Date: Aug 5th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Reuven M. Silberman, for an Exemption Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, Reuven M. Silberman ("RS") hereby applies for an exemption from the Federal Aviation 

Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial vehicles 

(UASs) for the purpose of conducting commercial flights for aerial education, research, maintenance and 

industry application training. 

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as but not limited to these accompanying RS documents; 

1. RS’s sUAS Flight Operations Manual and;

2. RS’s Operations Manuals"

3. RS’s sUAS Aircraft Flight Manual 

(collectively referred to as " RS' Operations Manuals")

4. RS-UAS User Guide and;

5. RS-UAS User Manual

(collectively referred to as "Manufacturer's Manual").

1

The RS submits these as well as other RS supporting materials as confidential documents pursuant 

to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or proprietary information 

that the RS has not and will not share with others. Additionally, these documents contain operating 

conditions and procedures that are not generally available to the public and are protected from release under 

the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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Page 2

This Petition is organized as follows:

I. Petitioner

II. Description of Proposed Operations

A. Aerial UAS Education, Research, Maintenance and Industry Applications

III. Relevant Statutory Authority

IV. RS’ Proposed UAS Operations Meet the Requirements of Section 333 of the Reform Act

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

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

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

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

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
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Page 3

I. DESCRIPTION OF PETITIONER

Reuven M. Silberman is a current and active FAA licensed Certified Flight & Instrument Instructor (CFII), 

Advanced Ground Instructor (AGI), and retired Air Traffic Controller with 25 years in the tower and flight 

service options. He also has over 5 years of experience as a ground school instructor teaching the Private, 

Instrument, and weather courses at the community college level. Mr. Silberman has excelled in many 

different areas of aviation studies in flight, ground, and air traffic operations. He has also the co-builder / 

owner of a Vans RV7A Experimental Aircraft. Mr. Silberman now finds himself in a unique place in his 

career where he can utilize his past experience as a flight and ground instructor, along with his background 

in air traffic operations, to assist the budding industry of commercial UAS operations. His company Aerial 

Robotics Education will focus on UAS training, maintenance and industry applications. Mr. Silberman is 

dedicated to providing UAS education and innovative job opportunities and solutions for students

interested in the safe operation of UAS’s in the National Airspace System (NAS). He will also 

specialize in being a professional Visual Observer (VO) to individuals and companies that have t heir 

own UAS flight departments in assisting them in the safe operation of their UAS’s. 

As the UAS / UAS industry is new, creating new training methods for the current and next generation of 

operators will be a complex task having Mr. Silberman wearing many hats as the principle researcher, 

director, and coordinator of the Aerial Robotics Education program. Along with a small staff, the team is

creating a unique method of educating students to ready them for the thousands of jobs that will be created 

as a result of the expediential growth of the UAS / UAS industry, and the hundreds of applications that will 

follow. As part of Mr. Silberman’s vision of providing new and innovative solutions for educating the next 

generation of operators Mr. Silberman will be pulling from his extensive experience as a flight instructor, as 

well as his background in flight operations, air traffic control, and professional teaching. Mr. Silberman

seeks an exemption to allow for the commercial operation of small UAS’s to facilitate research in aerial 

education, flight training, maintenance and industry applications.

The contact information for Petitioner is as follows:

Reuven M. Silberman 

CFI, ATC (retired) 

PO Box 713026 

Santee, CA 92072 

858-254-3848 

Pilots2@yahoo.com

II.DESCRIPTION OF PROPOSED OPERATION

RS seeks an exemption pursuant to Section 333 of the Reform Act to operate the DJI Phantom II, Phantom 

III, Inspire 1, S1000, S900, S800, UAS, (RS-UAS) for the proposed operations discussed below. All UAS

operations education, research and training will occur under tightly controlled conditions at locations where

RS has received permission to operate from the landowner that is more than five miles from any airport or 

other authorized representatives. Upon completion of Auburn University's Program, students will be 

provided with a Certificate of Completion. This "Certificate of Completion" does not permit the student to 

engage in commercial UAS activities that are not in accordance with the FARs, but U.S. Department of 

Transportation December 3, 2014 Page 4 rather, is intended to be an acknowledgement that the student has 

successfully demonstrated a complete understanding of UAS operations from a NAS perspective.
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Aug 5th, 2015

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The proposed UAS operations will be conducted in accordance with the conditions and limitations of 

this Petition for Exemption and RS’ Operations Manuals. As detailed in RS' Operations Manuals, all UAS

operations will be limited to daytime VFR conditions, within visual line-of-sight ("VLOS") of the operator

and Visual Observers (VO), in controlled or uncontrolled airspace, and will occur at least 5 nm away from 

an airport. Moreover, RS’ Operations Manuals incorporate redundant safeguards to assure that the aircraft 

does not travel outside the controlled area of UAS operations.

A. Aerial UAS Education, Research, Maintenance and Industry Applications 

RS seeks to use small UASs for the purpose of conducting aerial research in education for UAS flight 

training, maintenance and industry application study.

RS has tailored his operations to meet the requirements established by the FAA in prior grants of

exemptions authorizing commercial use of UAS in aerial research in education for UAS flight training, 

maintenance and industry application uses including:

 Auburn University Aviation Center, (Exemption No. 11304)

 Troy Built Models, (Exemption No. 11493)

 DART Drones, LLC, (Exemption No. 11625)

Aerial UAS education, research, maintenance and industry applications will be conducted on

approved property in a controlled area, away from spectators and persons not involved and will only be 

conducted during daylight hours, in VFR conditions, at altitudes below 400' AGL as set forth below. RS

operations will provide a superior level of safety and quality.

RS seeks to use small UAS for the purpose of conducting aerial research in education and for UAS

flight training, maintenance and industry applications. The growth of the small UAS industry will 

ultimately reduce the potential risk, physical harm, serious injury and death associated with manned aircraft 

that currently perform such tasks. Further, the use of traditional aircraft exposes participants and the public to 

the risk of dangerous low level aircraft operations. The use of small UASs mitigates these hazards and is 

ultimately a much safer method of performing these and most all applications where the need for aerial

operations are required.

Small UAS aerial research in education for UAS flight training, maintenance and industry application 

uses is much safer than the use of traditional manned aircraft performing the same function. Conventional 

operations using rotorcraft and fixed-wing aircraft in low level operations present risks associated with 

vehicles weighing thousands of pounds and carrying large amounts of fuel. It is important to note that the

use of small UASs in these types of operations will not only be safer and more cost effective, but the

quality of collected data and information is will be far superior. 
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Small UAS aerial research in education for UASs, flight training, maintenance and industry 

application uses are more reliable, and allows for the collection, dissemination, and storage of visual and 

other sensory data with greater precision and duration. Additionally, UASs are capable of accessing and

inspecting areas not accessible to full size aircraft and completing many potential high risk tasks that would 

otherwise be inaccessible to humans or cannot be completed using conventional aircraft.

III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in 

the National Airspace System ("NAS") where it is safe to do so based on the following considerations:

● The UAS's size, weight, speed and operational capability;

● Operation of the UAS in close proximity to airports and populated areas; and

● Operation of the UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from §§ 44701(a), (b) and; §§ 44702 – 44716, et seq.). A party requesting an

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. RS' PROPOSED UAS OPERATIONS MEET THE REQUIREMENTS OF SECTION 333

OF THE REFORM ACT

The small UAS operations proposed by RS in this Petition for Exemption qualify for expedited

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are

satisfied.

A. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational Capability

A Grant of Exemption is appropriate for operations conducted using the RS-UASs or other qualified

small UAS, based on previously granted FAA 333 granted exemptions listed in one of, if not multiples of 

the same categories having like size, weight, speed, and operational capabilities. For the purposes of this 

application the RS-UAS being used are a representation of small UAS’s that may be used. This application 

is intended for the commercial training and operation of any and all small qualifying small UAS’s that 

predate this application and have been listed in other FAA 333 Exemption Grants. 
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All RS-UAS used also must have an integrated GPS system that calculates the UAS's position and height 

and relays that information via a secure connection to the operator. Additionally, all RS-UAS must contain 

a failsafe mode if the flight connection to the remote control is lost, and this system permits all RS-UAS to 

return to a predetermined location and land without injury or damage. The use of the RS-UAS throughout 

this application is considered as a generic-specific UAS that meet and exceed all safety, weight and flight 

performance requirements of the DJI Phantom II, Phantom III, Inspire 1, S1000, S900, S800, identified as

(RS-UAS) herein. In no way are the RS-UAS to be exclusively limited to one manufacture or model of 

UAS other than in their approved flight and operations specifications to further include:

 The RS-UAS have been approved for use in prior Section 333 Grants of Exemption from the

FAA.

2

 The RS-UAS or previously approved UAS with weighs less than 55 pounds, including payload.

 The RS-UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UAS as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The UASs will have system redundancies and independent functionality to ensure the overall safety

and predictability of the system. If connection to the remote control or ground control station is 

lost, failsafe systems will permit the UAS to return to a predetermined location and safely land

without injury or damage.

 The radio frequencies used for operations and control of the UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the RS-UAS is 900 MHz, 2.4 GHz or 5.8 GHz frequency 

bands. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely exceed 

6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference in

weight between the RS-UAS and a helicopter significantly reduces the potential harm to the participating

and non- participating individuals or property in the event of an accident or incident. In addition, the risk to 

the onboard pilot and camera operator is eliminated.

 _______________________

2

See e.g., Grant of Exemption to Michael Baker International, LLC (Exemption No. 11711),

M2 Flight Solutions, LLC (Exemption No. 11519), BizUAS Corp, (Exemption No. 11351).
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B. Approval is Warranted Based on the Operational Restrictions Set Forth in RS’ Operations

Manuals

RS’ Operations Manuals and the Manufacturer's Manual for the selected UASs will contain all the 

procedures and limitations necessary to safely and successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of RS’ proposed operations, 

below is a summary of operational limitations and conditions that RS will adhere to, and which will ensure

an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The UAS weighs less than 55 pounds, fully loaded.

2. All operations shall be conducted over private or controlled-access property with permission from the land

owner, air traffic control or authorized representative. Permission from the land owner, air traffic control or 

authorized representative will be obtained prior to each flight operation.

3. All UASs operated under the Grant of Exemption will be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 14

4. CFR part 45, Subpart C. Markings will be as large as practicable.

5. Prior to each flight operation RS will obtain approval from the air traffic facility in which the operation is 

to be conducted. The request for approval will include the date, time, location, duration of flight, altitude, 

and a means to immediately contact the designated PIC. The request for approval can be by telephone, fax, 

email, or US Postal Service. A telephone call to the approving ATC facility will be made prior to the 

beginning of the operation and at the conclusion if requested by the controlling ATC facility. 

6. Minimum crew for each commercial flight operation will consist of a pilot who will be the physical 

operator of the UAS and a Visual Observer (VO) who is responsible for maintaining visual contact with the 

UAS and overseeing its safe operation. A VO is a required crew member when the UAS pilot is a principal 

videographer. The UAS pilot and VO will determine, before flight, who is Pilot in Command (PIC) of the 

operation. 

7. PIC shall possess at least a Private Pilot's Certificate and current Class III Medical Certificate. The PIC 

will also meet the flight review requirements specified in 14 C.F.R 61.56 in an aircraft in which the PIC is 

rated on his or her pilot certificate.

8. The UAS shall be operated within VLOS of the PIC or VO at all times. The PIC must use human vision 

unaided by any device other than corrective lenses, as specified on the PIC's FAA-issued medical 

certificate.

9. The PIC and VO designated for any operation will be able to communicate verbally at all times.
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10. Electronic messaging, texting, or personal telephone calls will not be permitted during flight operations.

11. The additional requirements identified in the Grant of Exemption shall be added to the RS’ Operations

Manuals. The Operations Manuals will be maintained and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and RS’

Operations Manuals, the conditions and limitations in the Grant of Exemption shall take precedence and 

must be followed. Otherwise, RS shall follow the procedures outlined in their Operations Manuals.

12. RS may update or revise its Operations Manuals. Revisions will be tracked and a revised copy of the Manual

will be provided to the Administrator upon request. RS will also present an updated and revised Operations

Manuals if he petitions for extension or amendment to its Grant of Exemption. If an update or revision 

would affect the basis upon which the FAA grants the exemption, RS will seek an amendment to its Grant 

of Exemption. RS will contact the FAA’s UAS Integration Office (AFS-80) if questions arise regarding

updates or revisions to the operating documents.

13. The Grant of Exemption will be available to the PIC at the ground control station anytime the UAS is

operating.

14. UAS operation is prohibited from beginning a UAS flight unless (considering wind and forecast weather 

conditions) there is enough power to fly to the first intended point of landing, and assuming normal 

cruising speed, to fly after that for at least 10 minutes.

15. Maximum total flight time for each operational flight using the RS-UAS will be limited to 40 minutes or 

the amount of time the UAS can be flown and still maintain a reserve battery power of no less than 25%, 

whichever occurs first.

16. Flights will be operated at an altitude of no more than 400 feet AGL and will not enter navigable controlled 

airspace without prior authorization and approval from the FAA. In the event the structure being inspected 

exceeds 400 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the 

structure, and no more than 50 feet horizontally from the structure.

17. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, 

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAS and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 500 feet of the UAS, 

flight operations must cease immediately and/or;
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b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a

safety assessment of the risk of operating closer to those objects and determined that it

does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, or essential persons do not present an undue hazard 

to those persons per § 91.119(a).

18. The RS-UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud

or when visibility is less than 3 statute miles from the PIC. These weather minimums apply to fixed wing 

aircraft RS-UAS and have been identified in other sections herein. However rotor wing type RS-UAS will 

comply with Helo weather minimums. See FAR 91.155 (b) (1).

19. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart without prior permission of the controlling agency. 

20. Prior to each flight the PIC shall inspect the UAS to confirm that it is in a condition safe for flight. The

pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or equipment, 

not already covered in the relevant sections of the operating documents. The PIC shall not operate the UAS

if the inspection reveals a condition that affects the safe operation of the UAS until the necessary

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

control station shall be included in the preflight inspection. All maintenance and alternations must be 

properly documented in the UAS records as required by RS’ Operations Manuals.

21. RS students will learn to will carry out pre-flights, maintenance, inspections, and record keeping 

requirements in accordance with the Operations Manuals. Maintenance, inspection, and alterations will be 

noted in the UAS records, including total time in service, description of work accomplished, and the 

signature of the person returning the UAS to service.

22. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight

characteristics (e.g., replacement of a flight critical component) must undergo a functional test flight in

accordance with RS Operations Manuals. The PIC who conductsthe functional test flight must make an

entry in the UAS aircraft records of the flight. The requirements and proceduresfor a functional test flight

and UAS record entry shall be included in the RS’ Operations Manuals.

23. The UAS will be operated and maintained according to the Manufacturer's Manuals and any required

manufacturer Safety/Service Bulletins.

24. Prior to the operation, a Mission Packet will be created in accordance with the requirements on RS’ 

Operations Manuals.
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25. RS will learn how to obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

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

and potential transponder requirements.

26. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire or other appropriate governmental agencies.

27. If the UAS loses communication with the pilot, it will have the capability to return to a pre-determined 

location within the operational area and land safely.

28. Contingency plans will be in place to safely terminate flight if there is a loss of communication between the 

PIC and the Observer.

29. The UAS will have the capability to safely abort flight in the case of unpredicted obstacles or emergencies.

30. The designated PIC will have at least a current Class II Medical Certificate or valid state drive’s license.

31. A student PIC learning to perform aerial motion picture and television filming will prior to conducting

commercial film flight operations, will have accumulated and logged in a manner consistent with 14 CFR § 

61.51(b), a minimum of 200 flight cycles and 25 hours total time performed as a non-aerial motion picture 

and television filming PIC.

32. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special Visual Flight 

Rules ("SVFR") shall not be conducted.

33. The UAS shall remain clear and yield the right of way to all other manned operations and activities at all 

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.).

34. UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

35. The UAS will not be operated from an elevated platform or moving device / vehicle.

36. Before conducting operations, the radio frequency spectrum used for operation and control of the UA will

comply with the Federal Communications Commission (FCC) or other appropriate government oversight

agency requirements.
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V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3

RS seeks an exemption from several interrelated provisions of Title 14 of the Code of Federal 

Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes of conducting the requested operations using a

UAS. Listed below are: (1) the specific sections of 14 C.F.R for which exemption is sought, and (2) the 

operating procedures and safeguards that Petitioner has established which will ensure a level of safety better 

than or equal to the rules from which exemption is sought.

4

______________________________________

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

The reasons why granting the exemption would not adversely affect safety, or how the exemption

would provide a level of safety at least equal to that provided by the rule from which you seek

exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

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

Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally

used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, however, 

the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements 

of the Reform Act, an exemption is requested.

Equivalent Level of Safety

RS’ use of the RS-UAS or any qualifying small RS-UAS is safe when taking into account their size, 

weight, speed, and operational capability. As set forth in the description of proposed operations in 

Section IV (A), qualifying RS-UAS’s weighs less than 55 pounds, including payload and will not be 

flown at a ground speed in excess of 50 knots. The RS-UAS is also equipped with safety features that 

will allow Petitioner to operate the UAS safely after experience certain in-flight contingencies or

failures.

67

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [DJI S1000] has the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. The

UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link event with a 

pre-coordinated, predictable, automated flight maneuver, and manual flight control functionality as

a backup. These safety features provide an equivalent level of safety compared to a manned aircraft 

performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The RS-UAS standard aircraft and RS-UASs with upgrades can be operated entirely by a touchscreen, map-based interface. This means the operator only needs to command the system where to

go, and the system does all the flying for the operator. The RS-UAS can be operated in both semi and

fully autonomousflight modes In addition, RS-UAS standard aircraft and RS-UASs with upgrades 

comes with pre-programmed no fly zones so the UAS cannot enter areas deemed unsafe or

unnecessary to fly over. The petitioner states further that the UAS has built-in intelligent fault handling

which allowsthe RS-UAS to detect a system fault while in the air and automatically fly back to its

takeoff location and land. Faults that can be detected include: loss of communication; exceeding preset wind thresholds; and low battery levels.

{footnote continued}
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Page 13

Additionally, the UASs carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in RS's Operations Manuals.

Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area

of operation. RS will also provide the FAA with advance notice of all operations via NOTAMs where

required by the applicable COA. In all cases, the operation of small UAS’s under the proposed conditions 

will be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the UASs do not need a means to communicate with other aircraft or ATC, because those

capabilities will be possessed by the PIC and VO, who are not onboard the UAS.

8 In addition, no senseand-avoid technology is necessary for the UASs because they will be operated at all times in VFR 

conditions and within VLOS of the designated PIC.

9

 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent that RS's small UASs would otherwise require certification under Part 

27, Petitioner seeks an exemption from Part 27's airworthiness standards for the same reasons identified in 

the request for exemption from 14 C.F.R. Part 21, Subpart H, supra.

________________________

{continued from previous page}

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. The flight controlsystem employs not only GPS positioning but

a variety ofsensorsincluding sonar, barometric pressure, temperature, wind speed and othersto ensure

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly

away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. airworthiness standards for the same reasons identified in the request for exemption from 14

C.F.R. Part 21, Subpart H, supra.
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Page 14

 C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

RS seeks an exemption from the aircraft marking and identification requirements contained in 14 

C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

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

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All UAS flown by RS will bear N-number markings that are as large as practicable in accordance

with 14 C.F.R. Part 45, Subpart C.

11

10FAA Docket No. FAA-2014-0352.

11See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
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Aug 5th, 2015

Page 15

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

Inspections

RS seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by RS’ Operations Manuals, the PIC will conduct a pre-flight inspection of the UAS and

all associated equipment to account for all discrepancies and/or inoperable components. Maintenance will be

performed and verified to address any conditions potentially affecting safe operation of the UAS and no 

flights will occur unless, and until, all flight critical components of the UAS have been found to be airworthy

and in a condition safe for operation. A functional test flight will be conducted following the

replacement of any flight-critical components. As required by RS’ Operations Manuals, the PIC who 

conducts the functional test flight will make an entry in the UAS’s aircraft records of the flight.

RS’ Operations Manual also includes requirements to follow the manufacturer’s UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, RS’ Operations Manuals also includes 

procedures to document and maintain a record of the UASs maintenance, preventative maintenance,

alterations, status of replacement /overhaul component parts, and the total time in service of the UASs used 

under this Grant of Exemption. As a whole, the maintenance and inspection procedures required in RS’

Operations Manuals ensure that an equivalent or higher level of safety will be achieved.
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Aug 5th, 2015

Page 16

PILOT-IN-COMMAND OF THE UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

RS seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from 

flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for

hire. In this case, while the UAS will be operated as part of a commercial operation, it carries neither

passengers nor cargo. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when UAS operations are involved.

Equivalent Level of Safety

The restrictions RS has placed on its UAS operations meet or exceed the restrictions similarly

imposed on Astraeus Aerial. RS will operate on private property away from persons and property not

involved in the operation. RS will also obtain an ATO issued COA prior to conducting any operations under 

this Grant of Exemption. All operations will be conducted in accordance with airspace requirements in the 

ATO issued COA including class of airspace, altitude level and potential transponder requirements. A 

NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, RS will further ensure safe operation by requiring that any PIC 

be thoroughly versed not only in airspace and communication issues pertaining to all aircraft operators but 

also in the unique aspects of UAS flight. As set forth in the Operations Manuals, pilots will have experience

not only in UAS operations generally but have logged flight time in the specific make and model used for the 

operations before they are permitted to participate in commercial flights on behalf of RS. The pilot 

qualification, training, and currency requirements in the Operations Manuals ensure that RS’ pilots are 

competent and proficient in the UAS they are operating. RS’ training and qualification requirements are 

consistent with those contained in prior FAA Section 333 Grants of Exemption, and will provide a higher

level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety.

__________________

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Aug 5th, 2015

Page 17

OPERATING PARAMETERS OF THE UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the UAS, RS seeks an exemption from 

14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be operated. The FAA 

has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part

21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the requirements for § 91.7(a) 

be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

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

manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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...

(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.

 ____________________

13See id. at 13-14, 22 
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Aug 5th, 2015

Page 18

Given the popularity, small size and configuration of UASs, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the UAS because there is simply no room and 

the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the UAS flight manual, registration certificate, 

and other required documents from the ground control station from which he or she is operating the 

aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be

achieved by ensuring that the PIC has access to the documents at the ground control station from which he

or she is operating the UAS.

H. 14 C.F.R. § 91.103: Preflight Action

RS seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with 

specific information before each flight, including information contained in the FAA-approved Flight 

Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the RS’ Operations Manuals and the 

Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any defects or 

inoperable components in accordance with the RS’ Operations Manuals, including checklists covering PreFlight, Launch, Landing, and Post-Flight procedures. The PIC will also be required to review weather,

flight requirements, battery charge, landing and takeoff distance, the UAS performance data, and

contingency landing areas—before initiation of flight. RS’ Operations Manuals and the Manufacturer's 

Manual will be kept at the ground control station and will be accessible to the PIC at all times while

operating the UAS.

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

 _________________

14Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
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Page 19

RS seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[no]

person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." UASs and remotely piloted aircraft, by their design, 

do not have functional dual controls. Instead, flight control is accomplished through the use of a device

that communicates with the aircraft via radio communications. Accordingly, an exemption will be required

for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the UASs that RS intends to use, an equivalent level of safe training can 

still be performed without dual controls because no pilot or passengers are aboard the UAS, and as required 

by the RS’s Operations Manuals, all persons will be a safe distance away in the event that the UAS

experiences any difficulties during flight instruction. Moreover, as required by the RS’s Operations Manuals, 

all flight training will be conducted in controlled and sterile environment. As a whole, the safety procedures 

provided for in RS’s Operations Manuals ensure that the proposed UAS operations provide an equivalent or 

higher level of safety than that provided by the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

RS requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119(c).

15 

Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 

feet above the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 

C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those minimum altitudes 

when it can be operated "without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the

FAA."

An exemption is required because the proposed UAS operations will normally need to occur below 

400 feet AGL. In circumstances where the UAS is used to inspect a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 100 feet above the highest point on the structure, and within 

50 feet horizontally of the structure. Additionally, due the nature of the proposed operations, the Pilot and/or

Observers(s) may need to be less than 500 feet away from the UAS.

___________________

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed UAS operations will not occur over congested areas, and therefore an exemption from § 91.119(b)

will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a tree Aerial 

(FAA-2014-0534 at 15)
U.S. Department of Transportation

Aug 5th, 2015

Page 20

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the UASs, any risk associated with these operations is far 

less than those that presently exist with conventional aircraft. An equivalent level of safety will be achieved

given the size, weight, and speed of the UASs, as well the controlled location where the operations will 

occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 feet AGL or 

below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet above the highest 

point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the UASs will be operated in a restricted area, and all flights 

will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that person 

is in a position where he or she is shielded from the UAS and any possible debris resulting from UAS failure. 

As required by the Operations Manuals, flights will be terminated if a nonparticipating person within 500 feet 

of the UAS leaves a shielded position. Further, UAS operations will occur at least 500 feet away from 

vehicles or structures unless the property owner/controller has granted permission and the PIC has made a

safety assessment of the risk of operating closer to those objects and, operations near the PIC or VO will not 

present an undue hazard per § 91.119(a). Adherence to these restrictions in the elevation of the departure

airport or barometric pressure. An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out. RS’ Operations Manuals will ensure operations can 

be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

RS seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure An exemption is required to the extent that the UASs do not have a

barometric altimeter, but rather a GPS altitude read out.

 ______________________

16See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the

UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons

afforded such protection. The operator must also ensure that nonparticipating persons remain under

such protection. If a situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons. In

addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles

and structures when the owner/controller of any such vessels, vehicles orstructures grants permission

for the operation and the PIC makes a safety assessment of the risk of operating closer to those 

objects and determines that it does not present an undue hazard.”
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Page 21

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the UASs will be operated below 400 feet AGL or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The UASs that RS intends to use for the proposed operations will meet all these operational 

characteristics. Moreover, as required by RS’ Operations Manuals, the PIC will be required to calibrate the 

aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 Grants of Exemption, 

the UASs RS intends to use, and the safety mitigation procedures contained in the Operations Manuals,

both ensure that an equivalent level of safety will be achieved, and a Grant of Exemption to the 

requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

RS requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states: 

(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 –

(1) During the day, to fly after that for at least 30 minutes; 

or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute battery reserve. An exemption from the fuel 

requirements of 14 C.F.R. § 91.151(a) is therefore required.

 _______________________

17If the height of the structure being inspected exceeds 400 feet AGL, the UAS will not be operated more than 

100 feet above the highest point on the structure.

18See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
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Aug 5th, 2015

Page 22

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a RS-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. 

In reaching this conclusion, the FAA considered that the UAS batteries for the RS-UAS provided 

provide approximately 20 minutes of powered flight (with payload) and provided battery level and battery 

time remaining in minutes and seconds to the PIC.19 The FAA also considered the fact that the RS-UAS

operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, and that in the 

event that the UAS should run low on power, the PIC will be alerted and can land the RS-UAS as soon as 

possible. Like the VDOS Grant of Exemption, RS use of the RS-UAS, combined with the requirements of 

Petitioner's Operations Manuals, ensure that an equivalent level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the RS-UAS unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. RS will adhere to this limitation for RS-UAS flights. 

The RS-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the UAS to a groundbased-on-screen display.20 As required by RS’ Operations Manuals, the PIC will promptly fly the UAS

back to the home launch location or pre-determined abort location where the UAS may safely land, while 

still maintaining a minimum of 25% reserve battery power. RS submits that the procedures requiring flights 

to be safely terminated once the batteries fall below 25% capacity, combined with the requirement that 

flights only be conducted within a secure, isolated area, using a UAS weighting less than 25 pounds, and 

within VLOS of the PIC and Observer(s), ensure that the proposed operation will provide an equivalent or 

higher level of safety to that provided by the regulations from which exemption is sought. 

_____________________

19Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20The RS-UAS ground control station displays, the UASs position, navigation route, tail number, altitude, 

heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor heading and 

orientation relative to the UAS. 
U.S. Department of Transportation

Aug 5th, 2015

Page 23

VI. DRUG AND ALCOHOL PROGRAM

RS will have policies in place to ensure that no person may participate in UAS flight operations if 

they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting RS’s Petition for Exemption. Congress has 

established a national policy that favors early integration of UASs into the NAS in controlled, safe working

environments such as those proposed in this Petition. Granting this Petition for Exemption helps fulfill 

Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain UAS may operate safely in the NAS before completion of the statutorily 

required rulemaking.

The proposed UAS operations in this Petition for Exemption significantly improves safety and 

reduces risk harm or serious injury to educators, students, and the public. Traditional methods of aerial 

research, education, maintenance and industry flight training applications exposes educators, students, and 

the public to the dangers of extreme low levels of flight with standard full size aircraft. Further the 

unknowing public seems to immediately collect in a group to see low flying aircraft curiously hoping to see 

stunts or tricks. This can be very dangerous in the event of an aircraft mechanical failure or pilot-student 

error can put a gathering of curious people and the unknowing public at risk. The use of small UASs can 

eliminate these hazards and is ultimately a much safer method of performing these types of flight 

operations education. 

The use of small UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the UASs carry no passengers 

or crew. Further, in the unlikely event of an accident, RS small battery powered UASs presents 

significantly less danger to persons on the ground when compared to operations by conventional manned 

aircraft.21 As Petitioner's UASs are battery powered, the public will also benefit from a reduction in 

harmful emissions associated with conventional aircraft performing in the same functions proposed herein. 

Lastly, as recognized by the FAA in prior Section 333 Grants of Exemption for educators and researchers, 

UASs provide an additional tool for the Flight Instruction Program, adding a greater degree of flexibility, 

which supplements the current capabilities offered by manned aircraft.22

__________________

21See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial filming can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAS will weigh 

less than 55 pounds with no onboard pilot or crew, and contain no flammable fuel. The pilot and crew will 

be remotely located from the aircraft. The limited weight significantly reduces the potential for harm to 

participating and nonparticipating individuals or property in the event of an incident or accident. The risk to 

an onboard pilot and crew during an incident or accident is eliminated with the use of a UAS for the aerial 

filming operation." 

22See Grant of Exemption No. 11304 to Auburn University Aviation Center, (FAA−2014−1014 at 2)

{footnote continued}
U.S. Department of Transportation

Aug 5th, 2015

Page 24

VIII. PRIVACY 

All RS UAS operations will be conducted in accordance with applicable federal, state, or local laws 

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

permission from the land owner, air traffic control, or authorized representative. Permission from land 

owner, air traffic control, or authorized representative will be obtained prior to commencing flight 

operations.

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & 

(b).

The exemption will enhance safety by reducing risk to the general public and property owners from 

the substantial hazards associated with performing equivalent Aerial Research in Education (ARIE) for 

UAS flight training, maintenance and industry applications with conventional fixed-wing aircraft, 

rotorcraft, or other methods.

X. CONCLUSION

RS Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform Act of 2012 

including weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

VLOS and national security. The proposed UAS operations will benefit the public as a whole by improving 

safety and reducing risk through education and training and by alleviating human exposure to danger. In 

consideration of the foregoing, this Petition for Exemption provides the FAA with more than adequate

justification for granting the requested exemptions allowing RS to use small UASs for controlled flights for 

Aerial Research in Education (ARIE) for UAS flight training, maintenance and industry applications.

________________________________________

{continued from previous page} 

The FAA has issued grants of exemption in circumstances similar in all material respects to those presented 

in your petition. In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No.FAA−2014−0352),

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the 

FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications 

described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to 

find that the UAS operation enabled by this exemption is in the public interest.
U.S. Department of Transportation

Aug 5th, 2015

Page 25

We thank you for your prompt consideration of our requested exemptions. 

Respectfully submitted,

Reuven Silberman 

Aerial Robotics Education

CFI, ATC (retired) 

PO Box 713026 

Santee, CA 92072 

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

Aerial Robotics Education

Phone: 858-254-3848 

Pilots2@yahoo.com

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals