UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

LEADING EDGE ASSOCIATES, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE

PRECISIONVISION 10 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on February 5, 2015

GREGORY S. WINTON, ESQ.

JARED M. ALLEN, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner
2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .................................................................................3

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .................................................4

BACKGROUND .................................................................................................................4

BASIS FOR PETITION ......................................................................................................5

NAME AND ADDRESS OF PETITIONER.................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH LEADING EDGE 

ASSOCIATES, INC. SEEKS EXEMPTION................................................................8

THE EXTENT OF RELIEF LEADING EDGE ASSOCIATES, INC. SEEKS AND 

THE REASON LEADING EDGE ASSOCIATES, INC. SEEKS THE RELIEF.......11

THE REASONS WHY GRANTING LEADING EDGE ASSOCIATES, INC.'S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ............................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT LEADING EDGE ASSOCIATES, INC.'S REQUEST ......................34

CONCLUSION.................................................................................................................34
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle 

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing 
4

SUMMARY

Leading Edge Associates, Inc. seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Leading Edge

Associates, Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial acquisitions and research over certain rural areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Leading Edge Associates, Inc. (hereinafter referred to as “Leading Edge”) provides its 

clients with expertise and knowledge in advanced technologies and solutions to increase 

efficiency, productivity and effectiveness. Leading Edge is experienced in all aspects of disease 

vector control, agriculture, and forestry. The objective of Leading Edge’s mosquito control 

operations is the protection of public health from disease vectors (i.e., small organisms such as 

mosquitoes or ticks that can carry pathogens from person to person and place to place) and 

insuring a quality of life from nuisance mosquitoes. 

BACKGROUND

Unmanned Aircraft System: PrecisionVision 10 UAS

Leading Edge seeks an exemption to operate the Leading Edge PrecisionVision 10 UAS

for compensation or hire within the NAS. The PrecisionVision 10 UAS is comprised of a 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground 

Control Station (GCS). The PrecisionVision 10 UA has a maximum gross weight of 

approximately 27 pounds, while having a length of 57 inches, width of 14 inches, height of 20

inches, and maximum speed of approximately 19 knots. The PrecisionVision 10 UA is equipped 
5

with one main rotor and one tail rotor, driven by a Lithium Polymer battery powered electric 

motor.

The PrecisionVision 10 UA that will be operated by Leading Edge will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

BASIS FOR PETITION

Petitioner, Leading Edge Associates, Inc., by and through undersigned counsel, pursuant 

to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

PrecisionVision 10 UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Leading Edge’s operation of the PrecisionVision 10 UAS

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Leading Edge requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Leading Edge submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Leading Edge will use trained technicians to perform maintenance, 
6

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the PrecisionVision 10 UAS Operation Manual,

Maintenance Schedule and Manual, Airframe Maintenance Manual, and Spektrum DX8 

Instruction Manual). Furthermore, Leading Edge will document and maintain all maintenance 

records for the PrecisionVision 10 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Leading Edge to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the PrecisionVision 10

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

and maintaining appropriate distances from people, vessels, vehicles and structures.

Leading Edge seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the PrecisionVision 10 UAS does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Leading Edge submits that it will ensure that the 

PrecisionVision 10 UAS is in an airworthy condition, prior to every flight, by determining that

the UAS is in compliance with the operating documents (i.e., the PrecisionVision 10 UAS 

Operation Manual, Maintenance Schedule and Manual, Airframe Maintenance Manual, and

Spektrum DX8 Instruction Manual), and that the aircraft is in a condition for safe flight.

 Leading Edge also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the PrecisionVision 10 UA will not have a typical barometric altimeter 

onboard. However, altitude information of the PrecisionVision 10 UA will be provided to the 

PIC via Global Positioning System (GPS) equipment and a radio communications telemetry data 
7

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with Leading Edge’s operation of the PrecisionVision 10 UA 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Leading Edge seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Leading Edge submits that 

safety will not be affected by operation of the PrecisionVision 10 UA during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery 

power remaining).

In accordance with 14 C.F.R. § 11.81, Leading Edge provides the following information 

in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Leading Edge Associates, Inc.

702 Tulip Tree Court

Fletcher, North Carolina 28732

The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com
8

B. The Specific Sections Of 14 C.F.R. From Which Leading Edge Seeks Exemption.

1. Leading Edge Seeks Exemption From The Requirements Of Section 

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

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

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC 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.

2. Leading Edge Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

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

3. Leading Edge Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 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.
9

4. Leading Edge Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following:

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 

minutes.

5. Leading Edge Seeks Exemption From The Requirement Of Section 

91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following:

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[.]

6. Leading Edge Seeks Exemption From The Requirements Of Section 

91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following:

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.]

7. Leading Edge Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(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
10

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

with part 21 of this chapter.

8. Leading Edge Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following:

(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.

(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 
11

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.

C. The Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks The 

Relief.

1. Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks 

Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot or 

higher level certificate, as well as a current and valid airman medical certificate, and who has

met certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC 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.
12

As set forth more fully below, Leading Edge submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the PrecisionVision 10 UAS unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate the PrecisionVision 10 UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and structures.

Further, Leading Edge submits that all flights of the PrecisionVision 10 UAS, conducted 

by the PIC pursuant to the grant of this Petition: (1) will be incidental to Leading Edge’s 

business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks 

Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow Leading Edge to determine that the PrecisionVision 10 UAS is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the PrecisionVision 10 UAS Operation Manual, Maintenance Schedule and 

Manual, Airframe Maintenance Manual, and Spektrum DX8 Instruction Manual).

Leading Edge seeks the requested relief because the PrecisionVision 10 UAS does not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

Leading Edge will ensure that the PrecisionVision 10 UAS is in an airworthy condition based 

upon its compliance with the operating documents (i.e., the PrecisionVision 10 UAS Operation 

Manual, Maintenance Schedule and Manual, Airframe Maintenance Manual, and Spektrum DX8 

Instruction Manual) prior to every flight, and further, determine that the aircraft is in a condition 

for safe flight, as stated in the conditions and limitations below.
13

3. Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks 

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the PrecisionVision 10 UAS, which utilizes a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any 

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet

above ground level (AGL), Leading Edge seeks the requested relief because the PrecisionVision 

10 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

PrecisionVision 10 UA is equipped with a barometric pressure sensor and GPS equipment, 

which automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on the heads-up display of the 

GCS.

4. Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks 

Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered PrecisionVision 10 UA

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery power
14

remaining). Leading Edge seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered PrecisionVision 10 UA will severely 

constrain the practicality of any aerial acquisition and research flight operations that Leading 

Edge proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the PrecisionVision 10

UAS, the PrecisionVision 10 operating documents, and Leading Edge’s proposed operating 

limitations, ensure that Leading Edge will safely operate the battery powered PrecisionVision 10

UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes

(i.e., 25 percent battery power remaining).

5. Extent Of Relief Leading Edge Seeks And The Reason Leading Edge Seeks 

Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Leading Edge requests relief from these 

Sections because the PrecisionVision 10 UAS does not require an airworthiness certificate. As 

set forth more fully below, the PrecisionVision 10 UAS meets the conditions of FMRA Section 

333 for operation without an airworthiness certificate. Accordingly, Leading Edge will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS

using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

the PrecisionVision 10 UAS Operation Manual, Maintenance Schedule and Manual, Airframe 

Maintenance Manual, and Spektrum DX8 Instruction Manual). Furthermore, Leading Edge will 

document and maintain all maintenance records for the PrecisionVision 10 UAS. 
15

D. The Reasons Why Granting Leading Edge’s Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Leading Edge to

safely, efficiently, and economically perform aerial acquisitions, aerial application, and research

over rural areas of the United States, commercially, in support of government entities, 

agriculture, and scientific studies. Specifically, Leading Edge will operate the PrecisionVision 

10 UAS as part of an integrated mosquito management program, which will serve to protect 

public health and reduce vector borne disease transmission.

Additionally, use of the PrecisionVision 10 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of 

Leading Edge’s proposed operation of the PrecisionVision 10 UAS will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From The Aerial Acquisition And Research 

Performed.

Leading Edge submits this Petition to commercially operate the PrecisionVision 10 UAS 

and perform aerial acquisition, aerial application, and research throughout rural areas of the 

United States, as part of mosquito control operations including pest/vector management 

programs, source analysis and reduction strategies, breeding habitat surveillance, and the 

creation of predictive mosquito breeding models. Therefore, the operations that Leading Edge 

will perform with the PrecisionVision 10 UAS will directly benefit the public and promote 

public health by enhancing current mosquito suppression efforts, and help prevent the spread of 

disease through nuisance mosquito species.

The mission statement and objective of Leading Edge’s mosquito control operation is the 

protection of public health from disease vectors (i.e., small organisms such as mosquitoes or 
16

ticks that can carry pathogens from person to person and place to place), as well as insuring a 

quality of life free from nuisance mosquitoes. 

Leading Edge’s use of the PrecisionVision 10 UAS, accompanied with imagery sensors 

for creating geo-reference mosaic imagery, 3D elevation profiles and other models, will greatly 

enhance the efficiency and precision of mosquito control operations. 

Specifically, Leading Edge’s use of the PrecisionVision 10 UAS will increase the 

precision and efficiency of strategies that are vital to integrated pest/vector management 

programs, such as source reduction, source analysis, and breeding habitat surveillance. 

Moreover, an increase in the precision and efficiency of these strategies will result in a decreased 

use of costly larvacides and insecticides.

The public will also benefit through Leading Edge’s use of the PrecisionVision 10 UAS,

since Mosquito breeding habitats are often located in areas that are inaccessible by manned 

vehicles, and/or are located in areas where the use of manned vehicles will negatively impact the 

environment. While operating in areas such as fresh and salt water marshes, pasture lands, and 

wetlands, the use of a battery operated, lightweight UAS will eliminate the harmful effects that 

manned vehicles or aircraft may have on threatened and endangered species, such as fuel 

pollution, noise pollution, and bird strikes. 

Additionally, use of the PrecisionVision 10 UAS increases the ability to respond 

effectively and efficiently during natural disasters, since response strategies that rely upon use of 

the UAS are not practical with the use of manned aircraft. 

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The PrecisionVision 10 UA is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 
17

reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of a PrecisionVision 10 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air 

and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

PrecisionVision 10 UA does not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial survey missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations. 

3. The Public Will Benefit From The Safety And Efficiency Of The 

PrecisionVision 10 UAS.

Conducting aerial acquisitions with the PrecisionVision 10 UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution 

generated during traditional aerial survey flight operations. By using battery power and electric 

motors, the PrecisionVision 10 UAS produces no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion twin 

engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The PrecisionVision 10 UA, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UA is propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the PrecisionVision 10 UAS to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside 
18

from the lack of flightcrew members located onboard the aircraft, the PrecisionVision 10 UA 

(weighing approximately 27 pounds at its maximum gross weight with a length of 57 inches, width 

of 14 inches, and with no fuel on board), has less physical potential for collateral damage to life 

and property on the ground, and in the air, compared to the manned aircraft that typically conduct 

aerial acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40 

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing Aerial Acquisition Operations With The 

PrecisionVision 10 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the PrecisionVision 10 UAS is also an economical 

alternative to using manned aircraft to conduct aerial acquisitions. As such, operation of the 

PrecisionVision 10 UAS will allow United States based companies, like Leading Edge, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered PrecisionVision 10

UAS is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the PrecisionVision 10 UAS, companies such as Leading Edge, can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the PrecisionVision 10 UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and federal 
19

tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, Leading Edge’s proposed operation of the PrecisionVision 10 UAS will not implicate 

any privacy issues. Specifically, the PrecisionVision 10 UAS will be operated only in rural 

areas, and in accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. Most significantly, the PrecisionVision 10 UA will not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly 

involved in the operation.

E. 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 Leading Edge Seeks Exemption.

1. Reasons Why The PrecisionVision 10 UAS Meets The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the 

unmanned aircraft and its operation, Leading Edge’s operation of the PrecisionVision 10 UAS 

meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 
20

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system.

In seeking this exemption, Leading Edge submits that the PrecisionVision 10 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the PrecisionVision 10 UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations.

a. The Specifications Of The PrecisionVision 10 UAS Demonstrate Its 

Safe Characteristics. 

The PrecisionVision 10 UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The PrecisionVision 10 UAS.

The technical specifications of the PrecisionVision 10 UAS are set forth by the 

PrecisionVision 10 Specifications and Data Sheet, attached hereto as Exhibit A. Exhibit A 
21

contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b)1.

ii. The PrecisionVision 10 UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A 

Defined Operational Area.

The PrecisionVision 10 UAS may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the

PrecisionVision 10 UAS is provided at pages 3-9 of the PrecisionVision 10 User Manual,

attached hereto as Exhibit B. Exhibit B contains proprietary information and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b).

iii. The PrecisionVision 10 UAS Is Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation.

When the Control Link is lost, the PrecisionVision 10 UA will remain stationary, in 

flight, for 30 seconds. If, after 30 seconds, the PrecisionVision 10 UA does not reacquire control 

link data from the GCS, the UA will assume that the Control Link is lost and the UA will return 

to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown.

When GPS signal is lost, the PrecisionVision 10 UA will continue to estimate its position 

and velocity based upon accelerometers. In the case of GPS signal loss, the UA autopilot will 

rely upon recorded pitch and roll values in order to keep the UA in a stable flight mode. In the 

alternative, the UA autopilot has the ability to allow the operator to control the desired pitch and 

roll in the unlikely event of GPS signal loss. If the operator cannot take control of the helicopter 

 

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 

11.35(b), are not to be included in the Federal Docket Management System (FDMS).
22

using the remote transmitter or CGS, the UA autopilot will keep the UA stable until GPS signal 

is reacquired. 

A complete description of the Failsafe Functions of the PrecisionVision 10 UAS are set 

forth at pages 7 through 9 (i.e., GPS Loss- Recovery Method) and pages 12 through 13 (i.e., FlyAway Prevention Measures) of the PrecisionVision 10 User Manual, attached hereto as Exhibit 

B. Exhibit B contains proprietary information and is to be held in a separate file pursuant to 14 

C.F.R. § 11.35(b).

iv. The PrecisionVision 10 GCS And Its Operation.

A complete description of the operation and specifications of the PrecisionVision 10 GCS

and flight control software is provided at pages 9 through 20 of the PrecisionVision 10 User 

Manual. A complete description of the manual control transmitter is set forth in the Spektrum 

DX8 Instruction Manual. A copy of the PrecisionVision 10 User Manual is attached hereto as 

Exhibit B, and a copy of the Spektrum DX8 Instruction Manual is attached hereto as Exhibit C. 

These exhibits are to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

b. Flight Operations Of The PrecisionVision 10 UAS Are Limited To 

The Line Of Sight Of A Certificated Pilot in Command With 

A Safety Observer.

Leading Edge will only utilize certificated pilots who possess a current and valid airman 

medical certificate to act as a pilot in command (PIC) of the PrecisionVision 10 UAS. 

Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of The PrecisionVision 10 UAS Will Be Conducted Pursuant 

To Specific Operating Limitations.

In seeking this exemption, Leading Edge proposes to commercially operate the 

PrecisionVision 10 UAS for the special purpose of conducting aerial acquisitions over rural areas 

of United States, pursuant to the following specific operating limitations:
23

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, a rotorcraft UAS weighing less than 27

pounds maximum gross weight: PrecisionVision 10 Unmanned Aircraft System. 

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the 

purpose of aerial acquisitions. 

3. The UA may not be flown at an indicated airspeed exceeding 19 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents. All altitudes 

reported to ATC must be in feet AGL. 

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or visual observer (VO) is not 

permitted. 

7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the 

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

PIC must be able to communicate verbally at all times. Electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the VO can perform the functions prescribed in the operating documents. 

8. The VO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS 

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

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA’s UAS 
24

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

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

operation or flight characteristics, e.g. replacement of a flight critical component, must 

undergo a functional test flight. The PIC who conducts the functional test flight must 

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. The PIC must also meet the flight review requirements specified 

in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). The VO is also required to complete the operator’s 

training requirements. A record of training must be documented and made available upon 

request by the Administrator. Flights for the purposes of training the operator’s PICs and 
25

VOs (training, proficiency, and experience-building) are permitted under the terms of the

exemption. However, training operations may only be conducted during dedicated 

training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 

14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

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

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

20. The UA may not operate within 5 nautical miles 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 NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

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

accordance with the operating documents. 

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

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. 

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

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

exemption. 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. All operations shall be conducted in accordance with airspace requirements in 

the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 
26

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

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

31. The UA may not be operated over congested or densely populated areas. 

32. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, VO, operator trainees or essential persons), vessels, 

vehicles, and structures unless:

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). 

33. 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. 

34. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported 

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 
27

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Leading Edge submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the PrecisionVision 10

UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the PrecisionVision 10 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering Leading Edge’s proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those 

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the PrecisionVision 10 UAS, Leading Edge submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Leading Edge’s specific proposed flight 

operations.

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, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161).

Leading Edge will not allow any PIC to operate the PrecisionVision 10 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the PrecisionVision 10

UAS training and currency requirements, that the PIC is able to safely operate the 

PrecisionVision 10 UAS in a manner consistent with this exemption, including evasive and 
28

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

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 take-offs 

and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that 

was obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during Leading Edge’s proposed operations. The Administrator has held that prior documented 

flight experience that was obtained in compliance with applicable regulations would ensure safe

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 hours make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 take-offs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.
29

Accordingly, Leading Edge will ensure safe operations by not allowing any PIC to 

operate the PrecisionVision 10 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the PrecisionVision 

10 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because 

prior to every flight, Leading Edge will ensure that the PrecisionVision 10 UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the PrecisionVision 10 UA will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA to the 

GCS for active monitoring of the flight path and altitude. This altitude information, combined 

with Leading Edge’s operation of the PrecisionVision 10 UA within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 
30

information will be generated by GPS equipment installed onboard the aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

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, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the PrecisionVision 10

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed

flight operations. Accordingly, Leading Edge will ensure that it will safely operate the battery 

powered PrecisionVision 10 UA during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes (i.e., 25 percent battery 

power remaining).

Here, as in Exemption No. 11109, the technical specifications of the PrecisionVision 10

UAS; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the PrecisionVision 10 UAS provides two audible and 

visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first 

warning occurring at 50% remaining battery power, and against at 30% remaining battery power.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating 
31

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at 

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, 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. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not 

Adversely Affect Safety.

In seeking this exemption, Leading Edge submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Leading 

Edge will use trained technicians to perform maintenance, alterations, or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed in the operating documents 

(i.e., the PrecisionVision 10 UAS Operation Manual, Maintenance Schedule and Manual, 

Airframe Maintenance Manual, and Spektrum DX8 Instruction Manual). Furthermore, Leading 

Edge will document and maintain all maintenance records for the PrecisionVision 10 UAS. 

Since the PrecisionVision 10 UAS will be inspected as prescribed by the operating 

documents, Leading Edge will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the PrecisionVision 10 UAS User Manual

is attached hereto as Exhibit B; a copy of the PrecisionVision 10 UAS Maintenance Schedule 

and Manual is attached hereto as Exhibit D; and a copy of the Airframe Maintenance Manual is 

attached hereto as Exhibit E. Exhibits B, D, and E contain proprietary information and are to be 

held in a separate file pursuant to 14 C.F.R. § 11.35(b).
32

Likewise, the exemption sought will not adversely affect safety because Leading Edge

will use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

PrecisionVision 10 UAS will be performed by trained technicians, which will document and 

maintain maintenance records for the PrecisionVision 10 UAS. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of Leading Edge’s proposed operating limitations, the operating 

documents, and the technical aspects of the PrecisionVision 10 UAS, Leading Edge submits that 

safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Leading Edge requests that the FAA

prescribe special conditions for the intended operation of the PrecisionVision 10 UAS, which 

contain such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 
33

Such special conditions will permit safe operation of the UA for the limited purpose of 

conducting aerial acquisitions over certain rural areas of the United States for compensation or 

hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe operation of the UAS in 

the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the PrecisionVision 10 UAS, since the airworthiness regulations of 14 

C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or 

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Leading Edge’s intended operation of the PrecisionVision 10

UAS, which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b).
34

F. A Summary That Can Be Published In The Federal Register, stating:

The Rules From Which Leading Edge Seeks Exemption:

Leading Edge Associates, Inc. seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Leading Edge Seeks:

This exemption will permit Leading Edge Associates, Inc. to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions and 

research over certain rural areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Leading 

Edge’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS

may operate safely in the NAS. As such, Leading Edge’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, Leading Edge will operate the PrecisionVision 10 UAS 

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise

pose a threat to national security.

CONCLUSION

As set forth herein, Leading Edge seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the PrecisionVision 10 UAS commercially, without an airworthiness certificate, for 

the limited purpose of conducting aerial acquisitions over certain rural areas of the United States. 
35

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing Leading Edge to safely, efficiently, and economically operate the 

PrecisionVision 10 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Leading Edge respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), and permit Leading Edge to operate the PrecisionVision 10 UAS commercially 

for the purpose of conducting aerial acquisitions and research over certain rural areas of the 

United States.

Dated: February 5, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________

Gregory S. Winton, Esq.

Jared M. Allen, Esq. 

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner 

cc: James H. Williams, AFS-80

Robert Pappas

Dean Griffith, Esq.