Mark E. McKinnon Mark.McKinnon@dentons.com

D 703.336.8708

Dentons US LLP

1676 International Drive • Penthouse

McLean, VA 22102

United States

T 703.336.8800

F 703.336.8750

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McKenna Long

dentons.com

November 6, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: Petition of AAI Corporation d/b/a Textron Systems Unmanned Systems for Grant 

of 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, AAI Corporation d/b/a Textron Systems Unmanned Systems 

(hereinafter Textron) hereby applies for a Grant of Exemption from the Federal Aviation 

Regulations (FARs) identified below, to operate unmanned aircraft systems (UAS) for the 

purpose of conducting aerial data collection. In particular, Textron seeks permission to operate 

the Aerosonde Mk 4.7G (hereinafter Aerosonde). 

Textron wishes to make clear that this Petition is not submitted as a summary grant. 

Textron seeks to leverage the unique capabilities and long history of successful operations of the 

Aerosonde to allow operations beyond the 400 foot AGL limitation currently imposed on other 

exemption holders. As set forth in more detail below, Textron believes that the Aerosonde can 

be safely operated using visual line of sight at altitudes at 500' and above. 

In addition, Textron wishes to note that due to the capabilities of the Aerosonde, there are 

a number of regulations that other UAS operators are normally exempted from that the 

Aerosonde can meet. In particular, the Aerosonde has a barometric altimeter, and complies with 

14 C.F.R. § 91.121. The Aerosonde also has dual controls for flight instruction, enabling it to 

comply with 14 C.F.R. § 91.109(a). The Aerosonde also normally operates with 80 to 90 

minutes of reserve fuel, so no exemption is needed from 91.151(a). Finally, the Aerosonde

routinely operates at or above 500 feet AGL with the exception of take-off and landing, so no 

exemption is needed from 14 C.F.R. § 91.119(c). 

In support of this Petition for Exemption, Textron will also submit the following 

materials:

 Aerosonde Operators Manual, TM 40393-40598-10
 

U.S. Department of Transportation

June 15, 2015

Page 2

 Aerosonde Operators Checklist

 Aerosonde Maintenance Manual, TM 40393-40598-24&P

 Aerosonde Crewmember Training Manual, R40393-00149

Textron submits these manuals (hereinafter "Operating Documents") under separate 

cover pursuant to 14 C.F.R. § 11.35(b), as they contain confidential commercial and proprietary 

information that is not generally made available to the public. As a result, the information is also 

protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

For your convenience, this Petition is organized as follows:

TABLE OF CONTENTS

Page

I. BACKGROUND DESCRIPTION OF PETITIONER AND CONTACT INFORMATION .........................3

II. DESCRIPTION OF PROPOSED OPERATION...............................................................................3

III. RELEVANT STATUTORY AUTHORITY ....................................................................................4

IV. THE AEROSONDE CAN SAFELY CONDUCT VISUAL LINE OF SIGHT

OPERATIONS ABOVE 500' AGL......................................................................................4

A. The Aerosonde has a Long Operational History of Flight Above 500' AGL..........4

B. Approval of Flight Operations Above 500' AGL is Warranted Based on 

the Accepted Operational Restrictions and Textron's Operating Documents..........5

V. REGULATIONS FROM WHICH EXEMPTION IS SOUGHT...........................................................6

A. 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements ...........................................................................................................7

B. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): 

Maintenance Inspections..........................................................................................8

C. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, 

Recreational and Sport Pilot Medical Certificate, Privileges and 

Limitations...............................................................................................................9

D. 91.7(a): Civil Aircraft Airworthiness.......................................................................9

E. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 91.203(a) and 

(b): Carrying Civil Aircraft Certification and Registration ...................................10

F. 91.103: Preflight Action.........................................................................................11

VI. DRUG AND ALCOHOL PROGRAM.........................................................................................11

VII. PUBLIC INTEREST................................................................................................................11
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VIII. PRIVACY .............................................................................................................................12

IX. FEDERAL REGISTER SUMMARY...........................................................................................12

X. CONCLUSION.......................................................................................................................12

In accordance with 14 C.F.R. § 11.81(a), Textron provides the following information in 

support of its Petition for Exemption. 

I. BACKGROUND DESCRIPTION OF PETITIONER AND CONTACT INFORMATION

Textron leverages over 30 years of UAS experience, a corporate commitment to service, 

and more than 1 million flight hours of tactical unmanned aircraft systems experience to provide 

an adaptable, flexible, and expeditionary system. With experienced operators and maintainers 

supported by a highly responsive worldwide logistic support infrastructure and a dedicated 

depot/training facility, Textron currently provides its customers with superior UAS services. 

Textron continues to fund capability enhancements and leverage the built-in growth capacity of 

the Aerosonde platform to rapidly deliver the most mission reliable system, payloads, and 

service. 

The contact information for Petitioner is as follows:

Sean M. Baity 

Chief Engineer, Civil and Commercial Programs

Textron Systems 

Unmanned Systems 

124 Industry Lane 

Hunt Valley, MD, 21030 

baity@textronsystems.com 

410.628.6770 (Office)

II. DESCRIPTION OF PROPOSED OPERATION

Textron seeks an exemption pursuant to Section 333 of the Reform Act to use the 

Aerosonde Mk 4.7G (hereinafter "Aerosonde") for aerial data collection. Textron is committed 

to maintaining the highest standards of flight safety. All UAS operations will be performed in 

accordance with the accompanying Textron Operating Documents, and in accordance with the 

requirements of an applicable Certificate of Authorization ("COA"). 

Textron systems maintains an active reliability and maintainability program which tracks 

all mishap and troubleshooting activities across the fleet through a 24/7 HelpDesk. The data is 

collected and actioned through an agile workflow database. Outcomes, findings, and 
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recommendations from incident investigation, trend analysis, and helpdesk support drive 

ongoing reliability engineering and product improvement investment

The UAS operations proposed by Textron in this Petition for Exemption fall squarely 

within the category of aerial data collection that has been subject to previous approval. 

III. RELEVANT STATUTORY AUTHORITY

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

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 

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. THE AEROSONDE CAN SAFELY CONDUCT VISUAL LINE OF SIGHT OPERATIONS

ABOVE 500' AGL

A. The Aerosonde has a Long Operational History of Flight Above 500' AGL

The Aerosonde is not a new and untested vehicle. The Aerosonde has been operated 

successfully for military and other governmental entities for decades. All of these operations are 

routinely conducted above 500' AGL. As of October 8, 2015, the Aerosonde fleet has accrued 

113,971 flight hours. The Aerosonde Mk4.7G first deployed outside of the continental United 

States in May 2012 and is currently operational and accruing flight hours at a rate of 700 to 900 

flight hours per week supporting worldwide Intelligence, Reconnaissance, and Surveillance 

(ISR) fee-for-service missions. The Aerosonde has supported 15 individual operational sites with 

a range of flight operational tempos. Site operations range from 300 flight hours per month to the 

largest single site being 4,200 flight hours per month. In addition, Textron Systems has 

successfully delivered an Aerosonde Mk4.7G system, trained certified Operators, and provides 

ongoing support for an international commercial Oil and Gas customer.
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Textron has successfully operated the Aerosonde above 500' through a number of COAs 

issued in cooperation with public entities. For example, the Aerosonde was operated in 

conjunction with a NASA project at altitudes of up to 2000' AGL. See e.g. 2012-ESA-30, 2009-

ESA-30, 2008-ESA-30. The Aerosonde has been authorized to fly at 3000' AGL for both the 

United State Air Force Academy and Kansas State, and 4000' AGL for Tennessee. See 2011-

WSA-46, 2011-CSA-51, 2011-ESA-27. Currently, the Aerosonde is flying at up to 2500' AGL 

with Virginia Tech and up to 3000' with the University of Alaska. See 2014-ESA-121, 2014-

WSA-185. Most notably, the Aerosonde completed two weeks of operations flying BVLOS, 

during both night and day, at altitudes of up to 14,500' MSL in support of the Department of the 

Interior's firefighting efforts. See Addendum to COA 2015-WSA-63, issued September 14, 

2015. 

The Aerosonde's safety and reliability are demonstrated by the fact that, throughout the 

entire operational history of the aircraft, there have been only 8 lost link communications events. 

None of these incidents resulted in an accident, and the aircraft was safely recovered each time. 

In addition, through use of Textron's robust reliability program, the root cause of each incident

was determined, and corrective action was successfully taken to prevent future occurrences. 

The Aerosonde has a maximum design takeoff weight of 75 pounds. As a result, it is not 

a "small UAS" as that term is defined in Section 331(6) of the FAA Modernization and Reform 

Act of 2012. While size and weight are factors that Congress directed the FAA to consider when 

providing a Section 333 Exemption, such Exemptions are not limited to small UAS. See id. at §

333(b)(1). For example, the FAA has previously held that the Yamaha RMAX is suitable for 

Section 333 operations even though it is 9 feet long, has a main rotor diameter of 10 feet, and has 

an empty weight of 141 pounds, nearly 3 times larger than a "small UAS". See Exemption 

11448 granted to Yamaha Motor Corporation U.S.A., Docket No. FAA-2014-0397. This finding 

was based on the RMAX's extensive history of overseas operations, primarily in Japan, and its 

safety record. 

Textron submits that the Aerosonde has a similar history of safe operations. In December 

2013, Textron performed a full fleet replacement of the engines on the Aerosonde, utilizing the 

EL-005 engine. This engine was purpose-designed and built by Lycoming, a world leader in the 

design and manufacture of aircraft and helicopter engines. The EL-005 engine provides classleading reliability, and has accumulated over 75,000 operational flight hours. In addition, 

although the Aerosonde weighs 20 lbs. more than a small UAS, it is still under half the weight of 

the RMAX. 

B. Approval of Flight Operations Above 500' AGL is Warranted Based on the 

Accepted Operational Restrictions and Textron's Operating Documents 

Textron has agreed to additional safety mitigations to ensure an added level of safety for its 

flights above 500' AGL. First, the flights will only be conducted in sparsely populated or 

unpopulated areas. As a result, there should be no danger to persons or structures on the ground. 

Second, it should be noted that the Aerosonde's routine operations are normally conducted Beyond 
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Visual Line of Sight (BVLOS). In fact, virtually all of the Aerosonde's 113,971 hours of flight have 

been performed BVLOS. While Textron firmly believes that the Aerosonde is completely capable of 

BVLOS operations in the National Airspace System, it will not conduct such flights under this 

exemption. Accordingly, Textron is not seeking an exemption from 49 U.S.C. § 91.113. Textron 

will only fly the Aerosonde at an altitude where, under the prevailing meteorological and lighting 

conditions, the Aerosonde can be seen by the Pilot in Command with sufficient clarity to determine 

its orientation, direction of travel and position relative to other aircraft. Textron believes that this 

additional safety measure will enable safe operations at altitude above 500' AGL. 

Finally, the FAA should also take into consideration that, because the Aerosonde was designed with 

BVLOS operations in mind, it incorporates a number of features which enhance safety that are not 

found on other UAS, such as a Mode 3 A/C or Mode S transponder, ATC airband radios, as well as 

visible light and IR anti-collision strobes, which can be seen at ranges in excess of 3 NMs. 

The Operating Documents for the Aerosonde contain all the procedures and limitations necessary to 

safely and successfully perform the proposed operations. These manuals and procedures have been 

refined, taking into account the experiences and lessons learned from over 110,000 hours of 

successful operations. All of the information needed to fly and maintain the aircraft and its 

associated systems is set forth in detail. In addition, to expedite the FAA's safety assessment of 

Textron's proposed UAS operations, Textron agrees to abide by the standard terms and limitations 

contained in prior FAA Exemption grants imposed on similarly situated petitioners seeking to use 

small UAS for aerial data collection, with the exception of the limitation of operations to below 400' 

AGL. See e.g., Exemption No. 11304 Granted to Auburn University Aviation Center, Docket No. 

FAA-2014-1014 at ¶ 1-31.

V. REGULATIONS FROM WHICH EXEMPTION IS SOUGHT

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 UAS, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest.1

Textron seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 45, 61 

and 91 for purposes of conducting the requested operations using small UAS, including:

FAR Description

91.9(c); 45.23(b) and Aircraft Marking and Identification Requirements

 

1

See 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).
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45.27(a)

91.405(a); 91.407(a)(1); 

91.409(a)(1) and (2); 

91.417(a) and (b) 

Maintenance and Inspection Requirements 

61.23(a) and (c); 61.113; 

61.101(e)(4) and (5); 61.315

Private, Recreational and Sport Pilot Medical Certificate

Privileges and Limitations

91.7(a) Civil Aircraft Airworthiness

91.9(b)(2); 91.203(a) and 

(b)

Carrying Aircraft Flight Manual, Certification and Registration in 

the Aircraft 

91.103 Preflight Action

Listed below are the specific sections of 14 C.F.R. for which an exemption is sought, and 

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.2

A. 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

Textron 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 

 

2

See 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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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 prior grants of exemption under Section 333 of the Reform Act, 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."3 All UAS flown by Textron will bear N-number markings 

that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.4 

B. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance 

Inspections

Textron seeks an exemption from the maintenance inspection requirements contained in 

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

specify maintenance and inspection standards in reference to 14 C.F.R. Part 43.5 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. 

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

be performed in accordance with the operating documents and any required manufacturer Safety 

or Service Bulletins. Further, as required by the operating documents, the Pilot in Command 

(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 the operating documents, the PIC 

who conducts the functional test flight will make an entry in the UAS aircraft records of the 

flight. 

 

3

FAA Docket No. FAA-2014-0352.

4

See, e.g., FAA Docket No. FAA-2014-0352, at 14. 

5

See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft "[s]hall 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.").
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The operating documents also include requirements to follow the UAS manufacturer’s 

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

aircraft components. Moreover, the operating documents also include procedures to document 

and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of Petitioner's UAS. As a 

whole, the maintenance and inspection procedures required by Petitioner's operating documents 

ensure that an equivalent or higher level of safety will be achieved.

C. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational 

and Sport Pilot Medical Certificate, Privileges and Limitations

Textron seeks exemption from these sections, which restricts private, recreational or sport 

pilot certificate holders from flying aircraft for compensation or hire, and would also require a 

Class II 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 No. 11062 to Astraeus Aerial6, the FAA determined that the 

unique characteristics of UAS operation outside of controlled airspace did not warrant the 

additional cost and restrictions attendant with requiring 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. 

More recently, the FAA determined that holders of recreational and sport pilot 

certificates would also have adequate aeronautical knowledge to pilot a UAS. Accordingly, 

because these individuals would also be subject to security screening by the Department of 

Homeland Security (DHS), the FAA determined that holders of recreational and sport pilot 

certificates would be qualified to serve as the PIC for UAS operations.7 

Textron Systems proposes that all PIC Operators hold, at a minimum, a sport pilot 

certification and third-class airmen medical certification to support all Aerosonde Mk4.7G UAS 

operations. 

D. 91.7(a): Civil Aircraft Airworthiness

Inasmuch as there will be no airworthiness certificate issued for the UAS, Textron seeks 

an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy 

condition to be operated. While Petitioner’s UAS will not have an airworthiness certificate, the 

FAA has determined that for the purposes of this exemption the pilot may determine the aircraft 

 

6

FAA Docket No. FAA-2014-0352.

7

See Grant of Exemption No. 11213 to Aeryon Labs, Inc. (Docket No. FAA-2014-0642 at pgs. 8-9).
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is in an airworthy condition prior to flight. The operating documents contain procedures, which 

allow the PIC to determine whether the aircraft is in a condition safe for flight, and an exemption 

from § 91.7(a) is therefore warranted. 

E. 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 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.

Given the small size and configuration of the UAS, 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. 

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.8 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 pilot has 

access to the documents at the ground control station from which he or she is piloting the UAS.9 

 

8 Memorandum 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. FAA-2014-0352 at 16-18.

9

See also Exemption No. 11213 to Aeryon Labs, Inc. at pg. 11:

{footnote continued}
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F. 91.103: Preflight Action

Petitioner 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.

Adherence to the requirements in the operating documents will ensure that the UAS is in 

an airworthy condition prior to flight. The PIC will perform a series of checklists designed to 

identify any defects or inoperable components, which cover pre-flight, take-off, landing and 

post-flight procedures. The PIC will also be required to review weather, flight requirements, 

battery charge, landing and takeoff distance, UA performance data, and contingency landing 

areas—before initiation of flight. Petitioner's operating documents will be kept at the ground 

control station and will be accessible to the PIC at all times while operating the UAS.

VI. DRUG AND ALCOHOL PROGRAM

Textron has established policies 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 Textron's Petition for Exemption. Congress 

has established a national policy that favors early integration of UAS into the National Air Space 

(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 improve safety 

and reduce risk by alleviating the public's exposure to danger associated with traditional aerial 

data collection methods, namely, full size fixed-wing aircraft and rotorcraft. Any accident 

involving Petitioner's small lightweight UAS will present significantly less danger to the pilot 

and other individuals on the ground than one involving a full size helicopter. 

 

{continued from previous page}

The petitioner requested relief from 14 CFR § 91.9(b)(2): Civil aircraft flight manual, marking, and 

placard requirements and § 91.203(a) and (b): Civil aircraft: Certifications required. The FAA has 

previously determined that relief from these sections is not necessary. See Exemption No. 11062. 

Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations.
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VIII. PRIVACY

The proposed operations will be conducted in accordance with applicable federal, state, 

or local laws regarding privacy. Textron will not conduct flight operations over property that it 

does not own or control without the prior consent and knowledge of the property owner. 

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:

45.23(b); 45.27(a); 61.23(a) and (c); 61.113; 61.101(e)(4) and (5); 61.315; 91.7(a); 

91.9(b)(2); 91.9(c); 91.103; 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 using conventional fixed-wing aircraft or 

rotorcraft for aerial data collection.

X. CONCLUSION

The proposed operations in this Petition for Exemption satisfy the criteria articulated in 

Section 333 of the Reform Act. In consideration of the foregoing, this Petition for Exemption 

provides the FAA with all the necessary justification for granting the requested exemptions 

allowing Textron to operate the Aerosonde for the purpose of aerial data collection.

 

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

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

please do not hesitate to contact us.

Very Truly Yours, 

Mark E. McKinnon

Counsel for Textron Systems Corporation

Attachments