prone America, Inc. 

'Federal Aviation Regulations for Exemption 

DRONE AMERICA 

April 8, 2016 

Docket Operations, M-30 

U.S. Department of Transportation (DOT) 

1200 New Jersey Avenue, SE 

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001 

RE: Section 333 Petition for Exemption 

To whom it may concern: 

Drone America, Inc. petitions for relief of specific regulations with regards to airworthiness certification under 

Section 333, 14 CFR 11.81. The proposed request for exemption would allow for the use and operation of 

Unmanned Aircraft Systems (UAS) within the National Airspace System (NAS) for emergency response. The 

proposed applications are assisting emergency personnel, protecting them from hazardous conditions and bodily 

harm, and providing a communications relay. 

In the event of national or local emergencies it may be deemed necessary for unmanned aircraft operations. 

Drone America requests that the FAA approve an exemption based on a specific platform size, weight, speed and 

limited operating range. 

Our request for exemption is based on public safety and integration to support firefighting, disaster relief, search 

and rescue, law enforcement, crew training and to participate in research of various National Aeronautics and 

Space Administration (NASA) and National Oceanic and Atmospheric Administration (NOAA) environmental 

studies. In the interest of public safety and research, the FAA has already authorized emergency service agencies 

limited use of unmanned aircraft for critical operations. 

Operational control would remain within Drone America's Emergency Services Division in which "due regard" for 

rules, regulations and operational procedures will be adhered to. 

The platform in consideration for Section 333 Exemption is Drone America's Savant. This is a multi-use fixedwing aircraft with potential applications in agriculture, search and rescue, mapping, mining, fire monitoring, 

communications, and others still in development. 

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Federal Aviation Regulations for Exemption 

Kyle Pruett - Engineering Manager 

Drone America, Inc. 

3555 Airway Drive Suite 310 

Reno, NV 89511 

775-473-9998 I 775-232-8650 

www .DroneAmerica.com 

Drone America, Inc. 2016 

Section 333 Exemption for UAS Operations 

Savant 

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Federal Aviation Regulations for Exemption 

SECTION 333 PETITION FOR EXEMPTION 

Drone America requests exemption from the following regulations: 

PART 21 THAT DESCRIBES PROCEDURAL REQUIREMENTS FOR THE COMPLIANCE OF: 

• Subpart G; Production Certificates 

• Subpart H; Airworthiness Certificates 

• Subpart I; Provisional Airworthiness Certificates 

• Subpart K; Parts Manufacturer Approval 

• Subpart L; Export Airworthiness Approvals 

• Subpart N; Acceptance of Aircraft Engines, Propellers and articles for Import 

• Subpart O; Technical Standard Order Approvals 

• Subpart P; Lavatory Oxygen Systems 

PART 45 THAT REQUIRES IDENTIFICATION AND REGISTRATION MARKINGS: 

Due to platform size and airframe configuration, 2" regulation markings will not fit in accordance with 

Part 45.11. Request for modification to comply with only Part 45.13 fire proof identification plate 

located on the inside of the platform. 

The Savant is an unmanned aircraft and cannot meet the requirements for display of markings of this 

size, nor does the Savant have a door or cabin to display the word "Experimental". 

PART 61.113 PRIVATE PILOT PRIVILEGES AND LIMITATIONS: 

a) Except as provided in paragraphs (b) through (h), no person who holds a private pilot certificate 

may act as a pilot in command of an aircraft that is carrying passenger or property for 

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

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

Drone America requests exemption from requiring a private pilot license because the aircraft size, 

weight, speed, and limited operational range do not necessarily require a private pilot license to 

operate. The aircraft will be operated within a horizontal visual line of sight (VLOS) from the surface 

not to exceed 400 feet AGL. Operations are conducted from a handheld tablet or laptop computer 

with auto takeoff and landing capabilities. Operators are required to complete a pilot training course 

and hold either a Third Class Medical Certificate or a state-issued driver's license. 

PART 91.7 CIVIL AIRCRAFT AIRWORTHINESS: 

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

b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in 

condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. 

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Drone America's aircraft vehicle operators (AVO's) are responsible for the inspection and safe 

operation of the aircraft. Aircraft will be inspected prior to each flight and maintenance performed as 

necessary to ensure flight safety. Should the condition of safe flight not be met, resolved or repaired 

the flight will be terminated until discrepancies are corrected. See Section 11 - Savant Preflight and 

Checklist. 

PART 91.9 CIVIL AIRCRAFT FLIGHT MANUAL, MARKING AND PLACARD REQUIREMENTS: 

a) No person may operate a civil aircraft without complying with the operating limitations specified in 

the approved Airplane or Rotorcraft Flight Manual, markings and placards, or as otherwise 

prescribed by the certificating authority of the: county of registry. 

A flight manual with operating limitations and placards will be immediately accessible to the AVO 

during flight as prescribed. · 

PART 91.107 USE OF SAFETY BELTS, SHOULDER HARNESSES AND CHILD RESTRAINTS: 

Part 91.107 Subpart Bis not applicable to Unmanned Aircraft. 

PART 91.119 MINIMUM SAFE ALTITUDES: 

Drone America requests exemption from minimum safe altitude regulations. Operations will be 

performed between O and 400 feet AGL. 

PART 91.203 CIVIL AIRCRAFT: CERTIFICATIONS REQUIRED: 

Drone America requests exemption from Part 91.203 because the Savant is Experimental and does 

not require airworthiness certification based on size, weight, speed, and limited operating range. The 

Savant does not carry fuel or passengers. 

PART 91.405 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. 

Drone America requests exemption from Part 91.405 (a) on the basis of the size, weight, speed and 

limited range of this unmanned aircraft. 

Drone America's aircraft vehicle operators (AVO's) will be responsible for the inspection and safe 

operation of the aircraft. The aircraft will be inspected prior to each flight and maintenance 

performed as necessary to ensure flight safety. If a condition is identified, and cannot be resolved or 

repaired, the flight will be terminated until discrepancies are corrected. 

PART 91.407 OPERATIONS AFTER MAINTENANCE, PREVENTIVE 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 

Drone America requests exemption from Part 91.407 (1) on the basis that Drone America is the sole 

operator. The Savant is considered Experimental and the AVO is responsible for all maintenance, 

preventive maintenance, rebuilding and/or alterations. 

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PART 91.409 INSPECTIONS: 

a) No person may operate an aircraft unless, within the preceding 12 calendar months -

2) It has had an inspection for the issuance of an airworthiness certificate in accordance 

with Part 21 of this chapter. 

Inspections and preventive maintenance is performed prior to each flight, therefore, Drone America 

requests exemption from Part 91.409 (a) (2). 

PART 91.417 MAINTENANCE RECORDS: 

a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: 

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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. 

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Federal Aviation Regulations for Exemption 

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

1) The records specified in paragraph (a)(l) 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 ar~ repaired and the aircraft is approved for return to 

service. 

Drone America requests exemption from Part 91.4'17. The Savant is considered Experimental and the 

AVO is responsible for all maintenance, preventive maintenance, rebuilding and/or alterations. There 

are no serial numbers for replaceable parts, so there would be no way to track their maintenance. If 

a part is not functioning correctly, it will be replaced. 

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Federal Aviation Regulations for Exemption 

UMANNANED AIRCRAFT SYSTEM OPERATIONS 

1. OPERATIONAL AND DESIGN CHARACTERISTICS: 

The Savant is a fixed-wing aircraft made of light-weight composite materials. It is intended for speeds 

between 30 mph and 85 mph and under normal flight conditions has a flight endurance of up to two 

hours. This small, fixed-wing aircraft is designed for commercial, industrial, and ISR applications. The 

advanced software and GPS guidance system provide the aircraft with self-stabilizing capability and 

multi-waypoint navigation. The Savant is powered by an electric brushless motor that produces highlevel performance and thrust. The aircraft is intended to carry payloads such as atmospheric sensors, 

surveying sensors, mapping equipment, and high d~finition stabilized video and data links. 

Based on other flight experience with similar platforms, flight data has not presented any unsafe 

conditions that would cause concern for safety while conducting flight under normal conditions. 

2. INTENDED PROCEDURE IMPLEMENTATIONS 

Preflight Inspection -Airframe: 

• Assess airframe for any damage during transportation 

• Inspect propeller 

• Verify that motor turns freely and bearings are smooth and quiet 

• Inspect wiring harness for wear, chafing, and all connections are tight 

• Check link antenna and mount for tightness 

• Check flight control servos for smooth operation 

• Check control linkages are secure 

• Check for Foreign Object Debris (FOD) in the payload compartment/battery compartment 

• Check that payload cover plate and any payload installed are secure 

• Install fresh battery and secure with straps 

• Plug battery into battery terminal 

• Install hatches and secure 

• Check wing and stabilizer attachments are secure 

• Check parachute for proper packing, no tangled lines, hatch releases freely 

• Inspect launch lugs for damage 

• Inspect landing skids 

Preflight Inspection - GCS: 

• Check and record initial battery voltage and current 

• Verify maps page as required for the mission 

• Verify and/or load flight plans 

• Verify mission limits including dead man status and lost com waypoint 

• Verify working aircraft GPS, check the number of satellites (7 or more is needed) and Percent 

Deterioration of Position (POOP) is less than 3% 

• Control altitude to GPS 

• Select manual control and verify manual control indicated is autopilot page (If using EP) 

• Verify control surface trims in manual mode, adjust using pilot console (If using EP) 

• Verify manual control (If using EP) 

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• Check the correct operation of the gyros and accelerometers by physically rotating the aircraft 

and verifying the sensor outputs 

• Configure the autopilot loops as needed (typically all auto) with the waypoint set for the 

launch plan 

• Check communications at the far end of the runway strip. RSSI signal should indicate close to 

the minimum reading of -71dBm (average is around -25) 

• Check for aircraft traffic and make any radio calls mandated by air traffic control 

• Final check on the system: Battery voltage, GPS health, RSSI, and sensors 

• Launch! 

Post Flight Inspection: 

• Disconnect battery 

• Unplug ground station radio 

• Shut off transmitter (if applicable) 

• Complete logbook entries and record battery use information 

• Inspect for any loose bolts/connectors/wires and note 

• Inspect airframe and propeller for any damage and note (replace if necessary) 

• Inspect launch lugs 

• Inspect landing skids 

• Plan to discharge all unused batteries to storage level (follow all battery and charger 

instructions) 

Maintenance and Repairs: 

Drone America's aircraft vehicle operators (AVO's) will be responsible for the inspection and safe 

operation of the aircraft. The aircraft will be inspected prior to each flight and maintenance 

performed as necessary to ensure flight safety. If a condition is identified, and cannot be resolved or 

repaired, the flight will be terminated until discrepancies are corrected. 

3. COMMUNICATION AND FREQUENCIES: 

C2 Link 

The Savant uses Microhard Digital Data Link (DDL) radios as a standard, which are directly integrated 

with the Cloudcap Piccolo autopilot system. The 2.4GHz band is used on the Savant, but all options 

listed in the table below are interchangeable with no further modification to the aircraft or any 

onboard systems. 

• FCC ID for the current IPnDDL2450 : NS9NBG30 

Model P/N GHz 

IPnDDL900 MHS116400 900 MHz 

IPnDDL2350 MHS116000 2.304-2.364 

IPnDDL2450 MHS116100 2.405-2.470 

IPnDDL3400 MHS116200 3.300-3.500 

IPnDDL5800 MHS116300 5.000-5.800 

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Cameras and Sensors 

The savant is payload agnostic and will be capable of carrying a variety of standard and customer 

supplied sensors/payloads. Typical sensors will be provided by UTC aerospace (Cloudcap 

Technologies) which include the TASE series of gimbal cameras. Trillium Engineering is another 

supplier of gimbal cameras that may be used. Custom sensors are assembled using high end cameras 

from FLIR, Sony, and other manufacturers. All sensors are separated from the flight control system 

and are housed in a removable cartridge in the bottom of the aircraft. These cartridges may or may 

not have an additional windows or Linux computer which handle all processing for the payload 

completely separate from the autopilot. 

Communications for the payload will be chosen based upon the data rate required for the system and 

will vary with each installation. These will be either on separate frequencies from the C2 link, or will 

have different encoding so that they do not cause interference with the C2 link. 

4. PILOT /CREW QUALIFICATIONS/TRAINING REFERENCE: 

a. Airman Certificate: 

Drone America will require a minimum of a Sport Pilot Certificate for piloting the Savant. 

b. Training: 

A pilot training course has been developed and is taught by a licensed FAA flight instructor employed 

by Drone America. 

c. Flight Hours: 

Drone America will not require a specific number of flight hours for a certified pilot. If the training 

course is completed satisfactorily, that person is qualified to pilot the Savant. 

d. Visual Observers: 

All visual observers must pass training and have an understanding of proper communication and 

phrases, visual scan techniques, and standard flight operations at non-towered airports. Pilots who 

have observer training may act as an observer when they are not acting as a pilot. 

5. MEDICAL STANDARDS FOR PIC: 

Drone America will require either a Third Class Medical Certificate or a State-issued Driver's license to 

pilot the Savant. 

6. OPERATIONS 

• Agriculture - The Savant is capable of carrying both hyperspectral and multispectral cameras which 

can be used to derive valuable information about crops. Plant health, insect infestation, and overspray 

of pesticides can be detected and monitored via the Savant's sensors. Safety considerations in this 

environment include a detailed site recon which will map any obstacles in order to create a safe and 

effective flight plan. 

• Search and Rescue - The Savant can be used to carry both visual and IR cameras simultaneously. 

Onboard processing and live downlink of data from the onboard computer provides faster response 

times and more accurate searches under tight time constraints. The Savant has a high wind tolerance 

and moderate flight speed, which allow it to be deployed in situations that are not ideal for the use of 

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Federal Aviation Regulations for Exemption 

manned aircraft. Crew members deployed with Search and Rescue teams are trained both as pilots and 

first response personnel, allowing them to operate safely and efficiently with the crews on the ground. 

• Mapping - The Savant can be configured with visual and IR cameras and LiDAR for use in mapping of 

hard to reach locations. It is suited to powerline and pipeline surveying due to its long endurance and 

moderate flight speed. These operations can provide data more quickly than sending manned crews on 

foot, and can also increase safety when the infrastructure is damaged by weather or natural disaster 

by preventing personnel from entering an unknown and dangerous situation. 

• Mining - Faster and more detailed mapping can be conducted from lower altitudes with the Savant 

versus a manned aircraft. This increase in both speed and accuracy of the data collected can save cost 

and environmental impact in a mining application. Analyses of data collected from the Savant can help 

to reduce pollutant output and can prevent w~rkers from coming into contact with dangerous 

chemicals in the event of a disaster. 

• Fire Monitoring - The Savant's ability to carry IR cameras and process data on the aircraft gives it 

the ability to collect accurate real-time data which can be directly applied to monitoring a wild fire. This 

is beneficial in areas of steep terrain and heavy forest. The data collected can be shared with fire 

teams immediately, so that they can be more effective and can also help them choose safer exit routes 

as the fire progresses. 

• Communications Relay - There are many situations where first responders of all types are cut off 

from communication with their other teams for long periods of time. Steep terrain can block signal 

from hand-held communications devices and cell service. The Savant can carry IP radios which act as a 

low altitude satellite to relay communications in real-time, restoring the line of contact. 

7. OPERATING SPECIFICATIONS: 

a. Proposed Operating Parameters 

VFR rules will be applied in the operation of the Savant. The Savant has a maximum operating speed 

of 87kts. It has a normal operating speed in the range of 40 to 80kts. Maximum operational altitude is 

estimated at 18,000 feet, pending testing of the airframe. Under normal operations, the Savant will 

not be operated above 400 feet AGL without permission from the FAA and any other governing body 

in the flight operations area. Standard operating altitude will be 400 feet AGL or less. 

b. Minimum Flight Visibility and Distance from Clouds: 

Flight operations will be conducted in compliance with 14 CFR Part 91.155 Basic VFR Weather 

Minimums. Operations are generally 400' AGL and will be performed as stated in the Basic VFR 

Weather Minimum table. 

c. Hazards: 

Operations will be conducted in day-light hours in VFR conditions at 400' AGL, or less and within visual 

line of sight. These flight parameters present minimal meteorological hazards to the operations and 

will not be operated in icing conditions without prior permission from the FAA. 

d. Safety Mitigations: 

Prior to flight, it is the responsibility of the pilot and observers to verify and monitor current and 

forecasted weather conditions. In the event the weather deteriorates, the flight will be terminated 

until adequate VFR conditions can be met per 14 CFR Part 91.155. 

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8. OPERA TIO NS AREA: 

The areas of operations are within Washoe County and the FM approved Reno-Stead Airport UAS 

Test Site. Each of these areas range from rural unpopulated desert to sparsely populated areas to 

demonstrate emergency service proof of concept. The criterion for each area provides specific field 

training relative to local emergencies and disaster relief. 

• Reno/Stead Airport - The Reno-Stead Airport has been designated by the FM as a UAS test site 

range. The test facility area is 812 acres 2.2 miles north of the main active runways 8/26. Runways 

14/32 does have the capability to be closed by the airport authority during flight test operations. The 

airport authority will post an AWOS and a NOTAM broadcasting the date and times of Unmanned 

Aircraft testing and air operations for the Reno/Stead Airport. The Reno/Stead Airport is secured by 

perimeter fencing and therefore, restricts unauthmized activities of public access and/or events. The 

test area is in a remote location 1.8 miles northeast of a housing subdivision. 

• Verdi Mountain Training Center - Is located in the Mount Rose Wilderness Area at an elevation of 

7,500' MSL. This operation area is 5 square miles with no structures or population within 6 miles of a 

population center. The purpose for this location provides UAS search and rescue training and 

implementation. 

• Washoe County Desert Training Center - This location is an isolated part of Northern Nevada in 

Washoe County. The operations area is 10 miles square and 10 miles from the nearest establishment. 

Operations will be conducted from Black Rock Airport (3,904' MSL), which is a private airstrip that has 

no structures in the middle of the Black Rock Playa. The purpose of location is to provide UAS 

emergency service training to law enforcement in the Northern Nevada and medical relief exercises. 

The operations area underlies the Reno Military Operation Area (MOA). The Reno MOA's floor is 

13,000' MSL. Emergency operations training will not exceed 4,500' MSL and will be conducted in day 

light hours under VFR conditions. De-confliction of the airspace does not present a problem since the 

Savant power supply will be depleted prior to UA reaching altitudes of 13,000'; therefore this alleviates 

potential cause of hazardous situations. 

• Reno Radio Control Club (RRCC) - As an AMA sanctioned RC flying field, this site is designated as 

a safe location to fly radio controlled model aircraft and UAVs. The RRCC field is located 11 nautical 

miles from the Mustang (FMG) VOR, on the 317 Radial, and is also 6.4 nautical miles ENE of 

Reno/Stead Airport. Field elevation is 5020 feet MSL. Operations up to 400 feet AGL are permitted in 

accordance with the rules of the Academy of Model Aeronautics (AMA). The purpose of this location is 

to provide a safe area for testing of new configurations including sensor/payload modifications, and 

airframe enhancements. Drone America will file a NOTAM prior to operations at the RRCC club field. 

The RRCC field is secured by perimeter fencing and therefore, restricts unauthorized activities of public 

access and/or events. 

• Hawthorne Airport and Army Depot - Hawthorne is located East and South of Reno, NV along 

Highway 95. It is isolated in a valley between high mountains, with Hawthorne Lake to the North and 

provides a location for harsh weather testing. The facility is operated by the Hawthorne Army Depot, 

and airspace will be coordinated through that government entity and the FM. Drone America will post 

an AWOS and a NOTAM broadcasting the date and times of Unmanned Aircraft testing and air 

operations for the Hawthorne Airport. The Hawthorne Airport is secured by perimeter fencing and 

therefore, restricts unauthorized activities of public access and/or events. 

• Tiger Field Airport - This airport is located on highway 95 in Fernley, NV. It is rarely used, and has 

minimal surrounding population. A large area to the west is wide open desert which is also used as 

army and navy testing and training grounds. This is the alternate location when the RRCC club field is 

not available due to weather or a club event. Drone America will post a NOTAM broadcasting the date 

and times of Unmanned Aircraft testing and air operations for Tiger Field Airport. The Tiger Field 

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Airport is secured by perimeter fencing and therefore, restricts unauthorized activities of public access 

and/or events. 

9. Airport Operations: 

Airport operations have been described in Section 8. The airports selected for operations have been 

either deemed as a UAS test site or are private fields in which authorization has been sought and 

approved for UAS emergency training exercises. All safety mitigations have been taken into 

consideration, including radio communications and lost link procedures. 

10. VISUAL LINE OF SIGHT (VLOS): 

The Savant will remain within visual line of sight (VLOS) of the observers. Through two-way 

communications with the pilot, observers will 'provide critical information about flight safety, 

obstructions and airspace encroachment. Observers will also clear the area of people to keep a safe 

perimeter of operations. 

11. PREFLIGHT SAFETY RISK ASSESMENT: 

• Airframe preflight check completed according to checklist in manual 

• Pilot and all personnel briefed on operation details 

• Pilot and crew safe to fly 

• Maps loaded for flying area within autopilot software 

• All flight plans verified by flight crew for clearance of obstacles and any potential hazards 

• Ground support equipment inspected for safety and in working order 

• Launch and recovery area inspected and cleared of obstacles and personnel 

• Correct sensor package installed and operating correctly 

• Data collection equipment functioning 

12. OPERATIONS WITH EXISTING REQUIREMENTS: 

Whenever existing requirements are in place (i.e. Temporary Flight Restrictions), Drone America will 

coordinate directly with the agencies involved. 

Before every test operation, Drone America files a NOTAM with the FAA. 

13. CERTIFICATE OF WAIVER OR AUTHORIZATION - COA: 

Drone America will submit an application for a Certificate of Waiver or Authorization congruently with 

this 333 Exemption request. 

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