U.S. Department of Transportation October 26, 2015 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Infopipe Information Services, Inc. 

Petition for Exemption under Section 333 of the FAA Reform Act and Part 11 of the FAA 

Regulations and certain parts of the FARs. 

Prepared and Submitted by: 

Darrell Connelly, Operator and President, Infopipe Information Services, Inc. 

10687 W Ottawa Ave 

Littleton, CO 80127 

303-973-7459 

darrell@infopipe.com
Petition Summary: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-95 

(2012), 126 Stat. 11 (“Section 333”) and the Federal Aviation Administration’s (“FAA”) general 

exemption authority under 49 U.S.C. section 44701(f), Griffin Aerial, LLC (“Petitioner”) hereby 

petitions for exemptions from 14 C.F.R Part 21, Subpart H (Airworthiness Certificates), 14 

C.F.R. Part 27 (Airworthiness Standards: Normal Category Rotorcraft), 14 C.F.R sections 

61.113(a)-(b), 91.103(b)(1), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a)(1), 91.409(a)(2), 

and 91.417(a)-(b). 

The proposed exemption, if granted, would allow Petitioner to conduct commercial operations of 

small unmanned aircraft systems (“UAS”) meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333. 

Petitioner is an aerial service and technology company that plans to exploit the capabilities of 

Unmanned Aerial Systems to offer a multitude of services, including: 

Aerial surveying 

Remote sensing 

Telecommunications 

Agriculture 

Aerial filmmaking and photography 

Energy systems inspections and asset management 

Construction site inspections and monitoring 

Wildlife and forestry monitoring 

Educational and research operations 

Pipeline inspection and patrolling 

Statutory Authority 

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA “shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the (comprehensive) plan 

and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 

of this Act.” In Section 332(b)(1), Congress made it clear that Section 333 provides a 

mechanism for “expedited operation authorization” if several factors are met. Petitioner meets 

all requirements to permit FAA approval of commercial UAS operations. 

The Petitioner Requests Relief From the Following: 

Section 61.113(a) and (b) prescribes that— 

(a) no person who holds a private pilot certificate may act as a 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. 
Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning 

a flight, become familiar with all available information concerning that flight, to include— 

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and 

forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, 

and any known traffic delays of which the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein; 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

Section 91.119 prescribes that, 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— 

(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. 

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” 

Section 91.151(a) prescribes that 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. 

[emphasis added] 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies 

repaired as prescribed in part 43 of the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 43.7 of the same chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had an inspection for the issuance of an 
airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that— 

(a) 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 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. 

 
Unmanned Aircraft Systems requested to operate under this request: 

DJI S900 

DJI S1000 

3D Robotics Iris + 

3D Robotics X8-M 

3D Robotics Aero-M 

The petitioner states that the small unmanned aircraft (UA) to be operated under this request 

are less than 55 lbs. fully loaded, fly at a speed of no more than 50 knots, carry neither a pilot 

nor passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively 

within a secured area as set out in the POHs. 

The S900 is a six-rotor manufactured by DJI. The VTOL hexarotor-type design has six motors, 

GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, 

the craft has integrated safety features built into the design of the UAS, as described in the 

POH, to ensure the safety of persons and property within and surrounding the limited operating 

area. The petitioner further describes that, in the event the UAS loses communications or its 

GPS signal, the UA will have the capability to return to a pre-determined location within the 

Security Perimeter and land. It will also have the capability to abort a flight in the event of 

unpredicted obstacles or emergencies. 

The S1000 is an eight-rotor manufactured by DJI. The VTOL octarotor-type design has eight 

motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In 

addition, the craft has integrated safety features built into the design of the UAS, as described in 

the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses 

communications or its GPS signal, the UA will have the capability to return to a pre-determined 

location within the Security Perimeter and land. It will also have the capability to abort a flight in 

the event of unpredicted obstacles or emergencies. 

The Iris + is a four-rotor manufactured by 3D Robotics. The VTOL quadrotor-type design has 

four motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. 

In addition, the craft has integrated safety features built into the design of the UAS, as described 

in the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses 

communications or its GPS signal, the UA will have the capability to return to a pre-determined 

location within the Security Perimeter and land. It will also have the capability to abort a flight in 

the event of unpredicted obstacles or emergencies. 

The X8-M is a four-rotor manufactured by 3D Robotics. The VTOL quadrotor-type design has 

eight motors, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. 

In addition, the craft has integrated safety features built into the design of the UAS, as described 

in the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses 

communications or its GPS signal, the UA will have the capability to return to a pre-determined 

location within the Security Perimeter and land. It will also have the capability to abort a flight in 

the event of unpredicted obstacles or emergencies. 

The Aero-M is a single motor fixed wing manufactured by 3D Robotics. The fixed wing has one 

motor, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In 
addition, the craft has integrated safety features built into the design of the UAS, as described in 

the POH, to ensure the safety of persons and property within and surrounding the limited 

operating area. The petitioner further describes that, in the event the UAS loses 

communications or its GPS signal, the UA will have the capability to return to a pre-determined 

location within the Security Perimeter and land. It will also have the capability to abort a flight in 

the event of unpredicted obstacles or emergencies. 

Petitioner’s UAS will be identified by serial number, registered in accordance with 14 C.F.R. Part 

47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart 

C. Markings will be as large as practicable. 

Pre-flight Inspection, Maintenance 

Before each flight the PIC will perform a series of pre-flight and takeoff checks as defined by the 

POH supplied. After each 60 minutes of airtime, the craft will undergo a thorough inspection of 

all aircraft components, including, but not limited to: 

a. Actuators / Servos 

b. Motors, wiring and connectors 

c. Propellers, smooth, no chips 

d. Electronic speed controller, wiring and connectors 

e. Batteries, wiring and connectors 

f. Remote command and control 

g. Ground control station 

UAS Operating Parameters 

The petitioner states that all flights will be operated within visual line of sight (VLOS) of pilot, in 

daytime VFR flight conditions and all operations will be conducted with the assistance of a 

second spotter/visual observer (VO). The UAS flights will be limited to a maximum altitude of 

400 feet AGL. Altitude is accurately measured by GPS. The petitioner further states that an 

operator will ensure that only consenting production personnel will be allowed within 100 feet of 

the UA operation, and UAS will be kept at least 100’ from any inhabited structure. Generally the 

petitioner’s UAS will be operated in rural or suburban areas that will permit significantly larger 

safety zones. 

Petitioner’s UAS will remain clear and yield the right of way to all manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5 

nautical miles of the geographic center of a non-towered airport unless a letter of agreement 

with that airport’s management is obtained and the operation is conducted in accordance with a 

Notice to Airmen (“NOTAM”). 

 
Pilot in Command (PIC) 

The pilot in command will possess a valid airline transport, commercial, private, recreational, or 

sport pilot certificate and a current FAA airman medical certificate or a valid U.S. driver’s 

license issued by a state. 

Visual Observer (VO) 

A visual observer will be deployed to enhance ability to see other air traffic. 

Compliance with Applicable Procedures and Requirements 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will comply 

with the other applicable procedures and requirements stated in § 91.103(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery requirements, 

aircraft performance data, and landing and takeoff distances before initiation of a flight. The PIC 

will also account for all relevant site-specific conditions in their preflight procedures. Risks 

presented by sun glare will be mitigated by the PIC’s and VO’s ability to see other air traffic and 

initiate a return-to-home sequence if needed. 

Radio Frequencies 

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle 

control in unlicensed frequency bands. All devices used will comply with FCC usage and 

emissions regulations. 

Safety and Benefits of the UAS 

The petitioner will be using the UAS in a variety of applications that generally require expensive 

full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer a myriad of 

benefits over the use of full-sized manned aircraft for electric power line inspection, oil/gas 

pipeline inspection, advanced agriculture, film and still photography, just to name a few. 

Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS 

carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. 

By granting Petitioner’s requested exemptions, the FAA will help drive development of safe and 

successful commercial UAS operations and will advance the public knowledge base for such 

operations. Petitioner is committed to promoting the UAS research efforts of policymakers 

including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS 

operations and serving as a resource for future UAS research operations. Thus, the FAA has 

good cause to grant this Petition. 

Conclusion 

For the foregoing reasons, the exemptions requested herein should be granted and Petitioner 

should be permitted to conduct small UAS operations in accordance with its manuals and all 

other operating parameters deemed necessary and appropriate by the FAA.