Phone (304) 983-8900

Fax (304) 983-8905

104 Corporate Drive, Morgantown, WV 26501

Harold Vass Operator:

Product Engineer Pillar Innovations, LLC

304.282.3876 104 Corporate Dr.

haroldvass@pillarinnovations.com Morgantown, WV 26501

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

February 2, 2016

Re: Petition of Pillar Innovations, LLC for Exemption Pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012

Dear Sir and/or Madam:

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

Part 11, Pillar Innovations, LLC (“Pillar”), hereby applies for an exemption from Federal Aviation 

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

(i.e., "small unmanned aircraft" or "sUAS"). This application is substantially similar to previous 

Exemptions and therefore appropriate for Summary Approval1

The contact information for Petitioner is as follows:

Pillar Innovations, LLC.

Attn: Harold Vass – Product Engineer

104 Corporate Dr. Morgantown, WV 26501

Phone: 304.282.3876

E-mail: haroldvass@pillarinnovations.com

 1 Referenced at http://www.faa.gov/news/updates/?newsID=82485
2

For your convenience, a table of contents for this petition is provided here:

I. Description of Petitioner

II. Relevant Statutory Authority

III. Qualifications for Approval under Section 333 of the Reform Act

IV. Description of Possible Aircraft

V. Description of Proposed Operations

VI. Regulations from which Exemption is Requested

a. 14 C.F.R. Part 21, Subpart H-Airworthiness Certificates and 14 C.F.R.§ 91.203 

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

c. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in 

Command. Commercial Pilot Privileges and Limitations.

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

e. 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

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

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

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

i. 14 C.F.R. § 91.119: Minimum Safe Altitudes

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

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

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

VIII. Drug and Alcohol Program

IX. Public Interest

X. Privacy

XI. Federal Registry Summary

XII. Conclusion
3

I. DESCRIPTION OF PETITIONER

Pillar Innovations, LLC was formed in 2007 from parent company Beitzel Construction Corporation

(formed in February of 1974). The company is headquartered in Grantsville, MD but now maintains 

offices in Maryland, West Virginia, Ohio, Indiana, and New Mexico. Pillar Innovations is a recognized 

leader in new technology, primarily in the mining and oil & gas industries serving customers nationwide 

out of numerous sales and service facilities. Pillar prides itself on being a company that delivers state-ofthe-art systems coupled with superior service long after the sale.

In May, 2015 Pillar Innovations, LLC and parent company Beitzel Corporation celebrated 4 years without 

a lost time injury. The two company’s commitment to safety and innovative practices are responsible for 

continual, sustained growth even in turbulent market conditions. 

Pillar Innovations, LLC currently has departments focused on all of the following operations:

• Electrical

• Instrumentation

• Automation and Integration

• Communication Towers

• Fiber Optics

• Site Security

• Fire Suppression

• Water Management

• Engineering Services

• New Product Design

By granting this exemption, Pillar Innovations will be able to increase safety for employees in existing 

departments and continue to offer new and innovative solutions to customers. The company requests 

this exemption on the grounds of public interest and equivalent safety in order to provide the following 

services to customers in a manner that is more affordable and safer than existing methods:

• Building, Infrastructure, Construction 

Site Inspections

• Tower Inspections

• Power Line Inspections

• Aerial Surveying and Mapping

• Site Security 

• Aerial Photography/Videography

• Closed-set Filming

• Flare Stack Inspection

• Precision Agriculture

• Catastrophe Response

• Damage Assessments

• Oil and Gas Platform Inspections

• Thermal/IR Inspection of Power 

Infrastructure

• Pipeline Inspection and Patrolling

• Wind Farm Survey

• Surface Mine Inspections

• Power Generation Asset Inspections
4

II. RELEVANT STATUTORY AUTHORITY

This petition for exemption is submitted in accordance with the Section 333 (a) through (c) of the FAA 

Modernization and Reform Act of 2012. 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.2

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

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

public interest. See 49 U.S.C. § 44701(±) (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).

III. QUALIFICATIONS FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

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

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

operations would permit the use of small and relatively inexpensive UAS under controlled conditions in

airspace that is: (1) limited; (2) predetermined; (3) controlled as to access; and that (4) provides an 

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

the same purpose. In addition many of these operations, such as flare stack, power line, tower, and 

construction inspection would be alternately accomplished by sending an individual up into a structure 

to manually conduct a visual inspection, or by flying a conventional rotorcraft dangerously close to the 

infrastructure to accomplish the task. Such operations carry a much higher risk of serious bodily injury or 

death compared with conducing a photographic or video inspection from a small UAS. Given the small 

size of the sUASs involved and the restricted environment within which they will operate, this petition 

exemption falls within the zone of safety, i.e., an equivalent level of safety, in which Congress desired 

the FAA to permit commercial UAS operations by exemption pending completion of formal rulemaking. 

Also, due to the size of the sUASs, and the restricted area in which the sUASs will operate, approval of 

the application presents no national security issue. Considering the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of 

 2 1 Id. at § 333(b)(1).
5

safety surrounding the proposed operations, and the significant public benefit, the grant of the 

requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests the FAA 

grant the requested exemption without delay.

IV. DESCRIPTION OF POSSIBLE AIRCRAFT

Pillar Innovations, LLC requests the ability to utilize one or more of the following small UAS (“SUAS”).

Granting approval to choose from a large list of drones affords the company the ability to invest in 

equipment that is tailored by flight time, payload capacity, and ultimately safety to a specific need or 

offering. All sUAS listed are provided with an exemption number in which this model of aircraft was 

already granted exemption.

Altus UAS Delta 

X-8

12646

American 

Drones –

Falcon 450

12646

American 

Drones – Eagle 

550

12646

American 

Drones –

Nighthawk 550

12646

American 

Drones –

Phoenix 650

12646

Arch Aerial –

OCTO

11283

ARRIS – M680 

Hexa

12646

Ascending 

Technologies –

AscTec Falcon 

8

12075

AirRobot AR 

100-B

12646

AirRobot AR 

100-C

12646

AirRobot AR 

180

12646

AirRobot AR 

200

12646

Altavian Nova 

F6500

11456

DJI – Phantom 

2

11795

DJI – Phantom 

3

11783

DJI – Inspire 1 11710

DJI – F450 12283

DJI – F550 12283

DJI – S800 11788

DJI – S900 11794

DJI – S1000 11671

DJI – S1000+ 11532

DJI – Matrix 

100

11814

3D Robotics 

Aero – M

12646

3D Robotics 

Fixed Wing

12646

3D Robotics 

X8+

12646

3D Robotics X8 

– M

12646

3D Robotics Y6 12646

Blade 350 QX3 11737

Cinestar 8 Octo 11408

AgEagle 11480

3DR X8 11335

3DR Iris 11778

3DR Solo 11832

SenseFly eBee 11745

Yuneec Q500 

Typhon

11734

DraganFlyer 

X4-P

11281

DraganFlyer 

X4-ES

11487

Trimble UX5 11806

Trimble UX5 –

HP

12231

Trimble ZX5 12646

Microdrones 

MD4

11546

MikroKopter–

ARF OctoXL

11228

Skycatch 11343

Skyhunter 12586

HSE UAV –

DRASS Q1000

 

11710A

Aerialtronics 

Altura Zenith

12068

Intuitive Aerial 

– Aerigon IAH 3

12772

AeroCine 

Kopterworx 

Hammer X12

12646

AeroVironment 

Shrike

11439

AeroVironment 

Puma

11264

AeroVironment 

Qube

11868

Aerial Pixels 

Fx8PRO Elite

12809

Aeronavics X4 

Titanium

11225

Aeryon Sky 

Ranger

11213

Aeronavics 

SkyJib-8 Ti-QR

11559

Aeryon Scout 11209
6

Agribotix 

Hornet Drone

12646

Agribotix 

Enduro Quad

12646

Aibotix X –6 12469

AirCover QR-

425

11334

AirCover ORT-

825

12646

Align M690L 

Multicopter

11230A

Altus UAS Delta X-412646

HobbyKing 

Bixler 2

12079

Bormatec –

Maja UAV

11486

Bumblebee 

Carbon Fiber 

Quadcopter

11371

CarbonCore –

Cortex ARTF

12404

CineStar – 6 

MK Heavy Lift 

RTF

12517

Cyber 

Technology –

Cyber Quad

12068

DraganFlyer –

X6

11281

DraganFlyer –

Guardian

11281

DraganFlyer –

Commander

11281

Delair-Tech –

DT – 18

12785

Event 38 –

E384

13081

FoxTech FPV –

D130 X8 V2

12646

FoxTech FPV –

K130 V3

11449

Freefly – Alta 12455

Multirotor G4 11306

AeroLogix –

Geostar

11370

Germap –

G180

12075

Gryphon 

Dynamics – X8

12516

HexaCrafter 

HO-1250

11305

HexaCrafter 

HC-1100

12646

Hoverfly –

Livesky

12646

Hubsan – X4 

Microdrone

11562

Inova Drone –

Inova One

12646

Tactical 

Robotics –

InstantEye Mk2

12703

KongCopter 

FQ700

12646

Latitude HQ-20 12646

Latitude HQ-40 12646

Leptron –

Avenger

12363

Lockheed 

Martin –

Desert Hawk III

12646

Lockheed 

Martin –

Indago

11446

Microdrones –

MD4-200

12496

Microdrones –

MD4-1000

12496

Microdrones –

MD4-3000

12496

MLB- Super-

Bat UAV

11255

MultiRotor –

G4 Skycrane

11287

ParkZone –

Radian RTF

12646

Parrot – Bebop 12713

Finwing –

Penguin 1720

11486

Birdseyeview –

FireFly 6

11571

UAV Solutions – Phoenix 6012646

Precision 

Drone –

PaceSetter

11316

PrecisionHawk – Lancaster12469

Prioria – Hex 12837

Prioria –

Maveric UAS

11571

Pulse 

Aerospace –

Vapor

11241

RIEGL RiCopter 12785

Ritewing –

Spade 70”

11228

Ritewing –

Zephyr 3 Spade

11228

Rightwing –

Drak

12646

RF70 Aircraft 12410

Yamaha RMAX 11448

AeroCamera –

SR 15

11422

RangeVideo –

Jet

11527

SenseFly –

eXom

11373

Sensurion 

Aerospace –

Magpie

12646

MultiRotor –

G4 Blackbird 

V2

12646

Vanguard 

Defense 

Industries 

ShadowHawk

11255

Mavinci – Sirius 

Pro

11368

Skywalker X-8 11446
7

SteadiDrone –

Vader

11446

SteadiDrone –

Mavrik

11832

SteadiDrone –

Flare

11446

Swift 

Radioplanes –

Lynx

11432

Tarot – T18 12646

Tarot- 680 Pro 12720

Tarot – 690 11221

Tarot – T810 11397

Tarot – 960 11221

Tayzu Robotics 

– Titan X8

12646

T-Rex 800E Pro 11352

Turnigy Talon 

Quad

11889

Turbo Ace –

Cinewing 6

11392

Turbo Ace –

Matrix G

12545

Turbo Ace –

Matrix I

11674

Turbo Ace –

Matrix E

12545

Turbo Ace –

Matrix S

12545

Viking UAS –

VikingOne

12414

Viking UAS –

Patriot X4

12414

Viking UAS –

Patriot X8

12414

Viking UAS –

Ranger EX

12414

Viking UAS –

VK X6 Model 

800

12590

Volt Aerial 

Robotics –

Venture

11222

Vulcan –

Mantis

12646

Vulcan – Raven 12486

Walkera –

Scout X4

11665

Walkera – Tali 

H500

11869

V. DESCRIPTION OF PROPOSED OPERATIONS

A. Scope of Operations.

Pillar Innovations will provide a range of customers with a more controlled solution to location 

monitoring, aerial inspections, mapping, and more (see Section 1) by offering sUAS services in 

accordance with federal, state, and local law and its own policies committed to a safe work 

environment. To assist the FAA in its safety assessment of the Petitioner's proposed sUAS operations, 

below is a summary of operational limitations and conditions, which will ensure an equivalent or higher 

level of safety to operations conducted under current regulatory guidelines. The Petitioner understands 

that failure to comply will be grounds for the immediate suspension or rescission of any exemption 

granted.

1. The UAS weighs 55 pounds or less

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted.

3. The UAS may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UAS be operated at airspeeds greater than 

the maximum UAS operating airspeed recommended by the aircraft manufacturer.

4. The UAS must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.
8

6. All operations must utilize a visual observer (VO). The UAS must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption.

8. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics, e.g., replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights 

may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. 

The functional test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the sUAS to ensure that it is in a 

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the sUAS is in a 

condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g., operable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the sUAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the sUAS is found to be in a condition for safe

flight.

11. The operator must follow the sUAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components.

12. Each sUAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

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

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 
9

flight review requirements specified in 14CFR §61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14CFR §61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UAS with appropriate distance from 

nonparticipants in accordance with 14CFR §91.119.

15. UAS operations may not be conducted during night, as defined in 14CFR §1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA published aeronautical chart, unless 

a letter of agreement with that airport’s management is obtained or otherwise permitted by a 

COA issued to the exemption holder. The letter of agreement with the airport management 

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

17. The UA 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.

18. For tethered UAS operations, the tether line must have colored pennants or streamers attached 

at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and 

visible from at least one mile. This requirement for pennants or streamers is not applicable 

when operating exclusively below the top of and within 250 feet of any structure, so long as the 

UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined 

location within the private or controlled-access property.

20. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

21. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and 

to operate after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

22. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall 

be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a 

new or amended COA if it intends to conduct operations that cannot be conducted under the 

terms of the enclosed COA.
10

23. All aircraft operated in accordance with this exemption must be identified by serial number, 

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

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

24. . Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made 

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

25. The UA must remain clear and give way to all manned aviation operations and activities at all 

times.

26. The UAS may not be operated by the PIC from any moving device or vehicle.

27. All 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 sUAS 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 UA, 

flight operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and b. The owner/controller of any vessels, vehicles, or structures has granted 

permission for operating closer to those objects 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption.

28. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and television filming 

and production, the following additional conditions and limitations apply.

• The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption.

• At least 3 days before aerial filming, the operator of the UAS affected by this exemption must 

submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 

concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and 

times for all flights; b. Name and phone number of the operator for the UAS aerial filming 

conducted under this grant of exemption; c. Name and phone number of the person responsible 

for the on-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be 

used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement 

that the operator has obtained permission from property owners and/or local officials to 
11

conduct the filming production event; the list of those who gave permission must be made 

available to the inspector upon request; g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, 

and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation.

• Flight operations may be conducted closer than 500 feet from participating persons consenting 

to be involved and necessary for the filming production, as specified in the exemption holder’s 

MPTOM.

VI. 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 sUAVs, from its safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest.3

Petitioner seeks an exemption from several interrelated provisions of 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.

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

Petitioner seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 C.F .R. § 91.203(a)(1). The 

Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from 

the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular UAS. All UAS 

operated by Pillar Innovations will meet the requirements of a small UAS, i.e., have a gross take-off 

weight of less than 55 pounds. Given the size and limited operating area associated with the UAS 

operations, an exemption from Part 21, Subpart H, meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act.

In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed, will be at least as safe as, 

 3 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)
12

or safer than, a conventional aircraft operating with an airworthiness certificate without the restrictions 

and conditions of the proposed sUAS operations.

Equivalent Level of Safety

The sUASs to be operated hereunder weigh less than 55 pounds with payload, carry neither a pilot nor 

passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively within a 

secured and sterile area. Unlike other civil aircraft, the proposed operations will be controlled and 

monitored by the operator, as well as a visual observer, pursuant to the Manual's requirements.

These safety enhancements, which already apply to civil aircraft operated in connection with existing 

inspection operations, provide a greater degree of safety to the Petitioner's employees, members of the 

public, and property owners than conventional operations conducted with airworthiness certificates 

issued under 14 C.F.R. Part 21, Subpart H.

Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the sUAS, due to its size, speed of operation, lack of explosive materials or flammable 

liquid fuels, and inability to carry a substantial external load.

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

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

category rotorcraft. To the extent the Petitioner's sUAS would otherwise require certification under Part 

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

identified in the exemption request from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. § 61.113 (a) & (b), 61.133 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

Commercial Pilot Privileges and Limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in command 

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in 

command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property 

for compensation or hire. Pillar Innovations’ proposed operations meet the requirements of 8900.227 

para 16(c)(2)(c) "Operations without a pilot certificate" in which the PIC is required to complete "FAA 

private pilot ground instruction" and pass "the FAA Private Pilot written examination." Since there are 

currently no means available for the pilot of a UAS to gain the experience in an equivalent category and 

class in order to apply for a commercial pilot's license, the proposed operations can achieve the 

equivalent level of safety by requiring our pilots to complete a sUAS flight safety training program.

Equivalent Level of Safety

Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a 
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private, sport, or recreational pilot’s license rather than a commercial pilot’s license to operate this 

small UAS, as well as advanced UAS flight safety training. Unlike a conventional aircraft that carries the 

pilot and passengers, the sUAS is remotely controlled with no person on board. The risks associated with 

the operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested 

with a private pilot who holds advanced UAS flight safety training exceeds the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b).

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

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

C.F.R. § § 91.9(c), and 45.23(b).

• 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.

Exemption from 14 C.F.R. § 45.23(b) is warranted because the sUAS has no entrance to the cabin, 

cockpit, or pilot station on which the word "Experimental" can be placed. Moreover, given the size of

the sUAS, two-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage 

in compliance with 14 C.F.R. § 45.29(f). Given the nature of the specific relief sought by this exemption 

request, Petitioner requires relief from the associated marking and identification requirements of§ 

45.27(a) and § 91.9(c), which would require compliance with§ 45.23(b).

Equivalent Level of Safety

The equivalent level of safety for exemptions to the aircraft marking and identification requirements 

of§§ 91.9(c), 45.23(b) and 45.27(a) will be provided by having the sUAS marked on its fuselage as 

required by § 45.29(f). The FAA has previously issued the following exemptions to the aircraft marking 

requirements of§ 45.23(b): Exemption Nos. 10700, 10167 and 10167A.
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E. 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

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 not 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.

Pillar Innovations’ does not request an exemption from this section but instead notifies the FAA that, in 

accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS Flight Manual, 

registration certificate and other documentation will be kept at the control station with the PIC during 

flight. The Chief Counsel's Office has held that for all UAS operations, this alternate method constitutes 

full compliance with the regulations.

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

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

airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the 

sUAS, should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness.

Equivalent Level of Safety

The UASs will be fully maintained and operated in accordance with all specifications and requirements 

identified by the manufacturer. Pillar Innovations will only operate sUAS that have a proven track record 

of reliability and safety. Further, given that no UAS will be operated by Pillar with a weight of over 55 

pounds, and no UAS will be flown unless it has been maintained and prepared for flight in accordance 

with the manufacturer's requirements, an equivalent level of safety will be provided.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.
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G. 14 C.F.R. § 91.103: Preflight Action

Petitioner seeks an exemption from 14 C.P.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 Aircraft Operations Manual and flight 

manual provided by the manufacturer. The PIC will take all required preflight actions- including 

reviewing weather, flight battery requirements, landing and takeoff distance, and aircraft performance 

data - before initiation of flight. The Aircraft Operations Manual and manufacturer's flight manual will be 

kept at the ground station with the operator at all times.

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

Petitioner seeks an exemption from 14 C.P.R. § 91.109(a), which provides 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." sUASs and remotely piloted aircraft, by their design, do not have 

functional dual controls. Instead, flight control is accomplished through the use of a box that 

communicates with the aircraft via radio communications.

Equivalent Level of Safety

Given the size and speed of the sUAS, an equivalent level of safety can still be achieved without dual 

controls because no pilot or passengers are aboard the sUAS, and all persons will be a safe distance 

away in the event that the sUAS experiences any difficulties during flight instruction. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircraft.

Exemptions include: Nos. 5778K and 9862A.

I. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F .R. § 91.119. 

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."
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To provide the intended services, the sUAS is normally operated below 400 feet AGL.

Additionally, the sUAS will maintain a lateral distance of at least 100 feet from inhabited structures, 

buildings, vehicles, and vessels, and people not associated with the operation.

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum sUAS weight

proposed herein, and given the lack of flammable fuel, 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 UAS, as well as the location where it is operated. As 

set forth in the Manual, the sUAS will be operated in a restricted area. Furthermore, by operating at 

lower altitudes, the sUAS will not interfere with other aircraft that are subject to the minimum safe 

altitude regulations.

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

This petition 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 sUAS does not 

have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety

An equivalent level of safety will be achieved by following the procedures set forth in the Manual. As 

prescribed in the Manual, the operator will confirm the altitude of the launch site shown on the GPS 

altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly 

monitor the sUAS's height, thus ensuring operation at safe altitudes.

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

Petitioner 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 sUAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30-minute reserve. Pillar Innovations proposes that all flights 

comply with this requirement by mandating that the aircraft be safely landed with no less than 25% of 

battery life remaining.
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Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the sUAS. All flights will be planned to be terminated with no less than 25% 

reserve battery power still available. This restriction would be more than adequate to return the sUAS 

safely to the ground and its planned landing zone from anywhere in its limited operating area even in 

the event of an unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 

does not include the type of risks that Section 91.151 (a) was intended to alleviate given the size and 

speed of the small UAS, and the proximity of the flight operation to the landing zone. Moreover, 

operation will be limited to controlled areas where only people and property owners, or official 

representatives who have signed waivers, will be allowed.

This request for exemption falls within the scope of prior exemptions, including Exemption Nos. 10673, 

2689F, 5745, 10673, and 10808.

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

Petitioner also seeks an exemption from the maintenance inspection requirements contained in 14 

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

and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.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"). An exemption to these regulations is needed because Part 43 and these sections only 

apply to aircraft with an airworthiness certificate, which the sUAS 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 UAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual. As 

provided in the Operations Manual, the operator will ensure that the sUAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. The 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that flight operations will 

only take place in restricted areas for limited periods of time during daylight hours, creates less risk than 

that associated with conventional rotorcraft performing the same operation.

VII. ADVANCED UAS FLIGHT SAFETY TRAINING

Pillar Innovations recognizes that SUAS present a significant and complex flight safety challenge within 

the NAS. Pillar Innovations is committed to the highest standards of excellence in flight safety and safety 
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risk management. As a result, any PIC employed by Pillar Innovations be required to undergo sUAV 

specific training.

VIII. DRUG AND ALCOHOL PROGRAM

As set forth in the Manual, Pillar Innovations is committed to a drug-free work place and the right of the 

flying public it serves to safe and efficient flight service. All employees of Pillar are subjected to random 

drug screening in accordance with all federal, state, and local laws and regulations. Pillar Innovations 

currently screens all new hires and no less than 25% of employees on a yearly basis.

Excerpt from Pillar Innovations’ Employee Handbook 

A drug and alcohol-free workplace is essential to ensure the safe delivery of our services 

and to protect the well-being of all Employees. Pillar Innovations have enacted a 

Substance Abuse and Drug/Alcohol Testing Policy that all Employees must observe. This 

policy complies with all federal, state, and local laws and regulations. Failure to comply 

with this policy will result in termination.

10.01 Summary

Pillar Innovations prohibits the use, possession, selling, distributing or transportation of 

alcohol, marijuana, illegal drugs, or other controlled substances on Company premises. 

“Controlled Substances” refer to any drug or other substance prohibited by any state or 

federal law or regulation. The Company also prohibits reporting to work under the 

influence of alcohol, marijuana, illegal drugs, or other controlled substances. “Company 

Premises” includes all property owned, leased, used, or under the control of the Company;

including, but not limited to, the jobsite, structures, land, automobiles, trucks, buildings, 

offices, and facilities. This policy also includes any other work locations or modes of 

transportation to and from those locations while in the course and scope of Company 

employment.

10.02 Testing

The Company may test Employees for substance abuse

1) For reasonable cause

2) When an Employee has been involved in an accident or unsafe act

3) Randomly

4) As part of a pre-employment, substance-abuse testing program

A true positive test result will require disciplinary action, up to and including immediate 

termination without prior warning. All test results will be kept confidential and in a 

separate file from other personnel records.
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IX. PUBLIC INTEREST

Granting Pillar Innovations exemption request furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working environments such as 

those proposed in this petition. In addition, maintaining industrial safety has been a priority of state and 

local governments for decades. By its nature, the proposed use of sUAS offers superior safety to

performing the same tasks with conventional aircraft or rotorcraft.

In addition, granting the exemption will help advance the knowledge base for conducting commercial 

UAS operations. Pillar Innovations is committed to working with the local FSDO to share data from its 

operations. This additional data will help the FAA set future rules regarding UAS flight operations, 

maintenance, and crew qualifications. The public also has an interest in reducing the hazards and 

emissions associated with alternate use of conventional aircraft to conduct similar operations. The sUAS 

in question are very light weight and does not carry any flammable fuel, further reducing the risk from 

any potential accident.

X. PRIVACY

All flights will occur in accordance with any state or local laws regarding privacy.

XI. FEDERAL REGISTRY 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:

Pillar Innovations seeks an exemption from the following rules:

• 14 CFR Part 21, Subpart H

• 14 CFR 91.203 (a) & (b)

• 14 CFR Part 27

• 14 CFR 45.23(b)

• 14 CFR 61.113 (a) & (b)

• 14 CFR 91.9(b)(2)

• 14 CFR 91.203 (a) & (b)

• 14 CFR 91.7(a)

• 14 CFR 91.9(c) & 45.23(b)

• 14 CFR 91.103
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• 14 CFR 91.109(a)

• 14 CFR 91.119

• 14 CFR 91.121

• 14 CFR 91.151(a)

• 14 CFR 91.405(a)

• 14 CFR 91.407(a)(1)

• 14 CFR 91.409(a)(2)

• 14 CFR 91.417(a)&(b)

Approval of these exemptions will allow Pillar Innovations to offer flight services for a number of 

customers in the industries and applications noted above. The exemptions will enhance safety by 

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

equivalent work with conventional aircraft and rotorcraft.

XII. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012-size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security-provides more than adequate justification for the grant of the requested 

exemptions to permit Pillar Innovations to operate sUASs and provide on-demand UAS services to 

private entities.

Granting the requested exemption will benefit the public interest as a whole in many ways, including 

(1) Significantly improving safety and reducing risk by alleviating human exposure to danger, and 

(2) Improving the quality of services and decreasing operating costs compared with 

conventional flight operations.

If you have any questions or require any additional information, please do not hesitate to call.

PILLAR INNOVATIONS, LLC – 304.983.8900

________________________________

Harold Vass – Product Engineer

(304) 282-3876