RAVEN EXECUTIVE & SECURITY SERVICES, INC.

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June 1, 2015

Via Electronic Filing

Attn: Docket Operations

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue SE, Room W12-140

West Building Ground Floor

Washington, DC 20590-0001

RE: Exemption Request; Section 333 of the FAA Modernization & Reform Act and 

Part 11 of the Federal Aviation Regulations from 14 C.F.R.; 14CFR45.23(b); 15 CFR Part 

21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 

91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a) & (b).

Dear Sir or Madame,

Raven Executive & Security Services, Inc. (henceforth referred to as “RES”) hereby 

petitions the Secretary of Transportation and the Federal Aviation Administration (“FAA”) 

for exemption to the above referenced and below more fully described Federal Aviation 

Regulations. The exemption is being sought for the purpose of utilizing Unmanned Aerial 

Systems (UAS) for the purpose of conducting inspections of vertically developed 

structures, energy pipelines, right of ways, aerial survey and photography in support of 

agricultural operations (including crop monitoring and inspection), surveying and civil 

engineering services, as well as the insurance and finance industries. The exemption will 

provide cost effective and personal safety enhancing aerial imagery services.

The leadership team at RES has a proven track record in aviation with over 1,400 hours of 

combined flight time holding Commercial and Private Pilot license certificates, instrument 

single and multi-engine land and ground instructor certificate. RES is of the opinion that 

responsible UAS operations will benefit the public interest in the following ways:

• Removal of human risk from conventional flight operations

• Removal of human risk from gas detection inspections

• Removal of human risk from vertically developed structural inspections

• Improvement in the ability to provide integrity and encroachment data to energy 

transportation facilities and infrastructures

• Improvement upon cost efficiencies associated with manned flight.

• Improvement and increased efficiencies in the agricultural industry

• Increase the sophistication of data available to insurance and financial industries for 

good decision making.

Carmen P. Gackstetter, CE O

Raven Executive & Security 

Services, Inc.

7111 Dixie Highway #149

Clarkston, Michigan 48346
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Table of Contents

PROPOSED OPERATIONS ............................................................................................................... 3

AIRCRAFTS................................................................................................................................... 3,4

THE OPERATOR.............................................................................................................................. 4

OPERATING PARAMETERS .......................................................................................................5-8

REGULATORY STATEMENT ......................................................................................................... 9

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(A))............................................ 9

SECTIONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR WHICH RELIEF IS

SOUGHT (14 C.F.R. § 11.81(B)) ................................................................................................10-13

EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(C)) ........................................................... 13,14

STATEMENT OF PUBLIC INTEREST (14 C.F.R. § 11.81(D))................................................ 14,15

REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT PUBLIC 

SAFETY (14 C.F.R. § 11.81(E))..................................................................................................15-17

FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(F)).......................................................... 18

ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81(G))........................................ 18

CONCLUSION ................................................................................................................................... 19
RAVEN EXECUTIVE & SECURITY SERVICES, INC.

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PROPOSED OPERATIONS

Raven Executive & Security Services, Inc. (RES or Petitioner) is seeking an exemption

that will permit it to perform aerial photography and surveying services for energy 

companies engaged in the research, development and maintenance of energy industry 

infrastructure, transmission, transportation and refining infrastructure and facilities, property

owners, individual farmers, agri- businesses, surveying\engineering companies, and

insurance\finance companies. These services would be used to improve overall safety of 

inspection operations, monitoring and research gathering operations normally conducted by 

manned aircraft, provide efficiencies and enhance decision-making ability through safe 

economical aerial based survey and photography. This would be done using

conventional high resolution and 3D photo/video imaging and thermal imaging

technology to study and document property or facility conditions, facility and right of way 

encroachment, the transmission and transportation infrastructure integrity and security, crop 

photosynthesis\health and also visually inspect farm ground for re-planting, tiling needs, 

as well as the need for additional farm inputs. For insurance\finance purposes it will

allow for more thorough and conclusive claim research and documentation when 

insurance claims are made at both an individual or catastrophic\regional level.

AIRCRAFT

THE PHANTOM 2 VISION+ UAS

The Phantom 2 Vision+ UAS (the “System”) is comprised of a quad-rotor unmanned

aircraft (UA) with a gross weight of 2.6 pounds and a transportable ground control

station. Capable of carrying small digital photography equipment during flight, the

electrically powered PHANTOM has an approximate maximum speed of 28.6 kts. and is

operated using the transportable ground station, by a minimum required flight crew of

one, the Operator (PIC). The system will be operated in a manner that will not pose a 

threat to persons or property in the event of motor/rotor failure. Manufacturer 

specifications attached.

UA Manual - http://www.dji.com/product/phantom-2-vision-plus/download

UA Specs - h t t p : / / w w w . d j i . c o m / p r o d u c t / p h a n t o m - 2 - v i s i o n - p l u s / s p e c

This is the same system which is the subject system in Exemption No. 11138 granted to 

Douglas Trudeau, Realtor® on January 5, 2015. Regulatory Docket No. FAA-2014-

0481.

THE DJI INSPIRE I UAS

The DJI model T600 INSPIRE I (the “System”) is comprised of a small quad-rotor

design unmanned aircraft (UA) and a transportable ground control station. The UA 

system gross weight configuration is 2935 g (6.5 pounds). The UA is capable of

carrying small digital photography equipment during flight, the electrically powered

INSPIRE I has an approximate maximum speed of 43 knots and may be operated using

the transportable ground station, by a minimum required flight crew of one, the Operator 

(PIC). The system will be operated in a manner that will not pose a threat to persons or 
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property in the event of motor/rotor failure. Manufacturer specifications attached.

UA Manual - h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e - 1 / d o w n l o a d

UA Specs - h t t p : / / w w w . d j i . c o m / p r o d u c t / i n s p i r e - 1 / s p e c

This is the same system which is the subject system in Exemption No. 11693 granted to 

Replicopy Inc., dba RDM Productions May 26, 2015. Regulatory Docket No. FAA2014-1030.

THE DJI S1000 UAS

The DJI model S1000 (the “System”) is comprised of a small octo-rotor design unmanned

aircraft (UA) and a transportable ground control station. The UA system gross weight 

configuration with full payload is 11.0 Kg (24.25 pounds). The UA is capable of

carrying digital photography and research equipment during flight, the electrically

powered S1000 has an approximate maximum speed of 39 knots and may be operated

using the transportable ground station, by a minimum required flight crew of one, the

Operator (PIC). Capable of sustained flight in the event of single motor failure. The 

system will be operated in a manner that will not pose a threat to persons or property in 

the event of motor/rotor failure. Manufacturer specifications attached.

UA Manual - h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g - w i n g s-s 1 0 0 0 / d o w n l o a d

UA Specs - h t t p : / / w w w . d j i . c o m / p r o d u c t / s p r e a d i n g - w i n g s-s 1 0 0 0 / s p e c

This is the same system which is the subject system in Exemption No. 11554 granted to 

Midstream Integrity Services, LLC May 12, 2015. Regulatory Docket No. FAA-2015-

0377.

THE OPERATOR

The proposed Operator, (PIC) defined as the person who manipulates the controls of the

System, must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid 

U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory or 

the Federal Government. The PIC must also meet the flight review requirements specified 

in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

The Petitioner proposes that the Operator (PIC) would be augmented with a crew of a 

visual observer (VO) to assist with scanning for collision hazards and maintaining

awareness of the UAS’s precise location, as noted in proposed Part 107, the Visual 

Observer would be a required crewmember.

In addition to the Observer, the Petitioner further proposes that Operator may (as an 

operation dictates) augment the crew with an Equipment Operator (EO), who would be

responsible for operation of photographic equipment carried on board the UAS. The EO

would not be permitted to manipulate the flight or navigation controls of the UAS.
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OPERATINGPARAMETERS

Raven Executive & Security Services, Inc. is committed to the safe and compliant

operation of this System at all times. Because the UAS does not carry crew or passengers

on-board, and is so much smaller, lighter, and slower than manned aircraft, Petitioner

seeks relief from several aspects of 14 C.F.R. Part 91.

Raven Executive & Security Service’s exemption will not adversely affect safety, in the 

alternative reducing the risk to personal safety in the air and on the ground inherent with 

conventional manned aviation operations to accomplish the missions. Additionally, Raven 

proposes to operate with the following safety procedures and restrictions if granted an 

exemption: 

Proposed specific operating limitations

1. Operations authorized by this grant of exemption are limited to the above aircraft

described in the operating documents which is a quad-rotor or octo-rotor aircraft

weighing less than 55pounds. Proposed operations of any other aircraft will

require a new petition or a petition to amend this grant.

2. The UA may not be flown at an indicated airspeed exceeding 87 knots.

3. The UA must be operated at an altitude of less than 200 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.

4. The UA must be operated within visual line of sight (VLOS) of the Pilot In 

Command (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.

5. All operations must utilize a visual observer (VO). The UA must be operated 

within the visual line of sight (VLOS) of the VO at all times. The VO may be

used to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times

during flight operations. Such communications may be augmented through the

use of radios or other technology so long as not to interfere with the operation of

the UAS. 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.

6. The operating documents and this 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 in this exemption and 

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

herein take precedence and must be followed. Otherwise, the operator must follow

the procedures as outlined in its operating documents. The operator may update or

revise its operating documents. It is the operator’s responsibility to track such
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revisions and present updated and revised documents to the Administrator upon

request. The operator must also present updated and revised documents if he

petitions for extension or amendment to this grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the FAA 

granted this exemption, then the operator must petition for amendment to its grant

of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

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

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

the UAS, the UAS 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.

8. Any UAS 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.

9. The pre-flight inspection section in the operating documents must account for all

discrepancies, i.e. inoperable components, items, or equipment, not already 

covered in the relevant sections of the operating documents.

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

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, and alterations must be noted in the aircraft records, including total

flight hours, description of work accomplished, and the signature of the

authorized person returning the UAS to service.

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

14. UAS operations must be conducted by a PIC possessing at least a private,

recreational, sport pilot certificate and at least a current third-class medical

certificate. The PIC must also meet the flight review requirements specified in 14

CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

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

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

16. 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.
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17. 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.

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

in accordance with the operating documents.

19. 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.

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

Waiver or Authorization (COA) prior to conducting any operations in Class E

airspace. 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 

that operation.

21. All aircraft operated in accordance with this exemption must be identified by 

serial number, registered in accordance with 14 CFR part 47, and have

identification (N- Number) markings in accordance with 14 CFR part 45, Subpart

C. Markings must be as large as practicable.

22. 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.

23. The documents required under 14 CFR 91.9 and 91.203 must be available to the

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

These documents must be made available to the Administrator or any law 

enforcement official upon request.

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

operations and activities at all times.

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the 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 
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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).

27. 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.

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

boundaries of the operational area as defined by an 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.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the

UAS operations must comply with all applicable parts of 14 CFR including, but not

limited to, parts 45, 47, 61, and 91.
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REGULATORY STATEMENT

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

entitled Special Rules for Certain Unmanned Aircraft Systems, and 14 C.F.R. §§ 11.61(b)

and 11.81, the Petitioner, through Counsel, submits the following:

PETITIONER’S CONTACT INFORMATION (14 C.F.R. § 11.81(a))

The name and address of the Petitioner is:

Raven Executive & Security Services, Inc.

7111 Dixie Highway # 149

Clarkston, MI. 48346

The point of contact for purposes of this Petition is:

Rollie W. Gackstetter VP/CFO

Raven Executive & Security Services, Inc.

7111 Dixie Highway # 149

Clarkston, MI. 48346

Tel.248.978.3367

Fax.248.922.9218

rgackstetter@sbcglobal.net

Raven Executive & Security Services, Inc. is a Michigan based corporation since 2006 

Michigan ID Number 37015A , DUNS 078522636 conducting safety and security 

operations in Michigan, Indiana and Illinois. 
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SECTIONS OF TITLE 14 CODE OF FEDERAL REGULATIONS FOR

WHICH RELIEF IS SOUGHT (14 C.F.R. § 11.81(b))

Relief is sought from the following provisions of Title 14 of the Code Of Federal

Regulations:

Part 61

§ 61.113 (a) and (b), which state:

Private pilot privileges and limitations: Pilot in command.

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

who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire;

nor may that person, for compensation or hire, act as pilot in command of 

an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of 

an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or 

hire.

Part 91

§ 91.7(a), which states:

Civil aircraft airworthiness.

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

condition.

§ 91.119, which states:

Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft

below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, 

or over any open air assembly of persons, an altitude of 1,000 feet above the

highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the

operation is conducted without hazard to persons or property on the surface—
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(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated 

at less than the minimums prescribed in paragraph (c) of this section.

§ 91.121(a), which states:

Altimeter settings.

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; or

(2) At or above 18,000 feet MSL, to 29.92′′Hg.

§ 91.151, which states:

Fuel requirements for flight in VFR conditions.

(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.

(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.

§ 91.405(a), which states:

Maintenance required.

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;
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§ 91.407(a)(1), which states:

Operation after maintenance, preventative maintenance, rebuilding, or alteration.

(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; and...

§ 91.409(a)(1) and (2) which state:

Inspections

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

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

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

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

this chapter; or

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

accordance with part 21 of this chapter.

§ 91.417(a) and (b) which state:

Maintenance records.

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

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

specified in paragraph (b) of this section:

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

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

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

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

The records must include—

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

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving 

the aircraft for return to service.

(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) 
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and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date.

If the AD or safety directive involves recurring action, the time and 

date when the next action is required.

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

for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

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

periods prescribed:

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

retained until the work is repeated or superseded by other work or for

1 year after the work is performed.

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

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

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

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

the aircraft is approved for return to service.

EXTENT OF RELEIF SOUGHT (14 C.F.R. § 11.81(c))

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a

private pilot certificate, with at least a current third-class medical certificate holder to 

conduct the proposed flight operations for compensation or hire.

91.7(a). Raven Executive & Security Services, Inc. seeks relief from 91.7(a) to the extent

that the UAS systems delineated above are not eligible for an airworthiness certificate

under 14 C.F.R. 21 and therefore can not be airworthy in the context of the regulation.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations 

and the limited capabilities of the System. Raven Executive & Security Services, Inc.

can ensure that each operation is conducted within the requirements of 91.119(a) and is

therefore not seeking exemption from that section of the regulation. With respect to

91.119 (b) and (c) Raven Executive & Security Services, Inc. seeks relief for two

reasons. First, the diminutive size and flight envelope of the UA, and the limited range

of the System necessarily restrict operations to that of low level, low speed, line of sight

(with the Operator) operations. Combined with the intent of the operations primarily

being the survey and photography of property; commercial operation simply could not be

done without exemption. Second, while not a manned helicopter, the UAS systems are

more analogous to a helicopter than other aircraft, which a private pilot is permitted to

operate at less than the minimums prescribed in paragraph (b) or (c) of section 91.119 so

long as the operation is conducted without hazard to persons or property on the surface.

14. C.F.R. § 91.119(d).

91.121. Relief is sought from 91.121 due to the design of the system. While not

possessing an altimeter that can be set in compliance with the regulation, however the

System contains barometric altimeter and GPS derived altitude capabilities. That being 
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said, Raven Executive & Security Services, Inc. is not proposing relief to the extent that

the Operator is not expected to check the System settings prior to each flight.

91.151. Raven Executive & Security Services, Inc. requests relief from 91.151 due to the

limited design range and associated battery storage capacity.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that

the UAS aircraft and the larger System are not certificated pursuant to Part 21, nor issued

airworthiness certificates, and due to the fact that the technology of the System is so

different from traditional manned aircraft, the System does not fit well into the regulatory

scheme of Part 91 Subpart E. As such Raven seeks relief from the above noted 

regulations. However, Raven will maintain all maintenance records related to the system. 

Raven does not intend to document each battery replacement or charge, however, because

the battery is analogous to fuel in manned aircraft, and documenting each charge would 

be as laborious as documenting each fueling of a certificated aircraft in that aircraft’s 

maintenance records.

STATEMENT OF PUBLIC INTEREST (14 C.F.R. § 11.81(d))

The public benefits commensurate with the commercial operation of the UAS systems 

described above by Raven Executive & Security Services, Inc. are numerous. By

implementing this technology into the National Airspace System in a deliberate and

limited way, the public’s interest will be served in that environmental impacts will be

lessened, economies will be more efficient and relative public safety will increase.

This technology will serve to reduce present environmental impacts, and prevent future

negative impacts. Being an incredibly small, electrically powered System environmental

impacts are mitigated when this system is used in place of present approved manned 

aircraft operations. Because neither leaded avgas nor jet fuel is burned, the System itself 

has low impact. The low weight and tiny motors not only reduce fuel consumption, but

reduce noise in the environment and reduce the likely hood of other negative

environmental impacts such as bird strikes and fuel spills.

Because the System is so small, cheap and quick to deploy, yet retains the ability to 

return incredibly detailed information, crops can be monitored more closely for less cost, 

and as such the need to dispense agricultural chemicals can be further minimized.

Infrastructure such as roads, bridges, pipelines, can be quickly assessed without the need 

for heavy equipment such as trucks, cranes, hoists and aircraft that run on fossil fuels.

Additionally, with this technology deployed, studies regarding all aspects of land use, 

soil, topography, become possible where they previously were not due to economic 

reasons. The information collected by Raven for their consumers will have a broader 

environmental impact that will benefit everyone, not just the customer.

When this System is used in support of commercial operations, the public at large will

benefit from the efficiencies that this system brings into the aerial survey market. UAS

services in agriculture will allow farmers to have access to aerial based crop studies 
15 | P a g e

performed on a more timely basis which will allow them to reduce input costs (fuel, 

fertilizer, chemicals, etc.) allowing for more efficient crop production. In support of 

agricultural operations, UAS operation will provide the American consumer with lower 

food prices and better gains from the export of those agricultural products.

In support of the insurance and financial industries, pools of the insured will see lower 

premiums as a result of lower costs of claims administration and better future risk 

analysis derived from the collected information.

For both individual and wide-scaled disasters, the use of UAS’s will allow the insurance

companies a more efficient way of assessing the assets necessary to service their 

policyholder needs. They will be able to align their teams closely to the disaster paths at

their disaster sites and allow them to visually inspect more frequently where their teams 

have been as well as where they need to go. The use of UAS’s in disaster scenarios will

not only allow the insurance companies to better service their policyholders, but will

ensure that life safety measures are even more enhanced during widespread disaster 

scenarios. Through the use of thermal based imaging, not only will photosynthesis 

studies be possible, but it will also be possible to be used for disaster\recovery services 

during regional disasters.

REASONS WHY A GRANT OF THIS EXEMPTION WILL NOT AFFECT

PUBLIC SAFETY (14 C.F.R. § 11.81(e))

Raven Executive & Security Services, Inc. is firmly convinced that this product will not

affect public safety in any adverse way, but will in fact enhance it.

With respect to the safe operation of the aircraft, the Administrator, in exemption No. 

11138 has already evaluated the technical specifications of the aircraft. In noting it’s 

small size, limited speed and numerous safety features (such as low battery autonomous 

landing, lost-link event autonomous procedures, auto-pilot and stability control, to name

a few), Raven believes that the Administrator’s finding that this System can be safely 

operated in the NAS system was correct.

In order to ensure that safety, Raven would utilize a certificated pilot as the Operator,

and abide by common sense operating limitations to ensure that the safety of the public is 

ensured. A list of proposed specific operating limitations is included in the additional

information section, above. The Petitioner is only seeking relief from very specific

regulations that relate to the operation of this System, and is suggesting specific

alternative procedures to ensure safety in lieu of those regulations from which Petitioner 

is seeking relief.

Raven further notes that by replacing certain manned operations with operations 

conducted by this small System, public safety will actually be enhanced. In those

operations where traditional manned aircraft are presently used, the public bears the risk 

of the crash of a much larger, heavier vehicle travelling at a much higher rate of speed. 
16 | P a g e

Furthermore, many of those manned operations contribute to congestion in the NAS, and 

as such an increased risk of collision with other aircraft. Because the UAS systems listed 

above will be operated away from the airport environment, the airport environment being

the location of the highest risk of collision, using this aircraft in place of a manned aircraft

reduces the risk of collision.

With respect to each particular regulation for which relief is sought, Raven believes safety 

is insured:

61.113(a) and (b). Relief is requested to the extent necessary to permit the holder of a

private pilot certificate, with at least a current third-class medical certificate holder to 

conduct the proposed flight operations for compensation or hire.

Raven Executive & Security Services, Inc. notes that private pilots are allowed to operate

aircraft for compensation or hire so long as doing so is incidental to their business and

they do not carry passengers. This is done in much heavier, faster aircraft, which pose a

greater risk to persons or property on the ground. In the case of the UAS systems listed 

above, the aircraft, through it’s limited speed and weight poses much less risk of harm to

those on the surface. The fact that the very small UA will be operated in accordance with

the manufacturer’s instructions and over limited parcels of land, combined with it’s

limited range, negates the long cross-country flying experience required for a commercial

pilot certificate. Therefore Petitioner believes that an equivalent level of safety with

respect to manned aircraft is met with a minimum certification level of Private Pilot

91.7(a). R aven Executive & Security Service, Inc. seeks relief from 91.7(a) to the extent

that the UAS systems listed above are not eligible for an airworthiness certificate under 14

C.F.R. 21 and therefore can not be airworthy in the context of the regulation. The

Operator can, before each flight, determine whether or not the aircraft is capable of safe

flight by visually inspecting the System, accomplishing appropriate pre-flight inspections,

and ensuring compliance with the manufacturers operating manuals and therefore an

equivalent level of safety will be met.

91.119. Relief is sought from 91.119 due to the unique nature of the proposed operations 

and the limited capabilities of the System. Raven can ensure that each operation is 

conducted within the requirements of 91.119(a) and is therefore not seeking exemption 

from that section of the regulation. With respect to 91.119(b) and (c) Raven seeks relief

for two reasons. First, the diminutive size and flight envelope of the UA, and the limited

range of the System necessarily restrict operations to that of low level, low speed, line of

sight (with the Operator) operations. Combined with the intent of the operations 

primarily being the survey and photography of property; commercial operation simply 

could not be done without exemption. Second, while not a manned helicopter, the UAS 

systems listed above are more analogous to a helicopter than other aircraft, which a

private pilot is permitted to operate at less than the minimums prescribed in paragraph (b)

or (c) of section 91.119 so long as the operation is conducted without hazard to persons or 

property on the surface. 14. C.F.R. § 91.119(c).

With respect to operating the UAS systems listed above over or near a structure, Raven

would like point out that it is often more dangerous for those involved if a person were
17 | P a g e

to, for example, fall off of a roof or a ladder, or drop a heavy tool such as a hammer, than

it would be for the listed UAS systems to fall, so long as the Operator ensures that he has 

permission from the owner and requires that any structure the UAS is operated over or

near is not occupied, nor are people in the immediate vicinity, a high level of safety can

be achieved.

Due to the Systems limitations with respect speed and altitude, it’s light weight, and 

ability to maneuver like a helicopter (with an equally trained Private Pilot Operator), and 

a restriction than any structure flown over with permission and only when unoccupied, 

Raven respectfully submits that an equivalent level of safety is assured if relief is granted 

from 91.119 (b) and (c).

91.121. Relief is sought from 91.121 due to the design of the system. While not

possessing an altimeter that can be set in compliance with the regulation, an equivalent

level of safety can be met due to the fact that the System contains barometric altimeter 

and GPS derived altitude capabilities, thus ensuring an equivalent level of safety. That

being said, Raven is not proposing relief to the extent that the Operator is not expected

to check the System settings prior to each flight.

91.152. Raven requests relief from 91.151 due to the limited battery storage capacity. 

Petitioner feels that a good balance of safety and utility can be met if the Operator is 

permitted to plan and initiate a daytime VFR flight to the first intended point of landing, 

at normal cruising speed which would require no more than 70% battery power. This

System possesses several safety features with respect to power, including a low battery 

warning that first alerts at 30% remaining and an automated landing function when a

low battery is detected by the System. Should conditions change during the flight, this

will leave 30% battery capacity to fly to a safe alternative landing zone.

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Due to the fact that

the UAS systems listed above are not certificated pursuant to Part 21, nor issued

airworthiness certificates, and due to the fact that the technology of the System is so

different from traditional manned aircraft, the System does not fit well into the regulatory

scheme of Part 91 Subpart E. As such Raven seeks relief from the above noted 

regulations. In order to ensure an equivalent level of safety, Raven will use trained 

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

using the methods, techniques, and practices prescribed in the manufacturer’s manuals.

Raven will maintain all maintenance records related to the system. Raven does not

intend to document each battery replacement or charge, however, because the battery

operated systems are analogous to fuel in manned aircraft, and documenting each charge

would be as laborious as documenting each fueling of a certificated aircraft in that

aircraft’s maintenance records.
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FEDERAL REGISTRY SUMMARY (14 C.F.R. § 11.81(f))

Raven Executive & Security Services, 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).

This exemption will permit Raven Executive & Security Services, Inc. to

commercially operate an Unmanned Aircraft System (UAS) for the purpose of

conducting aerial survey and photography within the United States.

ADDITIONAL INFORMATION IN SUPPORT (14 C.F.R. § 11.81(g))

Documents and Manuals

The documents and manuals for the UAS systems delineated above in the petition can

be found at:

DJI Phantom II Vision +:

http://www.dji.com/product/phantom-2-vision-plus/download

h t t p : // w w w . d j i . c o m/ p r o d u c t / p h a n t o m -2 - v i s i o n - p l u s/ s p e c

D J I In s p i r e I:

h t t p : / / w w w . d j i . c o m/ p r o d u c t / i n s p i r e -1 / d o w n l o a d

h t t p : / / w w w . d j i . c o m/ p r o d u c t / i n s p i r e -1 / s p e c

D J I S 1 0 0 0 :

h t t p : // w w w . d j i . c o m/ p r o d u c t / s p r e a d i n g -w i n gs-s 1 0 0 0 / d o w n l o a d

h t t p : // w w w . d j i . c o m/ p r o d u c t / s p r e a d i n g -w i n gs-s 1 0 0 0 / s p e c

These documents are incorporated into this petition by reference. However, due to

file size limitations they are not being attached.
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CONCLUSION

As set forth above, Raven Executive & Security Services Inc. seeks an exemption from

certain parts of the Federal Aviation Regulations to permit Raven Executive & Security 

Services to operate a UA systems described above, for compensation or hire, commercially

in the United States for the purposes of conducting aerial photography and survey. RES

believes that a grant of exemption is in the public interest and that public safety will not

be negatively affected. By use of an unmanned system in scenarios where manned

aircraft are traditionally operated RES believes that public safety will actually be

enhanced.

PETITIONER, Raven Executive & Security Services Inc., in accordance with the

Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012,

Section 333, respectfully requests that the Administrator grant this Petition for an

exemption from the requirements of 14 C.F.R Sections 61.113(a) and (b), 91.7(a),

91.119(b) and (c), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) and (b), and permit Raven Executive & Security Services to operate

the UA systems described above commercially for the purpose of conducting aerial

survey and photography over certain areas of the United States.

Respectfully Submitted, 

Raven Executive & Security 

Services Inc.

Carmen P. Gackstetter, CEO

Raven Executive & Security Services, 

Inc.

7111 Dixie Highway #149

Clarkston, Michigan 48346

o.248.922.9218

c.248.830.1338

f.248.922.8218

Email: 

cgackstetter@ravenexecutive.com