11 October 2015 

Attention:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590

RE:

New Wave Systems, Inc. requests exemption from Title 14 requirements of the Code of 

Federal Regulations (C.F.R.), sections:

- 45.23, 61.113(a), 61.113(b), 91.105(a)(2), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), and 91.417(d)

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act (MARA) of 2012 (Public Law 112-95).

Michael Breslow

President & CEO

New Wave Systems, Inc.

(480) 201-1100

mbreslow@newwave.systems
Revision 1.0 2 December 2015

CONTENTS

14 C.F.R Exemption Request Section ...................................................................... 3

INTRODUCTION.............................................................................................................. 3

BASIS FOR PETITION ................................................................................................... 4

SECTION 91.105(a)(2)..........................................................................................................................4

SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), 

91.417(d), and 91.7(a)...........................................................................................................................5

SECTION 45.23....................................................................................................................................10

SECTIONS 61.113(a) & 61.113(b)....................................................................................................11

SECTION 91.121 .................................................................................................................................13

SECTION 91.151(b).............................................................................................................................14

OPERATIONAL CONSIDERATIONS........................................................................ 16

GLOSSARY OF ABBREVIATIONS ........................................................................... 21

Appendix A – DJI S1000............................................................................................. 22

Appendix B – JR GSR260Z........................................................................................ 23

Appendix C – D Series (D800-X4, D800-X8, D800-V6, D1100-V8).................... 24

Appendix D – Pixhawk Autopilot ............................................................................. 25
Revision 1.0 3 December 2015

14 C.F.R Exemption Request Section

New Wave Systems, Inc. seeks exemption from the requirements of 14 C.F.R §§ 45.23, 

61.113(a), 61.113 (b), 91.105(a)(2), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1), 91.409 (a)(2), 91.417(a), and 91.417(b), to operate Unmanned Aerial

System(s) (UAS) pursuant to Section 333 of the FAA MARA. This exemption will permit 

New Wave Systems, Inc. to operate UAS for the commercial purposes of conducting 

aerial video and photography of agricultural fields/sites and public lands as they relate to 

agriculture over areas within the United States (US).

INTRODUCTION

New Wave Systems, Inc. employs many prior military aviation UAS pilots, engineers, and 

aviation technicians who have a combined 25+ years of unmanned/manned aviation 

experience from the US Department of Defense (DOD). New Wave Systems, Inc. pilots 

have flown over 3,000 combat hours in a variety of environments on a variety of UAS

platforms, while our engineering staff has many years of autopilot (AP) software 

development, power plants development, and general unmanned aviation experience.

New Wave System, Inc. objective is to take the DOD methodology and experience while 

operating our UAS in a more affordable, safer, and reliable manner for a variety of 

agricultural inspection purposes.
Revision 1.0 4 December 2015

BASIS FOR PETITION

New Wave Systems, Inc., pursuant to the provisions of the FAA 14 C.F.R. § 11.61 and 

the FAA MARA, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to allow New Wave Systems, Inc. to commercially

operate the DJI S-1000, JR GSR260Z, and D-Series UAS in the National Airspace 

System (NAS).

New Wave Systems, Inc. submits that the requested relief is proper since an equivalent 

level of safety can be ensured. New Wave Systems, Inc. uses experienced personnel, 

technicians, and engineers that have come from the DOD UAS industry to operate and 

perform scheduled and un-scheduled maintenance, UAS alterations, and/or preventive 

maintenance on the various UAS using methods, techniques, and practices prescribed in 

the operating documents. Additionally, New Wave Systems, Inc. has established 

procedures and practices in accordance with established UAS manufacturer practices as 

well as DOD best practices where applicable.

SECTION 91.105(a)(2)

Section 91.105, titled: Flight Crew Members at Stations, subsection (a) prescribe the 

following, in relevant part:

a) During takeoff and landing, and while en route, each required flight crewmember 

shall:

1) Keep the safety belt fastened while at the crewmember station.

New Wave Systems, Inc. seeks relief from the requirements of Section 91.105(a)(2), 

titled: Flight Crew Members at Stations. The flight crew will not be aboard the UAV, but 

will instead be located outside of the UAV on the ground. All crewmembers will either be 

standing or sitting in a chair with no available seat belt. Given that the crewmembers will 

be on the ground and in a fixed position there should be no need to provide a seat belt 

as that will not increase safety.
Revision 1.0 5 December 2015

SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), 

91.417(d), and 91.7(a)

Section 91.405, titled: Maintenance Required, subsection (a) prescribes the following, in 

relevant part:

Each owner or operator of an aircraft

a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter;

Section 91.407, titled: Operation After Maintenance, Preventive Maintenance, Rebuilding, 

or Alteration, subsection (a)(1) prescribes the following, in relevant part:

a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—
Revision 1.0 6 December 2015

1) It has been approved for return to service by a person authorized under 

§43.7 of this chapter;

Section 91.409, titled: Inspections, subsections (a)(1) and (a)(2) prescribes the following, 

in relevant part:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had

1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by §43.7 of 

this chapter; or

2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under 

paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized 

to perform annual inspections and is entered as an “annual” inspection in 

the required maintenance records.

a) Except for work performed in accordance with§§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include

i. A description (or reference to data acceptable to the 

Administrator) of the work performed; and

ii. The date of completion of the work performed; and

iii. The signature, and certificate number of the person approving the 

aircraft for return to service.
Revision 1.0 7 December 2015

2) Records containing the following information:

i. The total time in service of the airframe, each engine, each 

propeller, and each rotor

ii. The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

iii. The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

iv. The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.

v. The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, 

the AD or safety directive number and revision date. If the AD or 

safety directive involves recurring action, the time and date when 

the next action is required.

vi. Copies of the forms prescribed by§ 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

b) The owner or operator shall retain the following records for the periods 

prescribed:

1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after 

the work is performed.

2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

3) A list of defects furnished to a registered owner or operator under§ 43.11 

of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service.

d) When a fuel tank is installed within the passenger compartment or a baggage 

compartment pursuant to part 43 of this chapter, a copy of FAA Form 337 shall 

be kept on board the modified aircraft by the owner or operator.
Revision 1.0 8 December 2015

Section 91.7, titled: Civil Aircraft Airworthiness, subsection (a) prescribes the following, in 

relevant part:

b) No person may operate a civil aircraft unless it is in an airworthy condition.

New Wave Systems, Inc. requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1), 91.409(a)(2), 91.417(a), 91.417(b), 91.417(d), and 91.7(a) as these 

sections set forth requirements for maintenance which apply to aircraft with an 

airworthiness certificate.

The DJI S-1000, JR GSR260Z, and D-Series UAS operating characteristics meet the 

conditions of the FAA MARA Section 333 for operating speed, gross take-off weight 

(GTOW), size, and scope of area operations based on visual line-of-sight (VLOS), and 

therefore will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H.

New Wave Systems, Inc. seeks relief from Section 91.7(a), titled: Civil Aircraft 

Airworthiness, because the above mentioned UAS do not require airworthiness 

certificates in accordance with 14 C.F.R. Part 21, Subpart H. As such, New Wave 

Systems, Inc. will ensure that the above mentioned UAS are in an airworthy condition 

prior to every flight in accordance with (IAW) UAS manufacturer and New Wave Systems, 

Inc. operating documents.

New Wave Systems, Inc. will maintain records on each UAS where applicable to include:

1. Records of the maintenance, preventive maintenance, alterations, and other 

required or approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. The 

records will include:

a. A description (or reference to data acceptable to the Administrator) of the 

work performed; and

i. The date of completion of the work performed; and 

ii. The signature of the person approving the aircraft for return to 

service
Revision 1.0 9 December 2015

2. Records containing the following information: 

a. The total time in service of the airframe and of each engine

b. The current status of life-limited parts of each airframe and engine 

c. The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis

d. The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and 

its parts are maintained

3. The owner or operator shall retain the following records for the periods prescribed: 

a. The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after 

the work is performed

b. The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold

The FAA has previously granted relief from Section 91.405(a), 91.407(a)(1), 91.409(a)(1), 

91.409(a)(2), 91.417(a), 91.417(b), 91.417(d), and 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, and 11065).
Revision 1.0 10 December 2015

SECTION 45.23

Section 45.23, titled: Display of Marks; General, subsection (b) prescribe the following, in 

relevant part:

b) 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.

New Wave Systems, Inc. seeks relief from the requirements of Section 45.23(b), titled: 

Display of Marks; General. The UAV will have no airworthiness certificate and given the 

size of the UAV, two-inch lettering will be impossible to place on the UAV. The UAV has 

no cabin and therefore no entrance to any form of cabin/cockpit/pilot station where the 

word “experimental” can be placed. The UAV will 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. The UAV will also be marked 

with “experimental” and both markings will be as large as practicable given the size of the 

UAS in a location where the PIC/VO/Etc. can see the markings.

The FAA has previously granted relief from Section 45.23 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, and 11065).
Revision 1.0 11 December 2015

SECTIONS 61.113(a) & 61.113(b)

Section 61.113: Private Pilot Privileges and Limitations: Pilot in Command, subsections 

(a) and (b) prescribe the following, in relevant part:

a) Except as provided in paragraphs (b) through (h) of this section, no person who 

holds a private pilot certificate may act as pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as pilot in command of an aircraft.

b) A private pilot may, for compensation or hire, 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.

New Wave Systems, Inc. seeks relief from certain requirements of Section 61.113(a) and 

61.113(b), titled: Private Pilot Privileges and Limitations: Pilot in Command. New Wave 

Systems, Inc. seeks to the extent necessary to allow a Pilot in Command (PIC) holding a 

private pilot or higher level certificate, as well as an airman third class medical certificate, 

and who has demonstrated, by meeting flight hour currency requirements as established 

by New Wave Systems, Inc., that the PIC is able to safely operate the above mentioned

UAS.

New Wave Systems, Inc. will operate UAS at all times in an unmanned state and requests 

relief based on this operating constraint. All UAS flights conducted by the PIC pursuant 

to the grant of this Petition: (1) will be incidental to New Wave Systems, Inc. business; 

and (2) will not carry passengers or property for compensation or hire. New Wave 

Systems, Inc. employs prior military UAS pilots, and has established training methods 

IAW applicable DOD UAS standards as well as manufacturer documentation. The current 

training and granting of a private pilot’s license does not guarantee the effective operation 

of UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. New Wave Systems, Inc. believes that the proficiency of our pilots and the 

standards implemented based on years of UAS experience enables our UAS pilots to 
Revision 1.0 12 December 2015

operate at a level of proficiency that exceeds an equivalent level of safety as that of a 

traditional manned commercial pilot.

New Wave Systems, Inc. minimum requirements for the PIC include:

1. Private Pilot’s license and a Class III medical;

2. A minimum of 100 flight cycles and 50 logged hours of total time as an UAS pilot

3. A minimum of at least 10 hours logged as a UAS pilot with a similar UAS type 

make and model of UAS to be utilized for operations under the exemption within 

the preceding 30 days

4. A minimum of 20 take-offs and landings in the preceding 30 days

5. Undergone a qualification process as specified in the Flight Operations & 

Procedures Manual consisting of a knowledge & skill test of the UAS to be used

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, and 11065). 
Revision 1.0 13 December 2015

SECTION 91.121

Section 91.121: Altimeter Settings, subsections (a) prescribe the following, in relevant 

part:

a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating

1) Below 18,000 feet MSL, to

i. The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station; or

iii. In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available 

before departure;

New Wave Systems, Inc. seeks an exemption from the requirements of Section 91.121, 

titled Altimeter Settings, as the above mentioned UAS will not have a traditional aviation 

style barometric altimeter onboard. To compensate for this, altitude information will be 

provided to the PIC via the UAS through the radio command and control (C2) 

communications telemetry data link. The C2 downlinks from the unmanned aerial vehicle 

(UAV) to the ground control station (GCS) for active monitoring of the flight path by global 

position system and micro-electro-mechanical (MEM) barometer sensor. This altitude 

information in addition to the PIC estimation of height via VLOS ensures a level of safety 

equivalent to Section 91.121.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, and 11065). 
Revision 1.0 14 December 2015

SECTION 91.151(b)

Section 91.151(b): Fuel Requirements for Flight in VFR Conditions, subsection (b) 

prescribe the following, in relevant part:

b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel/battery 

life to fly to any point of intended landing and, assuming normal cruising speed, 

to fly up to 75% of the anticipated fuel/battery life.

New Wave Systems, Inc. seeks an exemption from the requirements of Section 

91.151(b), entitled: Fuel Requirements for Flight in VFR Conditions. New Wave Systems, 

Inc. submits that safety will not be affected by operation of the either the battery powered 

DJI S-1000 or JR GSR260Z gasoline powered UAS during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR).

New Wave Systems, Inc. DJI S-1000 configuration will yield enough battery power to fly 

for an anticipated duration of approximately 25 minutes under ideal flying conditions. New 

Wave Systems, Inc. configuration of the S-1000 includes power indicators to show an 

estimation of how much battery power is left, as well as AP fail-safe conditions that will 

auto land the UAV at the closest user defined pre-programmed GPS waypoint (WP) upon 

a user defined low battery powered condition.

New Wave Systems, Inc. JR GSR260Z configuration yields anticipated flight durations of 

up to approximately 75 minutes under ideal flying conditions and depending upon fuel 

load. New Wave Systems, Inc. configuration of the JR GSR260Z includes power 

indicators to show an estimation of how much fuel is left, as well as AP fail-safe conditions 

that will auto land the UAV at the closest user defined pre-programmed GPS waypoint 

(WP) upon a user defined low fuel condition.

New Wave Systems, Inc. D-Series (D800-X4, D800-X8, D800-V6, D1100-V8)

configuration will yield enough battery power to fly for an anticipated duration of 

approximately 45 minutes under ideal flying conditions. New Wave Systems, Inc. 

configuration of the D-Series includes power indicators to show an estimation of how 

much battery power is left, as well as AP fail-safe conditions that will auto land the UAV 
Revision 1.0 15 December 2015

at the closest user defined pre-programmed GPS waypoint (WP) upon a user defined low 

battery powered condition.

The FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, and 11065).
Revision 1.0 16 December 2015

OPERATIONAL CONSIDERATIONS

New Wave Systems, Inc. utilizes the commercial Pixhawk AP with New Wave Systems, 

Inc. firmware and GCS software. Safety features that are utilized in the AP and its 

associated software include:

1. Auto descent/landing failsafe conditions:

a. If C2 telemetry signal were to be severed or severely degraded the UAV will 

have the capability to return to the launch point and land given that it does 

not violate the battery/fuel level condition

b. If battery/fuel levels were to drop below a user defined value

2. In case of GPS failure, the UAV has the capability to use secondary 

measurement systems, such as the compass and barometer to return to the 

launch point area where the PIC can assume control

3. The GCS displays pilot flight display (PFD) and system health information, to 

include battery/fuel levels, GPS health, and UAV relative position and heading 

to the PIC

4. A geo-fence can be established by the user to prevent the UAV from flying 

above 400’ AGL and flying beyond VLOS distances for specific UAV

New Wave Systems, Inc. flight crew personnel and duties will include:

1. Visual observes (VO)/spotters

a. VOs/PICs will utilize radio spectrum analysis to detect possible interference 

on the C2 frequencies utilized for UAV

b. The VO will assist the PIC in maintaining VLOS of the UAV where 

necessary and watching the GCS for safety of flight and health of the UAV

c. The vehicle will always remain in direct VLOS to the PIC/VO

2. PIC

a. The PIC will be the sole operator of the UAV from take-off through landing

b. A briefing will be conducted by the PIC in regard to the planned UAS 

operations prior to each day’s activities. The PIC will ensure that all 

personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing
Revision 1.0 17 December 2015

c. The PIC will obtain the consent of all persons involved in the UAS 

operations and will ensure that only consenting persons will be allowed 

within 100 feet of the flight operations area

d. Prior to each flight the PIC must inspect (pre-flight) the UAS IAW 

established documentation to ensure it is in a safe-for-flight condition

e. The documents required under 14 CFR §§ 91.9 and 91.203 must be 

available to the PIC at the GCS of the UAS any time the UAV is operating

i. These documents must be made available to the Administrator or 

any law enforcement official upon request

3. PIC/VO

a. PIC/VO will at all times be able to communicate by voice

b. The PIC and/or VO will get written permission from the relevant property 

holders where flight operations will be conducted

4. General Personnel

a. Any person(s) who conduct any form of maintenance on the UAS will:

i. Log all maintenance actions

ii. Sign all maintenance actions

iii. Make available to all flight crew personnel maintenance logs

Physical Operation Limitations

1. The UAV will weigh less than 55 pounds GTOW

2. The UAV will not fly at a ground/airspeed exceeding 100mph, whichever is 

lesser

3. Flights will be operated at an altitude of no more than 400 feet above ground 

level (AGL)

a. A geo-fence will be established at 400 feet AGL

4. The UAV will be operated within VLOS of the PIC/VO at all times

a. This requires the PIC/VO to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued 

medical certificate
Revision 1.0 18 December 2015

b. The PIC will establish a geo-fence VLOS distance suitable for the type of 

UAS being operated

5. All UAS operations will utilize a VO

6. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics will undergo a functional check flight (FCF) in 

accordance with the operator’s manual

a. The PIC who conducts the FCF must make an entry in the UAS aircraft 

records of the flight

b. The FCF will be conducted at least 500 horizontal feet away from any 

persons not directly involved with the FCF

7. All flight crew personnel will be current and proficient as outlined by appropriate 

documentation

8. The UAV will remain clear and yield the right of way to all other manned 

operations and activities at all times

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

a. All operations must be conducted under visual meteorological conditions 

(VMC)

b. Flights under special visual flight rules (SVFR) are not authorized

10. The UAS will not be operated by the PIC from any moving device or vehicle

11. The UAV will 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

12. The UAV will not operate in Class B, C, or D airspace without written approval 

from the FAA

13. The UA may not operate within 5 nautical miles of the geographic center of a 

non-towered airport 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 NOTAM as required by the 

operator’s COA

a. The letter of agreement with the airport management must be made 

available to the Administrator upon request.
Revision 1.0 19 December 2015

14. Any incident and/or accident which occurs within the operational area as 

defined by the applicable COA will be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours.

15. Any incident and/or accident which occurs within the operational area as 

defined by the applicable COA will be reported to the National Transportation 

Safety Board (NTSB) within 24 hours.

16. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under this 

petition of exemption.

a. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation.

17. At least three days before scheduled infrastructure inspection, the operator of 

the UAS affected by this exemption must submit a written Plan of Activities to 

the local FSDO with jurisdiction over the area of proposed infrastructure 

inspection. 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 infrastructure

inspection operations conducted under this petition 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 infrastructure 

inspection event

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the infrastructure inspection 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
Revision 1.0 20 December 2015

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

city, town, county, and/or state over which infrastructure inspection will be 

conducted and the altitudes essential to accomplish the operation.
Revision 1.0 21 December 2015

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AP Auto-Pilot

ATC Air Traffic Control

ATO Air Traffic Organization

CFR Code of Federal Regulations

COA Certificate of Authorization

C2 Command & Control

DOD Department of Defense

FAA Federal Aviation Administration

GCS Ground Control Station 

GPS Global Positioning System

MEM Micro-Electrical-Mechanical

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

MARA Modernization and Reform Act of 2012

SO Safety Observer

SOP Standard Operating Procedures

UAV Unmanned Aerial Vehicle

UAS Unmanned Aerial System

US United States

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

WP Waypoint
Revision 1.0 22 December 2015

Appendix A – DJI S1000

See Attached Manual:

DJI S1000 User Manual V1.10 Supplemental Manual
Revision 1.0 23 December 2015

Appendix B – JR GSR260Z

See Attached Manual:

JR GSR260Z Supplemental Manual
Revision 1.0 24 December 2015

Appendix C – D Series (D800-X4, D800-X8, D800-V6, D1100-V8)

See Attached Manual:

GD-X8 & GD-6-V2 Supplemental Manual

The D Series UAVs are similar to the Gryphon Dynamics 800 and 1100 series UAVs, 

with the exception of the landing struts. The D Series UAVs do not have associated 

manuals and as such we have supplied the Gryphon Dynamics Manuals for review.
Revision 1.0 25 December 2015

Appendix D – Pixhawk Autopilot

See attached Manual:

3D Robotics PixHawk Manual Revision 7 Supplemental Manual