will always be within the VLOS of the VO. The PIC and the VO will have the 

ability to communicate verbally at all times.

c. Equipment: 

a. A radio transmitter/controller operated by the PIC. 

b. A portable receiver receiving transmitted live video and flight data from 

the UAS onboard camera and computer. This data is projected onto the 

controller used by the PIC to monitor during the flight. 

d. Zone: A designated area cordoned off by brightly colored cones to put the 

surrounding public on notice of the operation. One sandwich board with the name of 

the company, contact information, and description of the operation in order to alert 

the general public of the event taking place and allowing anyone interested to 

contact Rescue Training with questions. 

General Description A battery operated lightweight rotorcraft with additional 

onboard equipment and a separate ground station used 

for operation. 

Weight (including battery) Approximately 5 lbs. 

Flight path Vertical takeoff and landing 

Hovering Accuracy (Ready to Fly) Vertical: 0.8m/ Horizontal: 2.5 m 

Max. Ascent/Max. Descent Speed Ascent: 6m/s; Descent: 2m/s 

Max. Flight Speed 22 m/s 

Number of copter blades Four 

Color Base Color - White, Black, Gray
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e. Paperwork: The ground station will also include a designated area for the a copy 

of the pilot’s license, Operator’s Manual for the UAV (“Manual”) in operation, as 

amended with conditions or limitations scripted by the FAA, copy of the granted 

exemption, pursuant to the grant of this exemption by the FAA, copy of the 

insurance certificate, business cards and any other relevant paper work for the 

specific event. 

f. Other: Anything else that is required in order to be in full compliance with the 

regulations of the City and State where the event is taking place. 

BASIS FOR PETITION FOR EXEMPTION

Pursuant to the authority granted to the FAA under Federal Aviation Regulations, 14 C.F.R. 

§ 11.61(b) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules 

for Certain Unmanned Aircraft Systems, Rescue Training, Inc. respectfully requests to grant 

its petition for an exemption from the requirements of 14 C.F.R Part 21; 14 C.F.R. §61.113 

(a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. §91.9(b)(2); 14 C.F.R. §91.103; 14 C.F.R. §91.109; 

14 C.F.R. §91.119; 14 C.F.R. §91.121; 14 C.F.R. §91.151(a); 14 C.F.R. §91.203(a) and (b); 14 

C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §91.409(a)(2); and 14 C.F.R. 

§91.417(a) and (b). 

A. Name and Address of Petitioner:

Rescue Training, Inc.

9 Mall Terrace

Savannah, GA 31406

B. Specific Sections of 14 C.F.R. From Which Rescue Training Seeks

Exemptions and the Extent of Relief Rescue Training Seeks; The Reason

Rescue Training Seeks The Relief and Reasons why the Exemptions

Would not Affect Public Safety.

1. Rescue Training seeks an exemption from 14. C.F.R. Part 21

14 C.F.R. Part 21- Airworthiness Certificate 

14 C.F.R. Part 21 along with 14 C.F.R. §91.203(a) (1) establishes the necessary 

procedures in order to obtain an airworthiness certificate for a manned aircraft. The 

general purpose of an airworthiness certificate for an aircraft is to ensure the aircraft’s safe 

functionality, good working order and to ensure the safety of those onboard as well as 

anyone in proximity to the aircraft at any time. The Federal Aviation Act, 49 U.S.C. 

§44701(f) and Section 333 of the Reform Act statutorily authorize the FAA to issue an 

exemption from the airworthiness requirements upon consideration of the aircraft’s size, 

weight, speed and operational capability. Such considerations should be applied to 
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Petitioner’s UAS in determining that Rescue Training should be exempt from the 

airworthiness requirement for its UAS. 

The UAS to be operated by Rescue Training is less than 55 lbs. fully loaded (inclusive 

of additional equipment such as GPS tracker, camera, etc.) and does not carry a pilot or 

passengers. Furthermore, the UAS does not contain explosives, fuel or any other flammable 

materials. The operation of the UAS will be strictly confined to a designated area and under 

full control of the PIC and VO.

Safety Standard: The UAS is equipped with several safety features, which will 

further serve as a reason to exempt it from an airworthiness certificate. The UAS is 

equipped with a “Fail-Safe Feature” which allows it to self-correct a failure that is beyond 

control of the PIC. Once a “Failure” is detected the UAS’s automatic safety feature is 

triggered which prompts it to return to its GPS point of origin of takeoff. This along with the 

other safety features such as a proposed inflatable landing skids (in early stages of 

development) provide an enhanced safety feature to the operator and the general public 

compared to manned aircraft that hold an airworthiness certificate and are used to 

perform the tasks proposed to be performed by the UAS. 

Rescue Training would like to refer to Exemptions No.11062 and11067 in which the 

FAA previously determined that based on the [Petitioner’s] UAS “limited size, weight, 

operating conditions, design safety features and the imposed conditions and limitations ...

the [Petitioner] has demonstrated that the operations would not adversely affect safety 

compared to similar operations conducted with aircraft that have been issued an 

airworthiness certificate under 14 C.F.R. Part 21, Subpart H”. 

In the alternative Petitioner respectfully requests that the Administrator finds that 

the exemption from 14 C.F.R. Part 21 is not necessary because the regulation is not 

applicable to the UAS to be used by the Petitioner.

2. Rescue Training seeks an exemption from 14 C.F.R. §45. 23(b) 

14 C. F. R. §45.23(b) - Display of Marks; General 

(b) When marks include only the Roman capital letter “N” and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable. Provided that the exemption from 

Part 21 is granted and the UAS will not need an airworthiness certificate,

Petitioner seeks an exemption from the requirement that the word 

“EXPERIMENTAL” be displayed on the UAV near each entrance to the cabin, cockpit 

or pilot station. The requested UAVs are considered small UAS and subsequently 

does not have a cabin, cockpit, pilot station or any other type of entrance. The size of 

the UAS does not permit any markings to be above one inch (1”) in height and be 

longer than eight inches (8”). 
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Safety Standard: In order to achieve an equivalent level of safety and to most 

closely comply with the FAA regulations, Rescue Training proposes to display the 

word “EXPERIMENTAL” on top of the UAS with the dimensions of the signage being 

one inch by eight inches (1”x 8”) in compliance with 14 F.C.R. §45.29 (f). This type of 

signage will allow the PIC, FC and others in close proximity to see the designation of 

the UAS.

The FAA should grant Rescue Training the exemption from the regulation regarding 

the requirement for signage. As the FAA decided in Exemptions No. 11062 and 

11067 that an exemption from such requirements is warranted given that the 

aircraft obtains an N-number in accord with 14 C.F.R. Part 47, have identification (Nmarkings) in accord with 14 C.F.R. 45, Subpart C. and the markings must be as large 

as practicable the FAA Administrator should decide similarly in this instance. 

Rescue Training will display 9 markings as large as practicable on the top of the UAS 

in the interest of safety and compliance. See also Exemptions Nos. 10700, 8738, 

10167, and 10167A. 

3. Rescue Training seeks an exemption from 14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §61.113- Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

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

Rescue Training seeks an exemption from the restriction outlined in parts (a) and (b) of the 

regulation prohibiting a holder of a private pilot’s certificate to act as a pilot for an aircraft 

carrying property for compensation or hire. The UAS to be used by Rescue Training will be 

used for commercial operation for compensation or for hire, however, will not be carrying 

any passengers or cargo allowing Rescue Training to achieve the same level of safety of 

current operations by requiring the PIC to obtain a private or sport pilot’s license instead of 

a commercial pilot license. Unlike an aircraft that carries cargo or passengers, the UAS is 

remote controlled by an experienced PIC.

Safety Standard: Pursuant to obtaining a grant of the exemption to operate the UAS 

for compensation, Rescue Training will ensure that the PIC holds a private pilot’s license, 

has a significant number of flying hours and follows the instructions as set forth in the 

Manual for the UAS. Since there are no persons on board and the UAS will be operated 

within the safety procedures outlined by the FAA regulations, the operation of the UAS by 

remote control with a private pilot’s license by the PIC will exceed the present level of 

safety meant to be achieved by the requirements of 14 C.F.R. §61.113 (a) and (b). 
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As the FAA Administrator previously outlined in Exemption Nos. 11062 and 11067 

“[a]nother consideration supporting the certificate requirement is that pilots holding a 

private pilot certificate are subject to security screening by the Department of Homeland 

Security” and this type of screening should overrule “security concerns over the UAS 

operations” that would be granted under this exemption. Additionally as the FAA 

concluded in the analysis of the areas of knowledge specified in 14 C.F.R. part 61 for that of 

a commercial pilot versus a private pilot, the results show that “the required areas of 

knowledge for a commercial versus private pilot cover the same fundamental principles”. 

Granting Rescue Training the exemption based on the safety outlines and requirements 

outlined by the FAA and the experience and expertise of the PIC, would not adversely affect 

the safety of the NAS. 

Rescue Training would like to refer to Exemptions No.11062 and 11067 in which 

the FAA previously determined that a commercial pilot’s license is not required to operate 

an UAS.

4. Rescue Training seeks an exemption from 14 C.F.R. §91.7(a) 

14 C.F.R. §91.7(a)-Civil aircraft airworthiness 

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

Rescue Training requests an exemption from the regulation, pursuant to Rescue Training

obtaining of an exemption to 14 C.F.R. Part 21, there will be no airworthiness certificate 

issued for the UAS and consequently a standard for airworthiness is not applicable. 

Safety Standard: Rescue Training’s compliance with an established pre-flight safety 

checklist, standard of operation as described in the Manual and outlined in the 

maintenance requirements prior to each flight ensures that an equivalent level of safety 

will be provided during all times of operation. The PIC will be in compliance with the 

requirements of 14 C.F.R. §91.7(b) when determining whether the aircraft is in a condition 

for safe flight.

As the FAA determined in Exemption Nos. 11062 and 11067 that a requirement of 

airworthiness does not need to be met if a certificate of airworthiness is not required, the 

FAA should determine similarly in favor of Rescue Training that if they are granted the 

exemption from a certificate of airworthiness, the provision of 14 C.F.R. §91.7(a) and (b) is 

not necessary.

5. Rescue Training seeks an exemption from 14 C.F.R. §91.9(b)(2) 

14 C.F.R. §91.9(b) (2) - Civil Aircraft Manual Requirements 

No person may operate a U.S.-registered civil aircraft—

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 
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Flight Manual, approved manual material, markings, and placards, or any combination 

thereof. 

Rescue Training seeks an exemption from maintaining a flight manual aboard the 

UAS.

Safety Standard: Given the size and design of the UAS it is not possible to carry the 

manual onboard during operation. To ensure full compliance with safety requirements the 

manual will be available at the ground station and immediately accessible by the PIC and 

VO at all times during operation. 

Petitioner would like to refer to Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, 10700 and 11067 where the Administrator 

issued a similar exemption as requested here. In the alternative, Petitioner requests that 

the Administrator finds that the exemption is not necessary based on the FAA 

Memorandum subject “Interpretation regarding whether certain required documents may 

be kept at an unmanned aircraft’s control station” dated August 8, 2014.

6. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.103

14 C.F.R. §91.103- Preflight Action

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be 

completed, and any known traffic delays of which the pilot in command has been 

advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the 

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature.

Rescue Training, Inc seeks an exemption from the Preflight Action requirements as 

prescribed in 14 C.F.R. §91.103 which requires the PIC to take certain actions before flights 

to ensure safety.

Safety Standard: The PIC will be familiar with all of the manual requirements and 

recommendations as well as perform a “Cross-Check Quadrant TM “a customized pre-flight 
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check list of actions to be performed prior to operation of the UAS. Combined, the PIC will 

take actions such as inspection of the UAS, the weather elements, and physical inspection of 

the area of operation and aircraft performance data prior to the initiation of every single 

flight. The Operator’s Manual and Operational limitations will be kept at the ground station 

within reach of the PIC at all times. The information collected at the time of the pre-flight 

check will be compiled into a report and kept in Petitioner’s office for record keeping. The 

pre-flight procedures will allow an equivalent if not higher level of safety to be reached. 

The PIC will also take into account visibility and distance from clouds as well as sun glare 

and the ability to see other traffic when conducting the pre-flight inspections.

In the alternative Petitioner requests the Administrator to find that the exemption is 

not necessary, as the FAA administrator found in Exemption Nos. 11062 and 11067, that 

with conditions and limitations the exemption is not necessary.

7. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.109(a)

14 C.F.R. §91.109(a) - Flight Instruction

(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 functional dual controls...

Petitioner requests an exemption from the regulation because the UAS and other 

remotely piloted aircraft, by design, do not have functional dual controls. Flight control of 

the UAS is accomplished by the PIC’s use of a control box which communicates with the 

aircraft via radio signal communication.

Safety Standard: Since the UAS is not carrying a pilot or passengers the equivalent 

level of safety will be achieved with the remote control of the UAS and without dual 

controls. The PIC is in full control of the UAS at all times. Because the flight will be 

performed in a cordoned off area, any trouble that the UAS might experience will be 

rectified in a safe manner by the PIC and the FC without any interference or danger to the 

public.

Petitioner would like to refer Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS may be operated without dual controls. See also 5778K and 

9862A.

In the alternative the Petitioner would like to request the Administrator to determine 

that the 14 C.F.R. §91.109(a) regulation is not applicable to Rescue Training, Inc. since 

Rescue Training, Inc. does not plan to use the UAS in an environment where dual controls 

are necessary such as instrument flight instruction and the PIC will be the only controller in 

operation of the UAS at all times. The VO may utilize a separate controller for camera 

operations only.
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8. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.119(b)

14 C.F.R. §91.119(b) - Minimum Safe Altitudes: General

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft.

Rescue Training, Inc. seeks an exemption from the requirement of a subsection (b) and 

relies on subsection (d) for an exemption. Subsection (d) permits the operation of a 

helicopter at less than the prescribed minimums, given that the operator is in compliance 

with any route or altitudes prescribed for helicopters by the FAA.

Rescue Training, Inc. requests an exemption to operate the UAS at 400 feet AGL. Except 

for the limited conditions stated in the Manual the UAS will not operate above 400 feet AGL. 

The equivalent level of safety will be achieved provided the size, weight and speed of the 

UAS.

Safety Standard: Rescue Training’s operation will provide at least an equivalent level

of safety if not higher at 400 feet AGL to those in relation to the minimum safe altitudes as 

outlined in regulation 91.119. Most civil airplanes operate at 500 feet AGL or above 

therefore the operation of the UAS by petitioner will not be in direct interference with 

manned aircraft in the NAS. 1 The operation of the UAS will be in a cordoned off area with 

security perimeters set up by the PIC. All property owners and abutters who may be 

affected will receive advanced notice of the operation and the propose flight operations as 

set forth in the proper Section of the Manual. The PIC will be in the ground control station 

equipped with the set up as described in detail above in the “Unmanned Aircraft 

Specifications”. Rescue Training, Inc. will ensure a “safe zone” around the area of PIC 

operation as large as is allowable in an urban setting. At all times anyone interested in the 

operation criteria of the UAS can contact Petitioner to obtain the necessary information. 

Rescue Training plans to design and equip an (emergency) inflatable landing skid 

system for the UAS in order to ensure a higher level of safety for those involved and around 

the operational area. The UAS is equipped with an automatic system that detects “trouble” 

such as low battery or connection loss and automatically triggers the UAS to land safely 

back at its point of lift off based on the GPS recorded coordinates of the take off. 

Compared to flight operations with aircraft or rotorcraft weighing far more than the 

UAS proposed to be used by Rescue Training and lack of flammable fuel and a pilot or 

passengers on board any risk associated with these operations is far less as compared 

manned aircraft operated in accord with the minimum altitude requirements as outline in 

the regulation..

1 Dershowitz, Adam Dr. , PhD., P.E. , CFEI, “UAS Safety Analysis Exponent Project”, December 2014, 

page 4. 
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9. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.121 

14 C.F.R. §91.121- Altimeter Settings 

(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—... 

Rescue Training, Inc. requests an exemption from the Altimeter Settings 

requirement because the UAS does not have a barometric altimeter, but is instead equipped 

with a GPS altitude reading device.

Safety Standard: With an exemption from the regulation, an equivalent level of 

safety will be achieved by the operator, pursuant to the Manual and pre-flight check lists 

and by confirming the altitude of the launch site as shown on the GPS altitude indicator 

before flight. To ensure that the exemption from the regulation does not adversely affect 

safety the petitioner proposes to operate the UAS at or below 400 feet AGL, provide 

altitude information to the PIC via a digitally encoded telemetric data feed, which 

downlinks from the ground-based

on-screen display. Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy buy the UAS PIC and the altitude information will be generated 

by equipment installed onboard the aircraft, as specified using GPS triangulation. 

Petitioner would like to refer to Exemption Nos. 11062 and 11067 where the 

Administrator found that UAS is permitted to be operated with a digitally encoded 

telemetric data feed instead of an onboard barometric altimeter. See also Exemption Nos. 

5778K and 9862A.

10. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.151 (a) -Fuel requirements for flight in VFR conditions

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed—

Rescue Training, Inc. seeks an exemption from the fuel requirement regulation because 

the Battery Life of the UAS, as outlined in the Operating Manual, is 25 minutes when flown 

without additional equipment and 15 minutes fully loaded with a camera and GPS tracking 

unit. The UAS battery life does not fit within the requirement of (a) (1) and Rescue 

Training, Inc. is not planning on flying the UAS in the nighttime.

Safety Standard: Rescue Training, Inc. proposes to limit the flight to 10 minutes total 

time after takeoff. Petitioner believes that an equivalent level of safety will be achieved by 

limiting flights to 10 minutes or 25% of battery power, which ever happens first which is 

well within the limits of the Manual. This proposed restriction will allow an adequate 

amount of time for the UAS to return to its intended landing zone during the operation. 

As the FAA granted relief for manned aircraft to operate at less than the minimums 

prescribed in 14 C.F.R. §91.151(a)(1) the FAA should grant a similar exemption to 

Petitioner in that the UAS can operate 10 minute flights or within 25% of battery life 
15

reserve. See similar rulings in Exemption Nos. 2689, 5745, 10650, 11062 and 11067. See 

also similar UAS-specific relief granted in Exemption Nos. 8811, 10808, and 10673 for 

daytime, Visual Flight Rules (VFR) conditions.

11. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.203(a) and (b) 

14 C.F.R. §91.203(a) and (b)-Civil Aircraft: Certifications Required 

(a)Except as provided in §91.715, no person may operate a civil aircraft unless it has within 

it the following: 

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a 

copy of the applicable operations specifications issued under §21.197(c) of this 

chapter, appropriate sections of the air carrier manual required by parts 121 and 

135 of this chapter containing that portion of the operations specifications issued 

under §21.197(c), or an authorization under §91.611) must have on it the

registration number assigned to the aircraft under part 47 of this chapter. However, 

the airworthiness certificate need not have on it an assigned special identification 

number before 10 days after that number is first affixed to the aircraft. A revised 

airworthiness certificate having on it an assigned special identification number, that 

has been affixed to an aircraft, may only be obtained upon application to an FAA 

Flight Standards district office. 

(2) An effective U.S. registration certificate issued to its owner or, for operation within 

the United States, the second copy of the Aircraft registration Application as 

provided for in §47.31(c), or a registration certification issued under the laws of a 

foreign country. 

(b)No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Rescue Training, Inc. requests an exemption from sections (a) and (b) of the 

regulation because the Administrator grants the earlier requested exemption from Chapter 

14 Part 21 the UAS will not be required to obtain an airworthiness certificate. Additionally 

the UAS is less than 55 lbs. when fully loaded and does not contain an onboard pilot 

therefore there is no ability or place to carry the certification and registration documents 

as prescribed. 

Safety Standard: Rescue Training, Inc. proposes to achieve the equivalent level of 

safety that is premised by the regulation by keeping the necessary and required documents 

at the ground control station within immediate reach by the PIC at all times and will be 

made available to the Administrator and law enforcement immediately upon request. 
16

For similar exemptions to this regulation granted by the FAA see Exemption Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11062 and 11067. In the 

alternative, Petitioner requests that the Administrator finds that the exemption is not 

necessary based on the FAA Memorandum subject “Interpretation regarding whether 

certain required documents may be kept at an unmanned aircraft’s control station” dated 

August 8, 2014.

12. Rescue Training, Inc. seeks an exemption from 14 C.F.R. §91.405(a), 

91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

14 C.F.R. §91.405(a), 91.407(a) (1), 91.409(a) (2) and 91.417(a) and (b) - Maintenance 

Exceptions

Rescue Training, Inc. seeks an exemption from the above outlined regulations 

governing the maintenance requirements, because these sections along with Part 43 apply 

only to aircraft with an airworthiness certificate, which if the petition is granted by the 

Administrator, will not apply to the Petitioner.

Safety Standard: With the grant of the exemption, an equivalent or higher level of 

safety will be achieved during the operation of the UAS. The Petitioner will inspect the UAS 

regularly and address all mechanical issues immediately. The PIC will ensure that the UAS 

is in proper working order prior to every flight, perform required maintenance and keep a 

record log of any maintenance issues and their respective resolutions. In the instance that 

the UAS is dormant for a prolonged period of time, the operator will inspect the UAS biweekly to ensure its working order. All maintenance and inspections will be performed in 

accordance with the Operator’s Manual (attached) and flights will not be conducted until 

the pre-flight check has been performed prior to each flight.

C. Reasons Why the Exemption Would Not Adversely Affect Public Safety 

And How the Exemption Would Provide a Level of Safety at least Equal 

to The Existing Rule 

Taking into consideration the safety standards outlined above granting Rescue 

Training an exemption to permit commercial operation of the UAS will not adversely affect 

public safety and would provide a level of safety at least equal to the existing rule and in 

several cases provide a higher level of safety. The UAS is a battery operated unmanned 

aircraft with no flammable fuel, pilot or passengers on board and operated by an operator 

with at least a private pilot’s license. The UAS will in several instances replace a manned 

aircraft hired to perform the same task or serve as an alternative to using persons climbing 

to high elevations and eliminating the risk of incident of injury or fall. 

The UAS will be operated by an experienced PIC who will be in full control of the 

UAS at all times with a VO who will provide another visual and keep the UAS in a VLOS at 

all times. . PIC will have access to all necessary up to date equipment, machinery and 
17

mechanicals necessary for the proper and airworthy operation of the UAS. Furthermore, 

Rescue Training will carry general commercial liability insurance to the training and 

operation of the UAS in excess of $1,000,000 and provide the insurance certificates upon 

request. Rescue Training proposes to operate the UAS with the utmost diligence, care and 

responsibility as outlined in the exemptions, regulations and additional restrictions and 

guidelines as proposed by the FAA. 

With following the safety provisions as outlined in the Manuals and being in strict 

compliance with FAA regulations, restrictions and conditions the operation of the UAS will 

not adversely affect public safety and the exemption will provide a level of safety at a level 

greater than the existing rule by providing alternative ways to inspect areas of high 

elevation instead of using physical man power to do so, thus preventing injuries and other 

hazards.

D. The Exemption is in the Public Interest 

Granting Rescue Training, Inc.’s request for a petition for the exemption from the 

regulations outlined above will further the public interest by allowing Rescue Training, Inc.

to provide commercial services and thus expanding the stream of commerce. Providing 

such services the public holds many benefits because these options are much more 

economical and safer than current available options, create safe and useful options for first 

responders to use in emergency situations and allows Rescue Training to conduct research 

and development for other uses of the UAS with future hopes of providing a positive

economic impact on the community as a whole while not implicating privacy and ensuring 

all equivalent safety levels and standards. 

Rescue Training, Inc. proposes to use the UAS system to perform “on-demand” 

services for public safety agencies (EMA, Police, Fire, and EMS) to provide UAS assistance 

in response to post disaster assessment, hazmat incidents, search and rescue operations, 

and other such public safety operations to augment or provide a more economical, faster, 

and/or safer alternative than utilizing manned helicopters, first responders, and/or other 

human observers to provide emergency assessments of hazardous materials, aerial data 

collections, aerial searching for missing persons, etc. 

Rescue Training proposes to offer these services until such time as the agency 

receives proper UAS safety training, COA, and establishes their own UAS Program. Rescue 

Training would like to assist these first responders in obtaining and establishing the 

necessary safety training program building a culture of safety within their agency.

Rescue Training proposes to offer three levels of “safe and legal” UAS training 

programs. All levels would utilize simulations and hands-on training. Level I Training - is 

offered for the hobbyist and recreational user. All instructions follow the standards and 

guidelines as provided by the FAA, the “knowbeforeyoufly.org” website, USI, AUVSI, and the 

AMA. Level II- is designed for the commercial UAS operator and those interested in 

obtaining their own exemptions for commercial operations. Level III – is designed for the 

Public Safety Agency/Operator wishing to implement an UAS program.

This exemption will also further the public interest by providing the option of 

having access to aerial photography and videography. The use of the UAS will provide 

government and private reporting agencies, real estate and development firms as well as 
18

architects the option to use a UAS to obtain aerial views, replacing the use of a manned 

aircraft. Use of the UAS is both more economical and safer and decreases congestion of the 

NAS. The use of the UAS versus a manned aircraft will also create a reduction in noise and 

air pollution, an increase in safety and a better economic alternative for the public. 

Finally, the public will benefit from the use of the UAS by Rescue Training, Inc.

because Rescue Training proposes to perform research and development for other uses of 

the UAS which although not yet fully developed are proposed to benefit the first

responders by using the UAS to investigate areas of high activity and danger zones creating 

a safer alternative than utilizing a person to perform the same investigation. The possibility 

of UAS utilization creates a safer, economical and indispensable alternative to current 

options. 

The enhanced safety achieved by using a UAS with a licensed PIC and the added 

safety gear to be used strictly in compliance with the uses outlined above while carrying no 

passengers or crew is in the public interest to replace the use of a manned aircraft of 

significantly greater proportions , carrying crew and flammable fuel. This use provides an 

alternative use with more accuracy and a higher level of safety.

E. A Summary to be Published in the Federal Registrar 

Applicant, Rescue Training, Inc., seeks an exemption from the following regulations Part 

21; 14 C.F.R. §45.23(b); 14 C.F.R. §61.113 (a) and (b); 14 C.F.R. §91.7(a); 14 C.F.R. 

§91.9(b)(2);14 C.F.R. §91.103; 14 C.F.R. §91.109(a); 14 C.F.R. §91.119(b);14 C.F.R. §91.121; 

14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.203(a) and (b); 14 C.F.R. §91.405(a); 14 C.F.R. 

§91.407(a)(1); 14 C.F.R. §91.409(a)(2); 14 C.F.R. §91.417(a) and (b), as established by the 

FAA, in order to commercially operate an unmanned aerial system weighing less than 20 

lbs. and operating at a maximum altitude of 400 feet AGL for aerial imagery and research 

and development for other commercial uses including but not limited to UAS safety 

training and land / building inspections.

The grant of the exemption allowing for commercial operation will maintain an 

equivalent if not higher level of safety than the one proposed by the FAA regulations, 

benefit the public interest and create a positive impact on the stream of commerce. 

Currently, the only way to obtain aerial imagery is to employ a manned aircraft system 

which often weights more than 4,000lbs, carries a pilot and flammable fuel and requires a 

designed large area landing pad or airport in order to get into the air. The other option to 

obtain aerial imagery is to physically scale a building in order to achieve a higher altitude 

for the imagery needed. The UAS, which is powered by battery and remote operated from a 

ground control station, provides a much safer and easier alternative eliminating most of 

the risk associated with accidents of a manned aircraft or injuries and accidents of climbing 

heights. 

The operation of the UAS conducted with strict accord of the FAA regulations and 

within the conditions outlined above will provide an equivalent if not higher level of safety 

supporting the grant of the exemption request by Rescue Training, Inc., including the 

exemption from the requirements of Part 21 and allowing commercial operations.
19

F. Additional Information, Views or Arguments Available

to Support the Request For an Exemption For RESCUE TRAINING, INC.

A recent “UAS Safety Analysis Exponent Project” conducted by Dr. Adam 

Dershowitz, PhD., P.E. , CFEI, a managing Engineer in Exponent’s Thermal Science practice, 

at the request of UAS America Fund , LLC and Kramer Levin Naftalis and Frankel, LLP 

concludes “that there is no significant added risk to other airspace users posed by this type 

of commercial drone operation” that is proposed to be used by Rescue Training, Inc..

The study is based on an analysis of 25 years of safety data involving small and 

medium sized birds, representing a simulated drone flight, and the rate of collisions with 

manned aircrafts. The study further concludes that using the proposed regulations of a 

maximum altitude of 400 feet AGL and a radius of 5 miles from airports there is no 

indication of imposed significant risk in allowing the operation of small UAS at or below 

400 feet AGL and at least 5 miles or further from airports. 

Rescue Training, Inc. further requests that the FAA recommend special condition, 

limitations and guidelines for the operation of the UAVs, which contain safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to the level 

established by Chapter 14 and the applicable subsections.

NO PRIVACY ISSUES ARISE AT THE GRANT OF THE EXEMPTION

If Rescue Training, Inc. is granted an exemption there are no privacy issues with 

regard to the operation of the UAS. Any privacy concerns, which might arise, can be 

alleviated by providing advanced notice to the possible affected persons. 

The UAS will be operated at the request of a client. At the inception of the agreement 

Rescue Training, Inc. will provide the client a Notice at least a few days in advance (if 

possible) outlining the operation which the client will need to distribute to foreseeable 

person that might be affected. Once the UAS is ready for takeoff, the ground station will be 

clearly marked with orange cones and a good sized sign noting the exact procedure in place 

and creating a chance for people to avoid the area if they do not wish to be caught on the 

film. This type of procedure can be equated with a movie production in a public area where 

people are notified in the same manner in order to have the option to avoid the area 

altogether. 

When the UAS is rising up into its flight the main focus of the camera is the land /

building itself, if there are faces of persons who did not provide consent to be filmed which 

are caught in the frame, following proper protocol Rescue Training, Inc. will use specifically 

designated software to blur out the faces before turning the finished product over to a nongovernmental client.
20

CONCLUSION

For the reasons outlined above and with authority granted to the FAA by 14 C.F.R. §11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012, Rescue Training, Inc.

requests and Exemption to commercially operate the UAVs, without an airworthiness 

certificate for experimental uses. The proposed operations would permit the use of small 

and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; 

(2) predetermined; (3) controlled as to access; and that (4) provides an increased level of 

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

same purpose. The grant of this exemption will advance the public interest, provide an 

economic benefit to the public and allow Rescue Training, Inc. to develop new and 

innovative uses for UASs in a safe and compliant manner. The exemption would allow the 

petitioner to operate an unmanned aircraft system (UAS) to conduct safety training 

programs, research and development, and aerial inspections of buildings and land within 

the United States.

GLOSSARY /ABBREVIATIONS

UAS- Unmanned Aircraft System 

PIC- Pilot in Command 

FC-Flight Coordinator 

VC-Visual Controller 

VO-Visual Observer

GPS- Global Positioning System 

VLOS- Visual Line of Sight

Attachment 1: UAS Training Outline

Attachment 2: AMA Flight Safety Manual

Attachment 3: UAV Operation Manual

(a) DJI Phantom 2

(b) DJI Phantom 3

(c) DJI Inspire 1

(d) Yuneec Q500