p

p

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Petition of San Tan Traffic Consultants for an Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 

Director: Flight Standards Service: 

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

14 C.F.R. Part II, San Tan Traffic Consultants (San Tan) hereby applies for an exemption from 

the Federal Aviation Regulations ("FARs") identified below to allow commercial operation of 

small unmanned aerial vehicles (i.e., "small unmanned aircraft" or "VAS") for the purpose of 

conducting aerial photography, videography, inspection, mapping and data collection for accident 

reconstruction for local municipalities. 

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

as well as the accompanying San Tan documents; 

I. PIC Flight Operations Manual and; 

2. Operations Manuals 

(Collectively 2 and 3 are referred to as Documents & Manuals") 

3. User Guide and; 

4. Flight ManuaJI 

(Collectively 3 and 4 are referred to as "Manufacturer's Manuals") 

San Tan submits these 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 

San Tan has not and will not share with other requesting parties. 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. NOTE: 

ALL ATTACHMENTS SET FORTH IN SUPPORT OF THIS LETTER OF 

PETITION ARE CONFIDENTIAL AND SHALL NOT BE RELEASED TO THE 

PUBLIC WITHOUT WRITTEN AUTHORIZATION FROM THE PETITIONER. 

For your convenience, this Petition is organized as follows: 

1

• The tenn "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. 
III. Relevant Statutory Authority 

IV. San Tan's 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. § 91.1 03: 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 

I. DESCRIPTION OF PETITIONER 

San Tan is based in Chandler, AZ and provides aerial videography, photography, inspection, 

mapping and data collection to their client base. The Company's Principal and Chief Pilot 

Joseph V. Catone has been flying UAV Quadcopters as a hobby for more than three years 
for the pilot in command (

PIC

) in addition to any other needed on site assistance. 

All of the equipment owned by San Tan is of the highest quality gear and has been able to 

provide these services safely and without any claims or incident. San Tan's goal is to advise the 

perspective client that San Tan is following all the applicable state and federal rules to ensure the 

safety of the public while providing the client with a competitive and cost effective product. 

San Tan seeks an exemption to allow for photography, videography, mapping, inspection and 

data collection and other related media products. 

The contact information for Petitioner is as follows: 

Joseph V. Catone 

San Tan Traffic Consultants 

975 E. Riggs Rd., Ste. 12-460 

Chandler, AZ 85249 

Phone: 602.999.2125 

Email: jcatone@santanrecon.com 

II. DESCRIPTION OF PROPOSED OPERATION 

San Tan seeks an exemption pursuant to Section 333 of the Reform Act to operate the Blade 350 

QX2 AP; Blade Chroma; and DJI Inspire; (referred to DB-UAS) (under 55lbs) for the proposed 

operations discussed herein below. All UAS operations will occur under tightly controlled 

conditions on private property or approved location where San Tan has received verifiable 

permission to operate from the landowner, controller or authorized representative. The proposed 

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

Petition for Exemption and San Tan's Operations Manuals. As detailed in San Tan's Operations 

Manuals, all UAS operations will be limited to daytime VFR conditions, within visual line-ofsight ("VLOS") of the operator, in uncontrolled airspace, and will occur at least 5 nm away from 

an airport reference point. Moreover, San Tan's Operations Manuals incorporate redundant 

safeguards to assure the aircraft does not travel outside the controlled area of UAS operations, 

including GPS "geo-fencing" technologies. 

A. Aerial Videography, Photography, Inspection, Mapping and Data Collection 

San Tan seeks to use small STT -UAS for the purpose of conducting aerial photography, 

videography, cinematography, inspection and mapping for the film, television, real estate, and 

web industries. San Tan has purposefully tailored its operations to meet the requirements 

established by the FAA in prior grants of exemption authorizing commercial use ofUAS in the 

relevant industries, including: 
• Flying-Cam, LLC (Exemption No. 11 080) 

• Aerocine, LLC (Exemption No. 11150) 

• Team 5, LLC (Exemption No. 11158) 

• Alan D. Purwin (Exemption No. 11161) 

• HelinetAviation Services, LLC (Exemption No. 11160) 

• Picture Factory, Inc. (Exemption No. 11178) 

• Trudeau, Realtor® (Exemption No. 11138) 

• Alon Sicherman (Exemption No. 11728) 

• Sokoler Medly (Exemption No. 11341) 

All UAS photography, videography, inspection mapping and data collection operations will 

occur on private property or approved location in a controlled area away from spectators and 

persons not involved in the recording process. In addition, the filming will be conducted between 

dawn and dusk to ensure maximum safety for the public and those involved in the manipulation 

and operation of the UAS; VFR conditions, at altitudes below 400' above ground level ("AGL"). 

As set forth below, San Tan's operations provide an equivalent level of safety which is superior 

to performing the same work using conventional fixed-wing aircraft or helicopters. 

Small UAS recording operations is also safer than traditional manned aircraft performing the 

same function. Videographer-inspectors also frequently need to climb roof tops, ladders, trees, 

or otherwise perform elevated work, which exposes them to the risk of dangerous falls, 

electrocution or other work related injuries. In addition, depending on the nature of the video 

needed and inspection, proximity to equipment, and other mechanical hazards associated with 

industrial sites and construction facilities often involves a risk of exposure to hazardous 

conditions. The use ofSTT-UAS mitigates these hazards and is ultimately a much safer and 

cost efficient method of performing these and most other types of recording operations. 

Moreover, conventional operations using rotorcraft and fixed-wing aircraft in low level 

operations present risks associated with vehicles weighing tens of thousands of pounds 

(including payload) and carrying large amounts of fuel which inherently presents significant fire 

hazards as well as exposure to other chemical contaminates. It is important to note the use of 

small UAS in this area will not only be safer and more cost effective to the perspective user or 

purchaser of the service, but the quality and expanse of acquired information will be far more 

robust given the low cost associated with its acquisition and other potential consumers an 

inexpensive product. 

UAS video production is more reliable, and allows for the collection, dissemination, and storage 

of visual and other sensory data with greater precision and duration at a very low cost. Small 

UAS will also be capable of accessing and inspecting areas that would otherwise be inaccessible 

or highly dangerous using conventional aircraft or other inspection methods. 
unmanned aircraft systems to operate in the National Airspace Systems (

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. § 4470l(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 .8 I 

(petitions for exemption). 

IV. SAN TAN'S PROPOSED STT-UAS OPERATIONS MEETTHE 

REQUIREMENTS OF SECTION 333 OF THE REFORM ACT 

The small SIT-U AS operations proposed by San Tan as noted above 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 UASs due to their size 

weight, speed, and operational capability. 

• The SIT-U AS utilized by San Tan has been approved for use in prior Section 333 

Grants of Exemption from the FAA.2 

• The SIT-U AS weighs less than 55 pounds, including payload 

• The SIT-U AS will not be flown at a ground speed in excess of 50 knots. The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 50 knot speed restriction. 

2See e.g., Gmnt of Exemption to Shotover Camem Systems L.P. (Exemption No. 11159); Gmnt of Exemption to 

VDOS Global, LLC (Exemption No. 11112); Gmnt of Exemption to LowCountryRC, Corp. (Exemption No. 11184); 

Gmnt of Exemption to Alan Purwin (Exemption No. 11161 ); Gmnt of Exemption to Helinet Aviation Services 

(Exemption No. 11160); Gmnt of Exemption to Total Safety U.S., Inc. (Exemption No. 11156) .. 
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 STT-UAS comply 

with the Federal Communications Commission ("FCC") and other appropriate 

government oversight agency requirements. The operating frequency for the SITUAS is 2.4 GHz frequency bands. 

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

likely exceed 6,000 pounds depending on payload. The difference in weight between the SITUAS and a helicopter significantly reduces the potential harm to the participating and nonparticipating individuals and/or surrounding property in the event of an unintended accident or 

incident. In addition, the risk to the on board pilot and camera operator is eliminated. 

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

San Tan's Operations Manuals 

Operations Manuals and the Manufacturer's Manual for the selected SIT-U AS 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 San 

Tan's proposed operations, below is a summary of operational limitations and conditions that San 

Tan will adhere to, and which will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines: 

1. The STT-UAS weighs less than 55 pounds, with payload. 

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

verifiable permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be obtained 

for each scheduled flight prior to operation. 

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

registered in accordance with 14 CFR part 4 7, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable. 

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the SIT-UAS, and one or more Visual Observers ("Observer") 

as necessary to safely conduct the mission. 
6. The STT-UAS shall be operated within VLOS of the PIC and Observer 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. 

7. The PIC and Observer designated for any operation will be able to communicate 

verbally at all times. 

8. Electronic messaging or texting will not be pennitted during flight operations. 

9. The additional requirements identified in the Grant of Exemption shall be added to 

the San Tan's 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 San Tan's Operations 

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

precedence and must be followed. Otherwise, San Tan shall follow the procedures 

outlined in their Operations Manuals. 

10. San Tan 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. San 

Tan will also present an updated and revised Operations Manuals if it 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, San Tan will seek an 

amendment to its Grant of Exemption. San Tan will contact the FAA's UAS 

Integration Office (AFS-80) if questions arise regarding updates or revisions to the 

operating documents. 

11. San Tan Operations Manuals and its Grant of Exemption will be available to the PIC 

at the ground control station anytime the STT-UAS is operating. 

12. The PIC is prohibited from beginning a STT-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 1 0 minutes. 

13. Maximum total flight time for each operational flight using the STT-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. 

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never 

enter navigable controlled airspace without timely prior written authorization and 

approval from the FAA. In the event the structure being inspected exceeds 400 feet 
a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA 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 and/or; 

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, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119( a). 

16. The STT-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. 

17. The SIT-U AS may not operate within 5 nm of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with 

a NOT AM as required by the San Tan COA. The letter of agreement with the airport 

management will be made available to the Administrator upon request. 

18. Prior to each flight the PIC shall inspect the STT-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 as well as equipment updates. The PIC shall not 

operate any STT-UAS if the inspection reveals a condition that affects the safe 

operation of the STT-UAS until the necessary maintenance has been performed and 

the STT-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 VAS's records as required by San Tan's Operations 

Manuals. 

19. San Tan will timely carry out its maintenance, inspections, and record keeping 

requirements in accordance with the Operations Manuals. Maintenance, inspection, 

and alterations will be fully noted in the STT-UAS records, including total time in 

service, description of work accomplished, date completed and the signature of the 

authorized person returning the STT-UAS to service. 
Manuals. 

21. The SIT-U AS will be operated and maintained according to the Manufacturer's 

Manuals and any required manufacturer Safety/Service Bulletins and product updates. 

22. Prior to the operation, a Mission Packet will be created in accordance with the 

requirements on San Tan's Operations Manuals. 

23. San Tan will 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. 

24. 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. 

25. If the STT-UAS loses communication with the PIC, it will have the capability to 

safely return to a pre-determined location within the operational area and land safely. 

26. Contingency plans will be in place to safely terminate flight ifthere is a loss of 

communication between the PIC and the Observer. 

27. The STT-UAS will have the capability to safely abort flight in the case ofunpredicted 

obstacles or emergencies. 

28. PICs and Observers will have at least a current Class III Medical Certificate or a valid 

and current state driver's license issued within the United States. 

29. Prior to conducting operations for filming, the PIC 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 as a UAS rotorcraft pilot and at least I 0 hours logged as a UAS 

pilot with a similar STT-UAS type platform. This requirement can be achieved by 

flights conducted and logged as a hobbyist. 

30. Prior to conducting operations for filming, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of hours pursuant to 54 

CFR § 61.5I(b) as UAS pilot operating the make and model ofSTT-UAS to be 

utilized for operations under the exemption and three take-offs and three landing in 
operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, hang gliders, etc.). 

33. STT-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are 

prohibited. 

34. The UAS will not be operated from an elevated platform unless designed and 

engineered specifically for such purposes and be in compliance with the general 

restrictions imposed by the applicable regulations. Additionally no PIC will provide 

any film-flight operations while in motion from atop any elevated platform vehicle or 

device. 

35. Before conducting operations, the radio frequency spectrum used for operation and 

control of the STT-UAS will comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

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 oftheAct, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.3 

San Tan 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 STT-UAS platforms noted above. Listed below are: (I) 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 

UNMANNED AIRCRAFf SYSTEM 

A. 14 C.F.R. Part 21, Subpart H - Airworthiness Certificates and 14 C.F.R. 

§91.203(a)(l) 

349 U.S.C. § 4470 I (f) (authorizing the grant of exemptions from requirements of regulations prescribed pursuant to 

Sections 4470 I (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. 
Equiva/e11t Level of Safety 

San Tan's use of the STI-UAS is safe when taking into account its size, weight, speed, and 

operational capability. As set forth in the description of proposed operations in Section IV(A), 

the STI-UAS weighs less than 55 pounds, including payload and will not be flown at a ground 

speed in excess of 50 knots. The SIT-U AS is also equipped with safety features which will 

allow Petitioner to operate the SIT-U AS safely after experiencing certain in-flight contingencies 

or failures as noted below.6 7 

Additionally, the SIT-U AS carries neither pilots nor passengers, carries no explosive materials 

or flammable liquid fuels, or other elements identified by Homeland Security as being 

prohibitive and operate exclusively within the parameters stated in San Tan's Operations 

Manuals. 

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

operator and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. San Tan will also provide the FAA with advance notice of all 

operations via NOTAMs as required by the applicable COA. In all cases, operation of the SIT5See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22). 

6See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): "The [OJ! SIOOO] 

has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an autopilot 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." 

7See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): "The STT-UAS can 

be operated entirely by a touch-screen, 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 STT-UAS can be operated in both semi 

and fully autonomous flight modes, with the operator simply clicking on a map to create a pre-planned flight path 

for a flight. In addition, the operator can create no fly zones or maximum flight ranges and altitudes so the system 

cannot enter areas deemed unsafe or unnecessary to fly over. The petitioner states further that the UAS has built-in 

intelligent fault handling which allows the STT-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 pre-set 

wind thresholds; and low battery levels. 

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 control system employs not only G PS positioning but a variety of sensors including sonar, 

barometric pressure, temperature, wind speed and others to 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." 
B. 14 C.F.R. Part 27 Ainvorthiness 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 San Tan's small STT-UAS 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. R. Part 21, 

Subpart H, supra. 

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

Requirements 

San Tan 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. 

8See Grant of Exemption No. 11062 toAstraeusAerial (FAA-2014-0352 at pg. 13). 
All STT

UAS flown by San Tan will bear N

number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C. 11 

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

Maintenance Inspections 

San Tan 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 "[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 from these regulations is needed 

because Part ./3 and these sections only apply Ia aircraft with an airworthiness certificate, which 

the UAS platforms Ia be operated under this gran/ of exemption will not have. (Emphasis added) 

Equivale11t Level of Safety 

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

will be timely performed in accordance with the Manufacturer's Manual and any required 

manufacturer Safety or Service Bulletins. Further, as required by San Tan's Operations Manuals, 

the PIC will conduct a pre-flight inspection of the STT-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 SIT-UAS and no 

flights will occur unless, and until, all flight critical components of the SIT-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 San Tan's 

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the 

SIT-UAS aircraft records of the flight. 

San Tan's 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, San Tan's Operations Manuals also include procedures to document and maintain 

a record of the SIT-U AS's maintenance, preventative maintenance, alterations, status of 

replacement /overhaul component parts, and the total time in service of the SIT-U AS used under 

10. FAA Docket No. FAA-2014-0352. 

II. See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
San Tan 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 SIT-U AS will be operated as 

part of a commercial operation, they carry neither passengers nor cargo. In the Grant of 

Exemption to Astraeus Aerial, the FAA determined that the unique characteristics ofUAS 

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 III Medical 

Certificate.12 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. 

Equivale11t Level of Safety 

The restrictions San Tan has placed on its SIT-U AS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. San Tan will operate on private property or approved 

location away from persons and property not involved in the operation. San Tan 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 NOT AM will 

also be issued as required by the applicable COA. 

In addition to these flight restrictions, San Tan 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 SIT-U AS flight. As set forth in the 

Operations Manuals, pilots will have experience not only in STT-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 San Tan. The pilot qualification, 

training, and currency requirements in the Operations Manuals ensure that San Tan pilots are 

competent and proficient in the STT-UAS they are operating. San Tan's 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 to the public. 

OPERATING PARAMETERS OF THE UAS 

F. 14 C.F.R. § 91.7(a): CivilAircraftAinvorthiness 

12Exemption No. 11062 (FAA Docket No. FAA-2014-0352). 
o

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 on board 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 SIT-UAS, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the STT-UAS because there is 

simply no room and the SIT-U AS has no cabin or cockpit. As a way to comply with the code 

San Tan will maintain the documents with the PIC and make them available for inspection. 

Eq11ivalellt Level of Safety 

In an FAA Office of Chief Counsel's Opinion dated August 8, 20 14, 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 

13 See I d. at I 3-I 4, 22. 
San Tan 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 FAAapproved 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 FAAapproved Flight Manual is required. 

Eq11ivale11t Level of Safety 

An equivalent level of safety will be provided by following the San Tan's 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 San Tan's Operations Manuals, 

including checklists covering Pre-Flight, Launch, 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. San 

Tan's 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 

San Tan seeks an exemption from 14 C.F.R. § 91.1 09(a), which provides in pertinent part that 

"[n]o 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). 

Eq11ivale11t Level of Safety 

Given the size and speed of the UASs that San Tan 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 San Tan'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 San Tan's Operations Manuals, all flight training will be conducted 

in controlled and sterile environment. As a whole, the safety procedures provided for in San 

14 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-20 14-0352 at 16-18. 
( 

)

9

9 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 STT-UAS operation will normally need to occur 

below 400 feet AGL. In circumstances where the STT-UAS is used to inspect a structure whose 

height exceeds 400 feet AGL, the STT-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 STT-UAS. 

Equivale11t 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 above noted UASs, any risk 

associated with these operations is far less than those which presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

STT-UAS, as well as 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 U.S. 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 STT-UAS 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 STT-UAS and 

any possible debris resulting from its failure. As required by the Operations Manuals, flights will 

be terminated if a nonparticipating person within 500 feet of the STT-UAS leaves a shielded 

position. Further, its operations will occur at least 500 feet away from vehicles or structures 

unless the property owner/controller timely 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 

Observer will not present an undue hazard per § 91.119( a). Adherence to these restrictions in 

15 Relief 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 Slugwear, Inc., dba Like on a tree Aerial (FAA-2014-0534 at 15). 
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. 

Equivale11t 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 

below17, (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.I8 

The STT-UAS that San Tan intends to use for the proposed operations will meet all these 

operational characteristics. Moreover, as required by San Tan's 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 STT-UAS San Tan intends to use, and the safety 

mitigation procedures contained in the Operations Manuals, both ensure that an equivalent level 

of safety or greater level 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 

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

conditions. Section 91.151 states: 

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 or structures grants pennission 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." 

171fthe 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. II 062 to Astraeus Aerial (F AA-20 14-0352 at 21 ). 
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. Moreover, it is not San 

Tan's intention to fly the SIT-U AS at night. 

Equivale11t 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 STT-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 I 0 minutes. In reaching this 

conclusion, the FAA considered that the UAS batteries for the STT-UAS provide approximately 

50 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 the STT-UAS 

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

that in the event that the SIT-U AS should run low on power, the PIC will be alerted and can 

safely land the- STT-UAS as soon as possible. Like the VDOS Grant of Exemption, San Tan's 

use of the STT-UAS, combined with the requirements of Petitioner's Operations Manuals, ensure 

that an equivalent level of safety can be achieved and in fact exceeded. 

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 UA unless 

(considering wind and forecast weather conditions), there was enough power to safely fly at 

normal cruising speed to the intended landing point and land the UA with 25% battery power 

remaining. San Tan will adhere to this limitation for its STT-UAS flights. 

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

remaining is continuously transmitted to the PIC via telemetric data feed, which downlinks from 

the STT-UAS to a ground-based-on-screen display.20 As required by San Tan's Operations 

Manuals, the PIC will promptly fly the SIT-U AS back to the home launch location or predetermined abort location where it may safely land, while still maintaining a minimum of25% 

reserve battery power. San Tan submits that the procedures requiring flights to be safely 

19. Grant of Exemption No. 11112 to VDOS Global, LLC (F AA-20 14-0382 at I 0). 

20. The STT-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. 
VI. DRUG AND ALCOHOL PROGRAM 

San Tan will have policies in place to ensure that no person may participate in STT-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 San Tan's Petition for Exemption. Congress has 

established a national policy that favors early integration ofUAS 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 STT-UAS operations in this Petition for Exemption significantly improves the 

safety and reduces risk of harm, physical injury and property damage to the public at large, the 

property owners from whom permission was granted for use by Petitioner and abutting 

properties, staff of Petitioner, unsuspecting passersby, inspecting engineers from relevant 

organizations and all those who may be in the local vicinity. Traditional methods of providing 

surveillance and mapping services location personnel to climb towers, trees, venture onto 

precarious roofs and other dangerous scenarios, perform elevated work for which the individual 

is neither trained nor equipped to perform, which exposes them to unnecessary risk of serious 

physical injury from dangerous falls or other physical mishaps. Moreover, inspectors/surveyors 

are often unnecessarily exposed to hazardous conditions, unsafe environments, culturally tense 

situations and other hazards associated with identifying specific locations for potential recording 

sites to be used in the end product. The use of small UAS can eliminate these hazards and 

ultimately create a much safer method of performing these types of inspections creating a safer 

environment for the public as well as San Tan employees. 

The use of small UAS also enhances safety and reduces risk to the surrounding public because, 

unlike manned aircraft weighing thousands of pounds, carrying crew in addition to flammable 

fuel, the UAS carry no passengers, crew or explosive fuel. Furthermore, in the unlikely event of 

an accident, San Tan's small battery powered STT-UAS presents significantly less danger to 

persons on the ground when compared to operations by conventional manned aircraft. 21 As 

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-20 14-0783 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 on board pilot or crew. 

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. Risk 

to an on board pilot and crew during an incident or accident is eliminated with the use of a UA for the aerial filming 

operation." 
provide an additional economic tool for the aerial filming notwithstanding the industry, adding a 

greater degree of flexibility, which supplements the current capabilities offered by manned 

aircraft.22 The quality of the finished product is enhanced and provides a greater finished product 

demand which will aid the current UAS industry and provide additional jobs as the cost of 

providing the needed product is greatly reduced while reducing the difficulty with which the 

finished product is created. The demand for the current industrial product is increasing and will 

continue to increase given the enhanced flexibility of production; therefore, given the lower cost, 

owner/operators and others in the relevant industry will be more inclined to utilize the services of 

commercial UAS along with an appropriate licensed PIC's. 

VIII. PRIVACY 

All STT-UAS operations will be conducted in accordance with applicable federal, state, and local 

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

property with permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

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)(l); 

91.409(a)(l) & (2); 91.417 (a) & (b). 

The exemption will enhance safety by reducing risk to the aircraft crew, production crew, general 

public, property owners and city structures from the substantial hazards associated with 

performing equivalent film work and aerial video production with conventional fixed-wing 

aircraft, rotorcraft, or other methods. 

X. CONCLUSION 

San Tan's Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform 

Act of 2012 which includes weight; speed; operating capabilities; proximity to airports and 

populated areas; operation within VLOS and national security. The proposed STT-UAS 

22See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (F AA-20 14-0794 at 18). 
We thank you for your prompt consideration of our requested exemptions. 

Respectfully Submitted, 

Joseph V. Catone 

San Tan Traffic Consultants 

975 E. Riggs Rd., Ste. 12-460 

Chandler, AZ 85249 

Phone: 602.999.2125 

Email: jcatone@santanrecon.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: 

I. 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 

1 0. Equipment Checklist 

11. VAS Manufacturer's Manuals 

a. User Manuals 

b. VAS Maintenance Manuals