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October 1, 2015

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition of USA Unmanned Aeronautical Systems Solutions Corporation for an 

Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to 

Operate Unmanned Aircraft Systems for Aerial Data Collection, sUAS Flight Training, Aerial 

Photography and Videography, Support News Services, Real Estate Photography and 

Videography, Construction, Waterway and Land Planning and use of Agriculture, Education, 

Oil and Gas Industry Infrastructure Inspection and Demonstration Flights.

Dear Sir or Madam:

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

and 14 C.F.R. Part 11, USA Unmanned Aeronautical Systems Solutions Corporation. (“U2 

SOLUTIONS”) hereby applies for an exemption from the Federal Aviation Regulations 

identified below to allow for the commercial operation of the DJI Inspire 1 (“Inspire”), the DJI 

Spreading Wings S-1000 (“Spreading Wings”), the DJI Spreading Wings S-900 (“Spreading 

Wings”), the DJI Phantom 2 (“Phantom 2”), the DJI Phantom 3 (“Phantom 3”), the 3DR AeroM (“Aero-M”), the 3DR Solo (“Solo”), and the PrecisionHawk Lancaster (:Lancaster”)

unmanned aircraft systems for aerial data collection, sUAS flight training, aerial photography

and videography, support news services, real estate photography and videography, construction, 

waterway and land planning and use of agriculture, education, oil and gas industry infrastructure 

inspection and demonstration flights.

U2 SOLUTIONS requests that the FAA review this petition pursuant to its “summary grant” 

process as the FAA has already granted exemptions similar in all material respects to this 

petition. See FAA Grant of Exception Nos. 11062, 11109, 11112, and 11213. The reasons stated 

by the FAA in granting the exemptions listed above also apply to this petition, and the grant of 

this petition is in the public interest.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED 

U2 SOLUTIONS requests exemption from the following regulations: 

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27; 

 14 C.F.R § 45.23(b); 

 14 C.F.R. § 45.27(a); 

 14 C.F.R § 61.113; 

 14 C.F.R § 91.7(a); 
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 14 C.F.R § 91.9(b)(2); 

 14 C.F.R § 91.9(c); 

 14 C.F.R § 91.103; 

 14 C.F.R § 91.109(a); 

 14 C.F.R § 91.119; 

 14 C.F.R § 91.121;

 14 C.F.R § 91.151(a) & (b) 

 14 C.F.R § 91.203 (a) & (b); 

 14 C.F.R § 91.405(a); 

 14 C.F.R § 91.407(a)(l); 

 14 C.F.R § 91.409(a)(2); 

 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the User Manuals for Inspire, the Spreading 

Wings, the Phantom 2&3, the Aero, the Solo and the Lancaster (together, the “Manuals”).

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS 

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system (“UAS”) where it does not 

create a hazard to users of the national airspace system (“NAS”) or the public or pose a threat to 

national security based on the following considerations:

 The size, weight, speed and operational capability; 

 Operation in proximity to airports and populated areas; and 

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator 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), 

44701-44716, 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. 14 C.F.R. § 11.81.

III. DESCRIPTION OF U2 SOLUTIONS AND ITS SERVICES

U2 SOLUTIONS provides aerial data capture and imaging services, as well as, sUAS flight 

training, aerial photography and videography, support news services, construction waterway

inspections and land planning, education, and demonstration flights for a variety of industries 

including engineering, infrastructure, energy, agriculture, real estate, sports, wild life, and 

insurance. U2 SOLUTIONS is headquartered in DeMotte, Indiana.
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Nicholas Van Houten, CEO

USA Unmanned Aeronautical Systems Solutions Corporation

9729 North Bunker Hill Road

Demotte, IN 46310

Tel (219) 345-2413

IV. DESCRIPTION OF PROPOSED OPERATIONS

U2 SOLUTIONS is requesting exemptions from applicable Federal Aviation Regulations 

(FARs) pursuant to Section 333 of the Reform Act to perform aerial data capture and imaging 

services for a variety of industries including sUAS flight training, aerial photography and 

videography, support news services, construction waterway inspections and land planning, 

education, and demonstration flights engineering, infrastructure, energy, agriculture, real estate, 

sports, wild life, and insurance.

These types of services are typically performed by helicopter or fixed wing aircraft. Use of a 

UAS will reduce safety risks because the UAS will not carry flammable fuel or a pilot, and UAS 

operations can be performed at considerable savings. The UAS will also allow for better imagery

than can be produced by using a helicopter or fixed wing aircraft.

A. Aircraft to be Operated

1. DJI Inspire 1

U2 SOLUTIONS will use the Inspire as one of the aircraft to provide its services. The FAA has 

already approved the Inspire for commercial use in FAA Exemption No. 11679 (FAA Docket 

No. FAA-2015-0706). The Inspire is shown in Figure 1 below.

Figure 1– DJI Inspire 1
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The Inspire is more fully described in the Inspire User Manual.

2. DJI Spreading Wings S-900

U2 SOLUTIONS will use the Spreading Wings as one of the aircraft to provide its services. The 

FAA has already approved the Spreading Wings for commercial use in FAA Exemption No. 

11521 (FAA Docket No. FAA-2014-0947). The Spreading Wings is shown in Figure 2 below.

Figure 2– DJI Spreading Wings S-900

The Spreading Wings is more fully described in the Spreading Wings User Manual.

3. DJI Spreading Wings S-1000

U2 SOLUTIONS will use the Spreading Wings as one of the aircraft to provide its services. The 

FAA has already approved the Spreading Wings for commercial use in FAA Exemption No. 

11521 (FAA Docket No. FAA-2014-0947). The Spreading Wings is shown in Figure 3 below.
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Figure 3– DJI Spreading Wings S-1000

The Spreading Wings is more fully described in the Spreading Wings User Manual.

4. DJI Phantom 2

U2 SOLUTIONS will use the Phantom 2 as one of the aircraft to provide its services. The FAA 

has already approved the Phantom 3 for commercial use in FAA Exemption No. 11696 (FAA 

Docket No. FAA-2015-0746). The Phantom 2 is shown in Figure 4 below.
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Figure 4– DJI Phantom 2

The Phantom 2 is more fully described in the Phantom 2 User Manual.

5. DJI Phantom 3

U2 SOLUTIONS will use the Phantom 3 as one of the aircraft to provide its services. The FAA 

has already approved the Phantom 3 for commercial use in FAA Exemption No. 11696 (FAA 

Docket No. FAA-2015-0746). The Phantom 3 is shown in Figure 5 below.
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Figure 5– DJI Phantom 3

The Phantom 3 is more fully described in the Phantom 3 User Manual.

6. 3DR Aero-M

U2 SOLUTIONS will use the 3DR Aero-M as one of the aircraft to provide its services. The 

FAA has already approved the Aero-M for commercial use in FAA Exemption No. 12842 (FAA 

Docket No. FAA-2015-2091). The Aero-M is shown in Figure 6 below.
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Figure 6– 3DR Aero-M

The Aero-M is more fully described in the Aero-M User Manual.

7. 3DR Solo

U2 SOLUTIONS will use the 3DR Solo as one of the aircraft to provide its services. The FAA 

has already approved the Solo for commercial use in FAA Exemption No. 12842 (FAA Docket 

No. FAA-2015-2091). The Solo is shown in Figure 7 below.
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Figure 7– 3DR Solo

The Solo is more fully described in the Solo User Manual.

8. PrecisionHawk Lancaster

U2 SOLUTIONS will use the PrecisionHawk Lancaster as one of the aircraft to provide its 

services. The FAA has already approved the Lancaster for commercial use in FAA Exemption 

No. 12842 (FAA Docket No. FAA-2015-2091). The Lancaster is shown in Figure 8 below.
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Figure 8– PrecisionHawk Lancaster

The Lancaster is more fully described in the Lancaster User Manual.

B. U2 SOLUTIONS’S Proposed Operations Demonstrate an Equivalent Level 

of Safety

1. General Description of Proposed Flight Operations

U2 SOLUTIONS proposes to operate within the limitations and performance specifications 

listed in this application and in the Manuals. These limitations provide for at least an equivalent, 

or higher, level of safety for operations under the current regulatory structure because the 

proposed operations are safer than conventional operations using helicopters or fixed wing 

aircraft which carry an operator and flammable fuel. The proposed flight operations are similar 

in all material respects to operations already approved by the FAA and are therefore subject to 

the FAA’s “summary grant” process.

The proposed operations do not create any hazard to users of the national airspace system or pose 

a threat to national security. The aircraft are battery operated which will not be flown with less 

than 25 percent battery life. The vehicles weigh less than 55 pounds. The vehicles will be 

operated at or below 400 feet AGL within the visual line of sight of the pilot in command. U2

SOLUTIONS’s operations will be over private or controlled access property with the permission 

of the owner/controller or authorized agent.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

proposed UAS carry no fuel, and therefore the risk of fire following an incident or accident due 

to fuel spillage is eliminated. Compared to manned aircraft, the UAS being operated by the 

petitioner reduces the risk to participating persons in close proximity to the aircraft due to the 

limited size, weight, operating conditions, and design safety features.

The petitioner’s aircraft have the capability to operate safely after experiencing certain inflight 

failures, as specified in the Manuals. The aircraft are also able to respond to a lost-link event 

with a pre-coordinated, predictable, automated flight maneuver.

2. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, UAV SOLUTIONS’s proposed 

operations would “not create a hazard to users of the national airspace system or the public or 

pose a threat to national security.” Reform Act Section 333(b)(1).

1. The aircraft weigh less than 55 pounds
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2. Each aircraft will be identified by serial number, registered with the FAA, and have 

identification (N-Number) markings as large as practicable.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and confirmed

for accuracy by PIC.

5. The PIC will ensure that before each flight, there is enough available power for the 

UAS to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power recommended by the manufacturer if greater.

6. The aircraft will be operated during daylight and in VFR conditions.

7. Flights will not exceed 400 feet AGL.

8. Flights will be operated at a lateral distance of at least 500 feet from any persons or 

property not associated with the operation who have not given prior permission.

9. Flights will be limited to a groundspeed of 100 mph.

10. Minimum crew for each flight will consist of a PIC and an Observer.

11. The PIC will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will also hold a current FAA airman medical 

certificate or a valid driver’s license issued by a state or the Federal Government. The

PIC will also meet the flight review requirements specified in 14 CFR § 61.56.

12. Prior to the flight, a Mission Plan will be created setting forth the limitations for the 

flight as well as contact information for the PIC.

13. The flight operations will yield the right of way to other manned aircraft operations.

14. All persons who are not involved with U2 Solutions’ operations will be required to be 

at least 500 feet from flight operations.

15. The aircraft will only operate over private or controlled access property with the 

permission of the owner/controller or authorized representatives.
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16. The UAS will not operate within 5 nautical miles of an airport unless a letter of 

agreement is obtained.

17. All required permission and permits will be obtained from territory, state, county or 

city jurisdictions prior to flight.

18. Prior to commencing operations, if needed to operate above 200 feet, U2 Solutions 

will obtain a Certificate of Waiver or Authorization (COA) from the FAA.

19. If the aircraft loses communications, it will have the capability to return to a 

predetermined location within the operational area and land.

20. If the aircraft loses its GPS signal it will have the capability of being flown manually

to a predetermined location within the operational area and land.

21. The flight will be aborted in case of unpredicted obstacles or emergencies.

22. UAS operations will be conducted within the parameters of the Manuals.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are more fully documented in 

the attached Manuals.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

U2 SOLUTIONS 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. Listed below are (1) the 

specific FAR sections for which exemption is sought, and (2) the operating procedures and 

safeguards that U2 SOLUTIONS has established which will ensure a level of safety better than 

or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

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

C.F.R. § 91.203(a)(1)

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

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

aircraft normally used for the same application. These criteria are met with this petition, and 

therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-
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0352 at 13-14, 22. If, however, the FAA determines that there are some characteristics of the 

UASs that fail to meet the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety: The UASs are safe when taking into account their size, weight, 

speed, and operational capability. They weigh less than 55 pounds and will be flown at speeds 

less than 100 miles per hour, and in visual line of sight of the operator. The UASs do not carry

pilots, passengers, explosive materials, or flammable liquid fuels. The UASs will be operated 

within the parameters of their respective Manuals.

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or fixed 

wing aircraft operating with an airworthiness certificate without the restrictions and conditions 

proposed here.

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 UASs would otherwise require certification under Part 27, 

U2 SOLUTIONS seeks an exemption from Part 27’s airworthiness standards for the same 

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

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

Identification Requirements

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) states:

Rotorcraft. 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.

14 C.F.R. § 91.9(c) states:

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

accordance with part 45 of this chapter

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

was warranted provided that the aircraft “have identification (N-Number) markings in 
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accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See 

Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.

Equivalent Level of Safety: U2 SOLUTIONS will mark all UASs with their N-Number in a 

prominent spot on the fuselage with markings that are as large as practicable.

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

U2 SOLUTIONS seeks exemption from 14 CFR § 61.113, which restricts private pilots 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 pilot is 

carrying passengers or cargo for hire.

While the UAS will be operated as part of a commercial operation, they carry neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined 

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

the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot 

certificate and a class II medical certificate. The FAA has also determined that the required 

knowledge for a commercial pilot covers the same fundamental principles as a private pilot.

The FAA has also granted exemptions allowing operations by people who hold an airline 

transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. 

The PIC must also meet the flight review requirements specified in 14 CFR § 61.56. See FAA 

Exemption No. 11374.

U2 SOLUTIONS will ensure the PIC will meet the requirements listed in the above paragraph. 

U2 SOLUTIONS will also ensure the PIC will have completed the manufacturers’ training 

guidelines outlined in the Manuals. 

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the 

overriding safety factor for the limited operations proposed by the petitioner to be the airmanship 

skills acquired through UAS-specific flight cycles, flight time, and specific make and model 

experience, culminating in verification through testing.” See Exemption No. 11062, Docket No. 

FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by 

requiring the knowledge and experience in the UAS operations described above.

The restrictions U2 SOLUTIONS has placed on its UAS operations meet or exceed the 

restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352 and those 

listed in the FAA’s “summary grant” process.

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

U2 SOLUTIONS seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. The FAA has stated that no exemption is 
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required to the extent that the requirements of Part 21 are waived or found inapplicable. 

Accordingly, U2 SOLUTIONS requests that the requirements for Section 91.7 be treated in 

accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

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

U2 SOLUTIONS 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. See also Grant of Exemption 

No. 11062, pp. 19-20, and Grant of Exemption No. 8607.

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

U2 SOLUTIONS seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on 

board. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight. Under 

these circumstances, the FAA has stated that no exemption is required. See Grant of Exemption 
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No. 11062, p. 20. 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 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The Manuals will be kept at the ground station with the operator at all times.

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

U2 SOLUTIONS seeks an exemption from 14 C.F.R. § 91.109(a), which provides 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 the Ground Control Station (GCS) that communicates with the 

aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on board the 

aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety

hazard. Given the size and speed of the UAS, an equivalent level of safe training can still be 

achieved without dual controls because no pilot or passengers are aboard the aircraft, and all 

persons will be a safe distance away in the event that the aircraft experiences any difficulties 

during flight instruction. In addition, U2 SOLUTIONS will conduct flight training at a remote 

facility away from population centers. These training flights will comply with the provisions in 

the Manuals. Accordingly, U2 SOLUTIONS’s proposed method of operation provides superior 

levels of safety.

I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

U2 SOLUTIONS requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. The Manuals provide for U2 SOLUTIONS 

operations at least 500 feet from persons and structures not involved in the operations. The FAA 

has already determined that relief from Section 91.119(c) is warranted for UAS operations in 

uncongested areas with similar flight restrictions as those imposed by U2 SOLUTIONS. See 

Grant of Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing aircraft 

weighing far more than the maximum weights 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 locations where it is operated. In order to avoid any risk to 

aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft are already

prohibited from operating closer than 500 from structures where U2 SOLUTIONS proses to 

operate. This is airspace where other aircraft do not normally operate. As set forth in the Manuals 
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and herein, the UAS will be operated in the remote sites, away from persons or structures not 

involved in the operation. All persons who are not involved with U2 SOLUTIONS’ operations 

will be required to be at least 500 feet from flight operations. This will pose no risk to the public 

because other aircraft are not operating in these areas.

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. The UASs proposed here use both barometric pressure sensors 

and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An 

exemption is required to the extent that the UAS does not have a barometric altimeter setting. 

The altitude of the UAS is monitored by the PIC on the ground control station and by the visual 

observer.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be 

achieved if the aircraft will be operated at or below 400 feet AGL and within visual line-of-sight

in addition to GPS based altitude information relayed in real time to the operator. See Grant of 

Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the UAS will be operated at 

or below 400 feet AGL and otherwise comply with the limitations in the Grant of Exemption No. 

11062.

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

Conditions

U2 SOLUTIONS 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 the UAS battery power means that no meaningful flight 

operations can be conducted while maintaining a 30 minute reserve. The aircraft are battery

powered with a maximum, in which, operations will not be flown with a battery at 25 percent or 

less. The PIC will ensure that before each flight, there is enough available power for the UAS to 

conduct the intended operation and to operate after that for at least five minutes or with the 

reserve power recommended by the manufacturer if greater.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if 

the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated 
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with at least 25% reserve battery power still available. See Grant of Exemption No. 11062, p. 21-

22. The FAA’s “summary grant” process provides that the PIC is prohibited from beginning a 

flight unless there is enough available power to conduct the intended operation and to operate 

after that for at least five minutes or with the reserve power recommended by the manufacturer if 

greater. See FAA Exemption No. 11374 (FAA Docket No. 2015-0091 at p. 5). The limitations 

here provide that the PIC will ensure that before each flight, there is enough available power for 

the UAS to conduct the intended operation and to operate after that for at least five minutes or 

with the reserve power recommended by the manufacturer if greater.

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

Maintenance Inspections

U2 SOLUTIONS seeks an exemption from the maintenance inspection requirements contained 

in 14 C.F.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.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 43 and these sections only apply to aircraft with an airworthiness certificate, which 

the UAS proposed here 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 Manuals. This includes maintenance, 

overhaul, replacement, and preflight inspection requirements. See Exemption No. 11062 (FAA 

Docket No. 2014-0352, at p. 14-15) and Exemption No. 11374 (FAA Docket No. 2015-0091, at 

p. 4).

U2 SOLUTIONS will follow the UAS manufacturer’s maintenance requirements. Flights will 

not be conducted unless a flight operations checklist is performed that includes all of the 

aircraft’s components.

VI. PUBLIC INTEREST

Granting U2 SOLUTIONS’s petition for exemption furthers the public interest. National policy

set by Congress favors early integration of UAS into the NAS in controlled, safe working 

environments such as proposed in this petition. By granting this petition, the FAA will fulfill 

Congress’s intent of allowing UAS to operate safely in the NAS before completion of the 

rulemaking required under Section 332 of the Reform Act.

Moreover, use of UAS will promote the efficient use of resources. The use of the UAS propped 

here will also decrease safety-related incidents involving traditional aircraft. The public has an 

interest in promoting science and technology education and in reducing the hazards and 

emissions associated with alternate use of helicopters and small airplanes to conduct similar 

operations.
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VII. PRIVACY

All flights will occur over private or controlled access property with the owner’s consent. All 

flights will be conducted in accordance with any federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

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:

U2 SOLUTIONS seeks an exemption from the following rules for aeronautical and UAS training 

and education of middle and high school students: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 

27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R 

§ 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 

14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 

91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will promote science and technology education and training while enhancing 

safety by reducing risk to the operator, the general public and property owners from the

substantial hazards associated with performing equivalent training and education using 

traditional conventional aircraft and rotorcraft.

U2 SOLUTIONS requests that the FAA grant this petition using the “summary grant” process 

such that publication in the Federal Register is not required. This petition would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner.

IX. ATTACHMENTS

Available online at https://www.dji.com/products

Attachment 1: Inspire 1 User Manual

Attachment 2: Spreading Wings S-900 User Manual

Attachment 3: Spreading Wings S-1000 User Manual

Attachment 4: Phantom 2 User Manual

Attachment 5: Phantom 3 User Manual

Available online at: https://3drobotics.com/kb/aero-m

Attachment 6: Aero-M User Manual

Available online at https://3drobotics.com/kb/solo

Attachment 7: Solo User Manual
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Available online at https://www.precisionhawk.com

Attachment 8: Lancaster User Manual

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

the CEO of USA Unmanned Aeronautical Systems Solutions Corporation.

X. CONCLUSION

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

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

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested exemptions to permit U2 SOLUTIONS to operate the UASs proposed 

here. Furthermore, this petition warrants review by the FAA under the “summary grant” process 

for immediate approval.

Respectfully submitted,

Nicholas Van Houten

CEO of U2 SOLUTIONS.