August 7, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy, LLC (Airbotsy), a 

survey and aerial imagery acquisition firm, requests exemption from the following Federal Aviation 

Regulations (FARs) that are found under Title 14 of the Code of Federal Regulations (CFR): Part 21 

Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 

(a) (b), Part 91 Subpart E (91.401-91.417). Such exemptions would allow Airbotsy to commercially 

operate its Small Unmanned Aircraft Systems (“sUASs) to acquire aerial imagery for various industries 

with respect to the strict operation conditions outlined herein or as established by the FAA as required 

by Section 333. The value of sUASs would provide benefits to several industries and Airbotsy applies for 

exemption to allow operations to be conducted within Limited Access Area (LAA), which are areas that 

are sparse in population and/or where access is limited to personnel with jobsite clearance or private 

property. This will ensure that all persons near the sUAS operations will be given an operations and 

safety briefing of the planned sUAS operations and/or Airbotsy can effectively prohibit persons from 

entering the flight perimeter boundaries during the flight operations. Specific examples of LAAs are 

construction sites, open-pit mines, and private property boundaries.

Airbotsy plans to operate sUASs that are rotorcraft and fixed wing aircraft (see Appendix D), each 

weighing less than 55 pounds (including payload), at speeds less than or equal to 50 knots, and at or 

below 400 feet AGL (in full limitations of the FAA Form 7711-1 UAS COA). The sUASs are constructed out 

of lightweight materials such as foam and/or plastic, do not carry flammable materials, and will be 

operated by a highly qualified Pilot In Command (PIC). Given these operating limitations, Airbotsy is 

confident that operations will not create a hazard to users of the National Air Space (NAS) nor to the 

general public and that the operation guidelines herein meet the safety that the Congress envisioned 

that the FAA must, by exemption, allow commercial operation of sUAS. 
1. Company Background

Airbotsy, LLC. 

Jocelyn Javernick PH: 720-384-4272 Email: JocelynJavernick@gmail.com

1624 Market Street, Suite 202

Denver, CO 80202

Airbotsy is a female owned marketing company located in Denver, Colorado that provides digital 

marketing tools, strategies, services, and products to various industries. Airbotsy is comprised of 

highly experienced professionals and researchers and in regards to aviation, Airbotsy includes a 

private pilot with 11 years of experience. This background makes Airbotsy a strong competitor in 

the emerging commercial sUAS market and a prime candidate to receive an exemption for sUAS 

operations.

2. Statutory Authority for Exemptions

FAA Modernization and Reform Act of 2012, Section 333

Under Section 333(a), the FAA “shall determine if certain unmanned aircraft systems may 

operate safety in the national airspace system before completion of the plan and rulemaking 

required by Section 332”. Section 333 (b) of the Reform Act lists several factors that should be 

considered in determining which UAS could allowed to operate in the National Airspace System 

(NAS). Factors considered for UAS are “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 the users of the national airspace system or the public, or pose a threat to national 

security”. If a UAS satisfies Section 333 (b), Section 333 (c) states that the FAA can determine 

“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”. Therefore, if the FAA determines that UAS meets the criteria of Section 333 (b) and 

does not pose a hazard or threat to the public, NAS, and national security, then the FAA has the 

ability to allow a UAS to operate within the NAS without an airworthiness certification.

3. Meeting the Criteria of Section 333

The operation of sUASs by Airbotsy will meet all criteria specified in Section 333 (b) as described 

in the paragraphs below. 

3.a. Size, Weight, and Speed

All sUASs operated by Airbotsy will be constructed of strong, yet lightweight material 

allowing all rotorcraft and fixed wing aircraft to be well below a weight of 55 pounds 

(including payload). All sUASs will be flown at or below an altitude of 400 feet AGL and 

at speeds below 50 knots. All sUASs will be operated within the pilot’s visual line of 

sight, within 1 nautical mile, and in areas with limited access. Therefore, these small, 

lightweight, and slow moving sUASs pose minimal to no hazard to infrastructure or 
persons. Compared to traditional methods of acquiring aerial photographs, the use of 

sUASs offer a considerable risk reduction to aircraft that weigh thousands of pounds, 

carry people, and are powered by flammable materials. 

3.b. Operational Capability

The objective of Airbotsy is to provide our clients with high resolution images and videos

that can be utilized for marketing and analysis. While our initial targeted market will be 

real estate, we would like the opportunity to expand into construction, mining, 

agricultural, and surveying industries. Digital imagery data has a variety of uses and 

benefits to various industries, but the most compelling argument for allowing sUASs to 

capture such data is their ability to provide safe, cost efficient, and fast methods when 

compared to tradition acquisition methods and thus benefit the economy and the public

interest. Prior to any flight, the PIC will complete a pre-flight checklist (Appendix A) and 

all flights will be conducted with a specific flight protocol (Appendix B). All sUASs will be 

launched and landed on-site without the need for a runway, all flights will be conducted 

at or below an altitude of 400 feet AGL (as specified by the current ‘blanket’ COA), and 

within visual line of sight, and visual flight rules (VFR). Given the built-in safety of most 

operating sUASs and the extensive training required for all PICs (Appendix C), the safety 

of the aerial vehicle will provide a much safer option for aerial imaging and would pose a 

minimal hazard to the NAS or public.

3.c. Proximity to Airports/Populated Areas

All operations will be performed at considerable and safe distances to airports and 

populated areas. At a minimum, flights will be conducted 5 NM away from general 

aviation airports, at least 3 NM away from any populated area, and at an altitude of 400

feet AGL or less, which will prevent conflict with manned aircraft operations. Further, all 

operations will be conducted in LAA environments were all persons within the area of 

interest will have explicit information of the flight operations date, time, duration and 

thus operations will not pose a threat to individuals or structures on the ground and will 

remain well clear of any and all air traffic.

3.d. Visual Line of Sight (VLOS)

The sUASs will be flown in accordance with day Visual Flight Rules (VFR) and only in 

Visual Meteorological Conditions (VMC) during day-light hours. Flights will operate 

within 1 NM and VLOS of the PIC, at an altitude 400 feet AGL or less, and will include a 

safety Visual Observer (VO).

4. Equivalent Level of Safety

The applicant proposes that exemption be granted to our sUAS operations that have the 

characteristics and that operate with the limitations listed herein. These limitations provide an 

equivalent or higher level of safety to operations under the current regulatory structure that 

already operates safe protocols followed by helicopters and conventional aircraft with the 
purpose of acquiring aerial imagery and survey data. Therefore, Airbotsy sUAS flights will be 

limited to the operations described in Appendix B. 

5. Basis for Petition

5.a. Name and Address of the Petitioner

Airbotsy, LLC

1624 Market Street, Suite 202

Denver, CO 80202

5.b. Specific Sections of 14 CFR from which Airbotsy seeks the following exemptions:

o 14 CFR Part 21

o 14 CFR 45.23 (b)

o 14 CFR 63.113 (a) & (b)

o 14 CFR 91.7 (a)

o 14 CFR 91.9 (b)

o 14 CFR 91.103

o 14 CFR 91.109

o 14 CFR 91.119

o 14 CFR 91.121

o 14 CFR 91.151 (a)

o 14 CFR 91.203 (a) & (b)

o 14 CFR 91.405

o 14 CFR Part 91 Subpart E (91.401-91.417)

5.b.1. 14 CFR Part 21 Subpart H: Airworthiness Certificates 14 C.F.R §91.203(a)(1)

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate (FAR §91.203 (a) (1)). The applicant requests exemption from Part 21 

Subpart H pursuant with Section 333 given the size, and operational capability 

(Limited Area Access described above), proximity to airports and populated areas, 

and VLOS operations with which Airbotsy will operate sUASs. An equal level of 

safety will be achieved with the operational limitations established in this document 

(Appendix B) for all Airbotsy flights. Specifically, our sUASs flights will occur within 

VLOS of the PIC, at an altitude of 400 feet AGL or less, and only over designated 

LAAs. Further, coupling our pilots experience in the NAS and with the UAS required 

training (described in Appendix C) will ensure safely operations without creating a 

hazard to any other aircraft, people, or structures on the ground and thus offers a

safer alternative for aerial imagery collection.

5.b.2. 14 CFR 45.23 (b): Marking Requirements

45.23 (b) requires certain aircraft to display the roman capital letter “N” with 

registration number and the words “restricted”, “light­sport”, “experimental”, or 

“provisional”, as applicable, on the entrance to the cabin, cockpit, or pilot station in 
lettering that is between 2 inches and 6 inches in height. The sUASs operated by 

Airbotsy are unmanned and have no cabin, cockpit, pilot station, or entrance to

which these required markings could be displayed. In addition, Airbotsy may not 

have a registration number assigned by the FAA, and therefore seeks full exemption 

from this regulation. However, Airbotsy proposes to comply with 45.29 (f) by placing 

the word “EXPERIMENTAL” in the largest possible lettering on top of the aircrafts 

fuselage. To ensure an equal or greater level of safety, Airbotsy also proposes to 

place a flag at the ground control station with the words “EXPERIMENTAL UAS” in 3 

inch lettering. Together, the flag and sUAS marked as “EXPERIMENTAL” will serve to 

inform all persons within visual distance that UAS’ status and operations.

5.b.3. 14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

However, since the sUASs will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by 

requiring the pilot operating the aircraft to hold an airline transport, commercial, 

private, recreational, or sport pilot certificate and to have completed the sUAS flight 

training described in Appendix C (Note: These pilot requirements for UAS operation 

are granted in Exemption No. 12326). When comparing the knowledge 

requirements of a private pilot compared to a commercial pilot (Table C1), the 

results show that “required areas of knowledge for a commercial versus private 

pilot cover the same fundamental principles” and the “experience obtained beyond 

a private pilot certificate in pursuit of a commercial pilot certificate in manned flight 

does not necessarily aid a pilot in the operational environment proposed” 

(Exemption No. 11062). Further, the risk associated with manned commercial flights 

discussed in Part 61 will be decreased with sUAS operations since no pilot or

passengers are on board, operations will be in limited to controlled and restricted

areas, and all flights will be planned and coordinated in advance as set forth in the 

Appendix A and B. 

5.b.4. 14 CFR 91.7 (a): Civil Aircraft Airworthiness

Regulation 91.7 (a) states “no person may operate a civil aircraft unless it is in an 

airworthy condition”. Assuming that Airbotsy is approved exemption for 

airworthiness certification requested in Section 5.b.1, no FAA standard will exist for 

determining airworthiness. Therefore, Airbotsy seeks full exemption from this 

regulation. To achieve an equal level of safety, prior to each flight Airbotsy will 

perform the pre-flight protocol and safety checks described in Appendix A as well as 

follow all comprehensive maintenance procedures established by the specific sUAS 

manufacturer. 
5.b.5. 14 CFR 91.9 (b): Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a current 

approved flight manual for the aircraft onboard. Since the sUASs utilized are small 

and lightweight, it is not physically capable of carrying an aircraft flight manual 

onboard. Given the sUAS is an unmanned aircraft with the PIC located at the ground 

control station, accessing such documents would be impossible during a flight. 

Therefore, Airbotsy requests exemption from the requirement to carry the aircraft 

flight manual onboard. To provide an equivalent level of safety, Airbotsy proposes 

to keep the sUASs manufactures’ flight manual at the ground station and thus 

allowing the PIC immediate access. The FAA has issued several exemptions to this 

regulation and include: Exemption Nos. 8737,8738, 9299, 9299A, 9565, 9565B, 

10167, 10167A, 10602, 32827, and 10700.

5.b.6. 14 CFR 91.103: Preflight Action

Regulation 91.103 requires that the PIC be familiar with specific information before 

each flight such as weather, forecast, and fuel requirements to ensure the safety of 

flight. Further, the PIC must be familiar with the information of the approved flight 

manual relating to aircraft performance and take-off and landing distances. Since 

the operated sUASs will not have fuel or a FAA-approved flight manual, Airbotsy

requests exemption from this regulation. To achieve an equal level of safety, 

Airbotsy will perform the pre-flight actions listed in Appendix A including checking 

for weather conditions, checking flight battery requirements, checking takeoff and 

landing distances, and all other actions listed.

5.b.7. 14 CFR 91.109: Flight Instruction

Section 91.109 states that “no person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls”. Since all 

sUASs will be piloted remotely and do not have dual controls, Airbotsy requests 

exemption from this regulation. An equivalent level of safety can be achieved since 

pilot and passengers are not aboard the aircraft and thus the lack of dual controls 

does not pose a safety hazard. Further, the remote ‘controls’ can be passed back 

and forth between the Instructor and the Student, which will essentially provide the 

same functionality as having dual controls. Examples of exemptions the FAA has 

previously approved for aircraft without fully functional dual controls include: 

Exemption Nos. 5778K & 9862A. 

5.b.8. 14 CFR 91.119: Minimum Safe Altitude

91.119 establishes safe minimum altitude to operate civil aircraft. Section 91.119 (c) 

specifically states that over “other than congested areas” a civil aircraft cannot 

operate below an “altitude of 500 feet above the surface, except over open water or 

sparsely populated areas in those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure.” Section 91.119 (d) allows 
helicopters to be operated at less than the minimums prescribed, if the PIC of the 

helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. The functions of the Airbotsy’s sUASs will be to fly at low altitudes over LAAs

that can be described as “other than congested areas.” All flight operations will be 

flown at altitudes of 400 feet AGL or less, within close proximity to the PIC to 

maintain visual line of sight (VLOS). Therefore, Airbotsy requests exemption from 

this regulation. An equivalent level of safety will be maintained by only operating 

sUASs over areas that meet our definition of Limited Access Areas, which meet the 

criteria of “other than congested areas.” Given the small size and lightweight 

airframes of sUASs, these alternative aerial platforms offer a significant risk 

reduction to persons and structures on the ground than a manned aircraft providing 

the same service. Further, by operating the sUASs at or below 400 feet AGL, 

Airbotsy will ensure that conflicts will be avoided between manned aircraft that are 

subject to the minimum safe altitude regulation of 91.119 and thus provide an equal 

or greater level of safety.

5.b.9. 14 CFR 91.121: Altimeter Settings

Regulation 91.121 requires aircraft to maintain cruising altitude by reference to a 

current reported altimeter that is set "... to the elevation of the departure airport or 

an appropriate altimeter setting available before departure." Since the sUASs 

operated may not have a barometric altimeter, Airbotsy requests exemption from 

this regulation. However, all sUASs operated by Airbotsy will be equipped with GPS 

that will provide both an initial altitude of the launch site prior to flight operations 

as well as real time GPS altitude readings during the flight that are visible to the PIC, 

which will ensure that flights at and below 400 feet AGL. Prior to any flight, a 

separate handheld barometer will be utilized to check that the GPS altitude

accuracy is within a tolerable range. This will ensure a level of safety equal to the 

regulation 91.121. Further details about Airbotsy’s altitude can be found in the preflight operations of Appendix A, and the flight protocol of Appendix B.

5.b.10. 14 CFR 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Regulation 91.151 (a) outlines fuel requirements for flights in VFR conditions and 

states that no person may begin a flight in Day VFR conditions unless there is 

enough fuel to fly to the intended landing point and fly for 30 minutes after that 

point is reached. Since the operated sUASs are battery operated and will not carry 

fuel, Airbotsy requests an exemption from 91.151 (a). Since most sUASs batteries 

will be exhausted after flights between 20 to 45 minutes (depending on the sUAS 

model), a 30 minute reserve would leave minimal, if any, operational flight time. 

Instead, Airbotsy proposes to operate its sUASs until the battery reaches 20% of its 

power (as determined by the onboard monitoring system and the PIC). Such an 

operation guideline will ensure that the sUASs will have plenty of battery to return 

to the launch site safely; however, one major advantage of a sUAS is that unlike 
manned aircraft it can easily and safely land anywhere over a Limited Access Areas 

in which its operations are limited to. Similar exemptions have been granted to 

other operations, including Exemptions 2689F, 5745,10673, and 10808.

5.b.11. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

Regulation 91.203 requires all civil aircraft to have within “...an appropriate and 

current airworthiness certificate” which must be “displayed at the cabin or cockpit 

entrance so that is legible to passengers or crew.” As requested in Section 5.b.1, 

Airbotsy is already seeking exemption from the airworthiness certificate regulation 

and thus requires an exemption from this regulation. Further, since the small size 

and design of sUASs do not provide cabin or cockpit, there is no ability to carry 

passengers or certification and registration documents. To provide an equal level of 

safety, Airbotsy proposes keep these documents at the ground flight control point 

where the PIC will have immediate access, to the extent they are applicable to the 

sUAS. Numerous exemptions to this regulation have been granted and include: 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

5.b.12. Part 91 Subpart E (91.401-91.417): Maintenance, Preventative Maintenance 

and Alterations

These regulations outline the requirements for maintenance and inspections in 

reference to Part 39 and Part 43. 91.405 (a), which states that “no person may 

perform maintenance, preventive maintenance, and alterations on an aircraft other 

than as prescribed in this subpart and other applicable regulations, including part 43 

of this chapter.” Since these sections apply to only aircraft with an airworthiness 

certificate, for which Airbotsy has applied for exemption (Section 5.b.1), Airbotsy

also seeks full exemption from these regulations. Prior to any flight, the PIC will be 

responsible for conducting pre-flight inspections and will following all inspection 

requirements specified by the manufacturer of the utilized sUAS. Further details can 

be found in Appendix A.

Preventative maintenance and corrective maintenance will be conducted by the 

manufacture if so stated by the manufactures’ guidelines. However, in instances 

that the manufacture does not require maintenance to be performed by the 

manufacturer, then the PIC will be responsible for conducting maintenance in 

accordance with the manufactures procedures and all maintenance performed by 

the PIC and/or manufacturer will be documented in accordance with 91.407 (a) (1). 

Specifically, records will include “a description of the work performed; and the date 

of completion of the work performed; and the signature of the person approving 

the aircraft for return to service.” Further, Airbotsy will ensure that no modifications 

or alterations are made to the airframe that affects the flight operating 

characteristics of the sUAS. These proposals are considered to be an equivalent level 

of safety since these sUASs are very limited in size and will carry a small payload and 
operate only in restricted areas for limited periods of time. In the event that 

mechanical issues arise, the sUAS can land immediately and will be operating from 

no higher than 400 feet AGL. 

6. Benefits to the Public

Approval of the above exemptions and commercial operation of sUASs by Airbotsy will benefit 

the public in the following four ways.

1) The commercial use of sUASs to acquire aerial photographs will reduce the need for manned 

aircraft operating in the NAS. With the skies of America becoming busier and Air Traffic 

Control (ATC) workloads overburdened, the use of sUASs will offer some relief to ATC since 

coordination during ground, take-off, departure, transit, arrival, and landing phases of flights 

is not necessary.

2) Reduced manned aircraft will reduce air and noise pollution. Since all sUASs operated by 

Airbotsy will be lightweight and battery powered, these sUASs electric motors operate much 

quieter than manned aircraft and do not burn fossil fuels. Typically, aerial photography is 

captured by twin engine fixed wing aircrafts that burn between 20 to 30 gallons of fuel per 

hour and can require significant travel time before reaching the intended area of interest. 

However, acquiring aerial imaging with sUASs can take off and land on site and would 

greatly reduce both air pollution and noise pollution which is of great benefit to the public.

3) Operating sUASs for the purpose of aerial photography also reduces the risk to life and 

property on the ground. When compared to a twin engine airplanes, sUASs’ size, weight, 

slow speed, and lack of flammable liquids are considerably less dangerous to people and/or 

structures on the ground.

4) Operations of sUASs offer an effective, affordable, and safe method to acquire aerial 

photography to many business industries such as mining, construction, and agriculture. Such 

cost efficiencies and improved knowledge from available data will result in greater business 

efficiency and thus the potential for economic growth for such industries. These highresolution imagery data generated from sUAS flights can help mines and construction sites 

monitor progress, plan and design future improvements/work, and aid in site surveys in 

both two-dimensional maps and three-dimensional terrain models. Further, farmers and 

scientists can use this aerial data to estimate biomass, yield monitoring, leaf area indexing, 

and overall crop health. In all, this data will provide the information necessary for 

businesses of today to thrive in the future and thus in the publics’ interest. 

7. Summary for Federal Register

Pursuant to with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy LLC 

requests exemption from the following Federal Aviation Regulations that are found under Title 

14 of the Code of Federal Regulations: Part 21 Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 

(b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401-91.417). 

Exemption from these regulations would allow Airbotsy, LLC to operate small unmanned vehicle 

(of 55 pounds or less) in areas with limited and controlled access for the purpose of providing 

high-resolution aerial imagery and video.
APPENDIX A: Pre-flight protocol

This section is divided into two areas of i) 24 hours prior to flight and ii) an immediate pre-flight 

inspection checklist.

1) 24 hours prior to flight:

 Prior to a sUAS flight, an area of operation will be established. This area of operation will 

include a defined lateral and vertical area, where the sUAS will operate. Safety procedures 

will be established for persons, property, and applicable airspace within the area of 

operation.

 Flights will be operated within line of sight of the PIC and Visual Observer.

 The sUAS will weigh less than 55 lbs total. 

 Flights will be operated in Class G airspace whenever possible. lf 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.

 Flight planning will include flight completion with at least 20% battery power remaining as 

measured by the sUAS or appropriate timing.

 lf equipped, and appropriate for the operation, sUAS aircraft will utilize GPS navigation, 

failsafe, return-to-home (RTH) and/or flight abort safety features.

 A briefing will be conducted in regard to the planned sUAS operations prior to operation at 

each new location. All personnel who will be performing duties within the boundaries of the 

area of operation will be present for this briefing. Therefore, images taken will be of 

individuals who have also consented to being photographed or otherwise have agreed to be 

in the area where aerial photography will take place.

 All required permissions and permits will be obtained from appropriate state, county or city 

jurisdictions, including local law enforcement, fire, or others appropriate governmental 

agencies.

 Written, to include electronic, and/or oral permission from the relevant property owners 

will be obtained prior to an operation.

 All employees working on-site will be thoroughly briefed on sUAS operations prior to 

operations commencing
2) Pre-flight inspection checklist

The pre-flight checklist/inspection will follow the specific pattern and sequence before each 

flight. 

A. Ground station setup:

I. Place the “EXPERIMENTAL” flag near the area of PIC

II. Visually scan the area of operation for any unforeseen hazards, persons, or 

infrastructure

III. Check that all relevant documents are on site and within easy access. These include:

i. PIC’s pilot license and medical certificate

ii. Proof of company’s FAA exemptions

iii. sUAS manufacturer’s flight manual

iv. All maintenance records

B. Pre-start sUAS inspection checklist

I. Check to ensure the sUAS power is “OFF”

II. Battery

i. Check sUAS batter is fully charged

ii. Check the hand-held controller’s battery is fully charged

III. Visually inspect the following

i. All propeller blades are free of damages

ii. All propeller blades are securely attached to the sUAS

iii. All surfaces are free from damages

iv. Antenna is undamaged

C. Pre-flight inspection checklist

I. Turn on the controller and sUAS battery

i. Ensure that all available system read-outs are clearly displayed on the 

controller and within normal range

ii. Test the functionality and free movement of:

1. Propulsion blade(s)

2. Ailerons (if applicable)

3. Check the GPS altitude reading of the sUAS is within range of a 

separate hand held barometer. 

II. Test flight

i. Prior to flying the sUAS for commercial purposes, the aircraft must 

successfully demonstrate a successful flight of approximately one minute in 

duration, in a small area free from any hazards, persons, and property and 

at an elevation at or below 10 feet AGL.
APPENDIX B: Flight protocol

Safety is the first and foremost concern of Airbotsy. Therefore, the following outlines the 

limitations and conditions which will govern all commercial operations conducted by Airbotsy

PIC in lieu of the approved FAA exemptions and all aircraft will be limited to the specifications of 

Appendix D.

 The sUAS will be less than 55 pounds (including payload)

 All sUAS flights will be piloted by an FAA licensed airman with an airline transport, 

commercial, private, recreational, or sport pilot certificate and who will have completed the 

training outlined in Appendix C.

 The sUAS FAA licensed airman will be considered Pilot in Command (PlC), whether flying or 

supervising, and will be responsible for safe operation of the flight.

 The sUAS will operate at or below 400 feet AGL

 No flight will be conducted if wind speeds are in excess of 20 mph.

 The sUAS will operate within 1 NM and within visual line of sight (VLOS) of the PIC

 The duration of each flight shall not exceed 20% of the sUAS battery’s power or a maximum 

total flight time of 30 minutes, whichever occurs first.

 All take-off and landings will occur on-site in accordance with the specifications of the sUAS 

manufacture’s User Manual

 Flights will avoid direct overflight of any office or maintenance buildings located on-site

 Flights will be cancelled in the event that any aircraft or ground control station equipment is 

inoperative or not fully functional

 Flights will be operated under visibility and cloud clearance requirements equivalent to 

Visual Flight Rules (VFR) and only in Visual Meteorological Conditions during daylight hours

 If the PIC or Visual Observer identifies a potential hazard, such as a manned aircraft within 

close proximity to the designated flight area, the PIC will immediately land the sUAS and 

operations will only resume after the hazard is clear of the area

 Only one sUAS will be airborne at any given time over a specific site, and at least 2NM away 

from any other sUAS operation.

 Minimum crew for each operation will consist of the sUAS PlC and a Visual Observer. 

 The sUAS PIC will establish a working relationship with a representative at the local FSDO 

with which to annually review safety procedures and other operations to further enhance 

safety.

 All operations will be confined to a Limited Access Area (LAA), which are areas that are 

sparse in population and/or where access is limited to personnel with jobsite clearance. This 

will ensure that all persons near the sUAS operations will be given an operations and safety 

briefing of the planned sUAS operations and/or Airbotsy can effectively prohibit persons 

from entering the flight perimeter boundaries during the flight operations.
APPENDIX C: Pilot training protocol

With safety the highest priority, proper UA flight training is imperative. In addition to extensive 

knowledge within the NAS, Airbotsy will require:

 The PIC must possess an airline transport, commercial, private, recreational, or sport pilot 

certificate, and a valid third-class medical certificate or state issued driver license in the case 

of a sport pilot certificate. 

 The PIC must have accumulated and logged a minimum of 200 flight cycles and 25 hours of 

total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar 

UAS type (single blade or multirotor).

 The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the 

make and model of UAS to be utilized for operations under the exemption and three takeoffs and landings in the preceding 90 days.

 The PIC will be trained in advance for the safe operation of the sUAS to be operated. This 

will include operation of the sUAS both in normal and emergency modes of operation, and 

will include familiarization with the operation manual (or similar) if published by the sUAS 

manufacturer. Training will also include types of maneuvers to be performed and the safe 

operation in relation to persons, property and applicable airspace.

 Further, the PIC must have also satisfied any additional qualifications/training/experience 

that are required by the sUASs manufacturer (i.e. flight operations and procedures manual). 

At this time, Airbotsy does not require pilots to hold a Commercial Pilot Certificate. As shown 

below in Table C1, the overall knowledge of a Private Pilot vs. a Commercial Pilot is sufficient for 

the flight maneuvers required for sUAS operations. 

Table C1: Private pilot vs. Commercial Pilot knowledge (Taken from Exemption No. 11062).

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

§ 61.125 Aeronautical knowledge. (a) General. A person 

who applies for a commercial pilot certificate must 

receive and log ground training... 

§ 61.105 Aeronautical knowledge. (a) General. A 

person who is applying for a private pilot certificate 

must receive and log ground training... 

(b) Aeronautical knowledge areas. (b) Aeronautical knowledge areas. 

(1) Applicable Federal Aviation Regulations of this 

chapter that relate to commercial pilot privileges, 

limitations, and flight operations; 

(1) Applicable Federal Aviation Regulations of this 

chapter that relate to private pilot privileges, 

limitations, and flight operations; 

(2) Accident reporting requirements of the National 

Transportation Safety Board; 

(2) Accident reporting requirements of the National 

Transportation Safety Board; 

(3) Basic aerodynamics and the principles of flight; (10) Principles of aerodynamics, powerplants, and 

aircraft systems; 

(4) Meteorology to include recognition of critical 

weather situations, windshear recognition and 

avoidance, and the use of aeronautical weather reports 

and forecasts; 

(6) Recognition of critical weather situations from the 

ground and in flight, windshear avoidance, and the 

procurement and use of aeronautical weather reports 

and forecasts; 
Table C1 continued.

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

(5) Safe and efficient operation of aircraft; 

(7) Safe and efficient operation of aircraft, including 

collision avoidance, and recognition and avoidance of 

wake turbulence; 

(6) Weight and balance computations; (9) Weight and balance computations; 

(7) Use of performance charts; (8) Effects of density altitude on takeoff and climb 

performance; 

(8) Significance and effects of exceeding aircraft 

performance limitations; 

**Related to other areas within the private 

requirements but not referenced specifically** 

(9) Use of aeronautical charts and a magnetic compass 

for pilotage and dead reckoning; 

(4) Use of aeronautical charts for VFR navigation using 

pilotage, dead reckoning, and navigation systems; 

(10) Use of air navigation facilities; 

(4) Use of aeronautical charts for VFR navigation using 

pilotage, dead reckoning, and navigation systems;

(5) Radio communication procedures; 

(11) Aeronautical decision making and judgment; (12) Aeronautical decision making and judgment; and 

(12) Principles and functions of aircraft systems; (10) Principles of aerodynamics, powerplants, and 

aircraft systems; 

(13) Maneuvers, procedures, and emergency operations 

appropriate to the aircraft; 

(7) Safe and efficient operation of aircraft, including 

collision avoidance, and recognition and avoidance of 

wake turbulence;

(11) Stall awareness, spin entry, spins, and spin recovery 

techniques for the airplane and glider category ratings; 

(14) Night and high-altitude operations; ** 

**Although not mentioned in § 61.105, 3 hours of night 

flight training is required for the private per § 61.107 

and § 61.109. For this comparison, high-altitude 

operations are considered not applicable.** 

(15) Procedures for operating within the National 

Airspace System; and 

(3) Use of the applicable portions of the “Aeronautical 

Information Manual” and FAA advisory circulars; (13) 

Preflight action that includes— (i) How to obtain 

information on runway lengths at airports of intended 

use, data on takeoff and landing distances, weather 

reports and forecasts, and fuel requirements; and (ii) 

How to plan for alternatives if the planned flight cannot 

be completed or delays are encountered. 

(16) Procedures for flight and ground training for lighterthan-air ratings. For this comparison (ASEL), these operations are 

considered not applicable.**  

§ 61.127 Flight proficiency. (a) General. A person who 

applies for a commercial pilot certificate must receive 

and log ground and flight training 

§ 61.107 Flight proficiency. (a) General. A person who 

applies for a private pilot certificate must receive and 

log ground and flight training 

(b) Areas of operation. (1) For an airplane category 

rating with a single-engine class rating: 

(b) Areas of operation. (1) For an airplane category 

rating with a single-engine class rating: 

(i) Preflight preparation; (i) Preflight preparation;
Table C1 continued. 

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

(ii) Preflight procedures; (ii) Preflight procedures; 

(iii) Airport and seaplane base operations; (iii) Airport and seaplane base operations; 

(iv) Takeoffs, landings, and go-arounds; (iv) Takeoffs, landings, and go-arounds; 

(v) Performance maneuvers; (v) Performance maneuvers; 

(vi) Ground reference maneuvers; (vi) Ground reference maneuvers; 

(vii) Navigation; (vii) Navigation; 

(viii) Slow flight and stalls; (viii) Slow flight and stalls; 

(ix) Emergency operations; (x) Emergency operations; 

(x) High-altitude operations; and **For this comparison, high-altitude operations are 

considered not applicable.** 

(xi) Postflight procedures. (xii) Postflight procedures. 

**Not referenced specifically** (ix) Basic instrument maneuvers; 

**Not referenced specifically** (xi) Night operations, except as provided in §61.110 of 

this part; and 
APPENDIX D: Utilized aircraft

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Airbotsy requests that the 

following four aircraft be considered for this exemption:

1. DJI Phantom 3 

a. Make: DJI

b. Model: Phantom 3

c. Type: Quadcopter

d. Maximum takeoff weight: DJI does not publish payload details for the Phantom 3. However, 

it has a total weight of 1280g (2.82 pounds) which includes the battery, propellers, camera 

and gimbal. The Phantom 3’s gimbal and camera are not removable, and doing so will void 

the UAS’s warranty; therefore, modification to allow additional or different payloads is not 

recommended by the manufacture. 

e. Airbotsy will utilize the Phantom 3 for video and aerial photography only in Limited Access 

Areas discussed in the exemption request (No. FAA-2015-1473). Airbotsy will not modify the 

aircraft’s payload or flight characteristics. 

f. The FAA has issued several exemptions for the similar DJI Phantom 2 and Phantom 2 Vision+ 

(e.g. No. 11398, 11310A, 11767), which are very similar as shown below in Table 1.

g. Aircraft manuals: http://www.dji.com/product/phantom-3/download

Table 1: Phantom 2 Vision+ compared to Phantom 3.

Item DJI Phantom 2 Vision Plus DJI Phantom 3

Weight (battery and 

propellers included) 1242 g 1280 g

Hover Accuracy

Vertical: 0.8 m

Horizontal: 2.5 m

Vertical: 0.1 - 0.5 m

Horizontal: 1.5 m

Max Ascent/Descent Speed Ascent: 6 m/s

Descent: 2 m/s

Ascent: 5 m/s

Descent: 3 m/s

Max Speed 15 m/s 16 m/s

Controlable range 1 km (0.6 miles) 2 km (1.2 miles)

Flight time ~25 minutes ~23 minutes
2. DJI S1000+

a. Make: DJI

b. Model: Spreading Wings S1000+

c. Type: Octocopter

d. Maximum takeoff weight: 11 kg (24.25 pounds), aircraft weight with 4.4 kg (9.7 pounds), 

and a payload up to 6.6 kg (14.55 pounds). 

e. Airbotsy will utilize the S1000+ to acquire high resolution aerial images, infrared remote 

sensing, and lidar. Such payload equipment varies in weight, but never exceeding a total 

aircraft weight of 11 kg (24.25 pounds).

f. The FAA has issued several exemptions for the DJI S1000+ (e.g. No. 11694, 11398, and 

11184) as well as UAS collection of lidar and infrared data collection (e.g. No. 11338).

g. Aircraft manuals: http://www.dji.com/product/spreading-wings-s1000-plus/download

3. Sensefly eBee Ag 

a. Make: SenseFly

b. Model: eBee Ag

c. Type: Fixed wing

d. Maximum takeoff weight: The published data specifies the aircraft weight with battery and 

camera is 1.53 pounds. Of this weight the camera (i.e. the maximum payload) is 0.33 lbs. 

e. Airbotsy will utilize the eBee Ag for agricultural monitoring and remote sensing and will not 

modify the payload with anything other than manufacture recommended accessories, and 

never exceeding a total takeoff weight greater than 1.53 pounds. 

f. The FAA has issued several exemptions for the eBee Ag (e.g. No. 11635, 11628, and 

11339).

g. Aircraft information: https://www.sensefly.com/fileadmin/user_upload/sensefly/

documents/brochures/eBee_Ag_en.pdf 

4. Sensefly eBee RTK

a. Make: SenseFly

b. Model: eBee, eBee RTK

c. Type: Fixed wing

d. Maximum takeoff weight: The published data specifies the aircraft weight with battery and 

camera is 1.61 pounds. Of this weight the camera (i.e. the maximum payload) is 0.33 lbs. 

e. Airbotsy will utilize the eBee RTK for any aerial imagery that requires survey grade 

georeferencing and will not modify the payload with anything other than manufacture 

recommended accessories, and never exceeding a total takeoff weight greater than 1.61 

pounds. 

f. The FAA has issued several exemptions for the eBee RTK (e.g. No. 11956, 11632, and 

11585).

g. Aircraft information: https://www.sensefly.com/fileadmin/user_upload/sensefly/

documents/brochures/eBee_RTK_en.pdf