November 30, 2015

Aaron Wypyszynski

Wyp Aviation, LLC

138 Lexie Ln

Meridianville, AL 35759

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code of Federal 

Regulations Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112-

95) Regarding Commercial Employment of Unmanned Aircraft Systems (UAS)

Dear Sir/Madam,

Pursuant to Section 333 of Public Law 112-95, commonly known as the “333 Exemption,” Wyp Aviation, 

LLC (“Wyp Aviation”) hereby applies for authorization to conduct commercial unmanned aircraft 

systems (UAS) operations within the United States National Airspace System (NAS) for the purpose of 

aerial data collection.

Federal Register Summary

Pursuant to 14 CFR §11.81, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed:

Wyp Aviation seeks exemption from 14 CFR Part 21, Subpart H; 14 CFR Part 23; 14 CFR Part 27; 

14 CFR 45.23(a)(b); 14 CFR 61.113(a)(b); 14 CFR 61.133(a)(i)(ii); 14 CFR 91.7(a); 14 CFR 

91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 

14 CFR 91.203(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); CFR 91.409(a)(1) and (a)(2); 14 CFR 

91.417(a)(b) to allow commercial employment of Unmanned Aircraft Systems (UAS) in support 

of aerial data collection. This exemption will enhance safety by reducing risk to the general 

public and property owners from the substantial hazards associated with performing equivalent 

work with conventional aircraft and rotorcraft.

The name and address of the applicant is:

Aaron Wypyszynski

Wyp Aviation, LLC

138 Lexie Lane

Meridianville, AL 35759

aaron@WypAviation.com
INTRODUCTION AND INTEREST OF THE PETITIONER

The use of small unmanned aerial systems (sUAS) in commercial and science applications is now 

widespread and transforming aerial data collection. These devices are used regularly to reduce costs 

and increase safety. Wyp Aviation’s operators possess over a decade of experience in operations of 

sUAS platforms both in the hobby and Department of Defense fields, as well as being FAA-certified and 

current pilots with several hundred hours of flight experience. Wyp Aviation wishes to extend this 

knowledge and experience to sUAS commercial operations to provide low-cost aerial data to our 

customers with a low environmental impact. Operations may consist of:

 Aerial imagery acquisition for local businesses, such as developers and realtors

 Search and rescue support for local first responder organizations

 Carrying of third party sensors to provide data collection and sensor evaluation

 Providing airborne platforms for evaluation of ground-based sensor performance

 Providing training to Wyp Aviation employees in support of sUAS operations

UAS are developing as a legitimate and robust means of conducting aerial data collection that 

heretofore have been possible only from manned aircraft. Such traditional techniques are expensive, 

incur substantial risk to personnel, and produce lower quality data. Our work addresses these issues 

through UAS applications to the benefit of society at large.

OVERVIEW CHARACTERISTICS OF PROPOSED UAS

Platform 3DR IRIS+ DJI Phantom 3 DJI Spreading 

Wings S1000 3DR Aero

Aircraft Type Quadcopter Quadcopter Octocopter Fixed-wing

Aircraft Weight (lbs) 2.8 2.7 9 6

Max Takeoff Weight 

(lbs) 4 3 22 8

Dimensions (in) 22x22x8 15x15x10 41x41x18 51x74x12

Max Flight Time 

approx. (min) 25 25 40 45

Max Airspeed (kts) 35 35 25 50

Autopilot Pixhawk DJI WooKong-M / 

Pixhawk Pixhawk

Propulsion Brushless Motor Brushless Motor Brushless Motor Brushless Motor

Power 11.1V lithium 

polymer battery

14.8V lithium 

polymer battery

22.2V lithium 

polymer battery

14.8V lithium 

polymer battery

Payload Camera / Sensor 

up to 1 lbs Included Camera Camera / Sensor up to 12 lbs

Camera / Sensor 

up to 2 lbs
QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 

of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive UAS under controlled 

conditions in airspace that is: (1) limited; (2) predetermined; (3) would provide an increased level of 

safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. 

The UASs planned to be operated are both rotorcraft and fixed wing, each weighing typically less than 

15 pounds, and always less than 55 pounds, including payload. They would operate, under normal 

conditions, at a speed of no more than 50 knots. The principal construction material of the UAS aircraft 

would primarily be foam, carbon fiber, aluminum, and/or plastic. Operations will be performed by a 

qualified UAS Pilot in Command (PIC), as outlined below, to ensure that the UAS will “not create a 

hazard to users of the national airspace system or the public.” Given the small size of the UAS aircraft

involved and the pre-planned environment within which they will operate, the applicant believes that 

these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence 

immediately. Also, due to the size of the UAS and the pre-defined, restricted area in which the UAS will 

operate, approval of the application presents no national security issue. The operation of UAS by 

knowledgeable professionals will serve to enhance safety, add to the public benefit, and reduce 

environmental impacts related to current methods of manned aircraft flight operations. The limitations 

and conditions to which the operator, or its employees acting as UAS PICs, agrees to be bound when 

conducting commercial operations under an FAA-issued exemption include: 

1. Operations authorized by this grant of exemption are limited to the following aircraft: 3DR 

IRIS+, DJI Phantom, DJI Spreading Wings S1000, 3DR AERO

2. UAS (aircraft and payload) will weigh less than 55 lbs. 

3. UAS will be operated at altitudes not greater than 400 feet above ground level (AGL). Altitudes 

reported to Air Traffic Control (ATC) will be in feet AGL. 

4. UAS will be flown at ground speeds not greater than 50 knots. 

5. The UAS PIC will 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, a possession, or the 

Federal government. The PIC must also meet the recent flight experience requirement stated in 

14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56. 

6. In addition to holding an FAA-issued airman certificate, UAS PIC must complete a Wyp Aviation 

UAS Training Program. This training will include detailed review of manufacturer operating 

manuals and practical demonstration of ability to safely operate UAS in a manner consistent 

with how the UAS will be operated under this exemption (to include evasive and emergency 

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

structures). PIC qualification will have a currency requirement of at least three takeoffs and 

landings within the preceding 90 days. PIC qualification flight hours will be logged in a manner 

consistent with 14 CFR § 61.51. 

7. UAS will not be operated within 5 nautical miles (NM) of an airport having an operational 

control tower, or within 3 NM of an airport with a published instrument flight procedure but not 
an operational control tower, or within 2 NM of an airport without a published instrument flight 

procedure or operational control tower, or within 2 NM of a heliport with a published 

instrument flight procedure. Flights will be operated in Class G airspace whenever possible. If 

operation in other airspace is required, the relevant controlling agency will be notified at least 

24 hours prior to the operation and, if required, any necessary permission obtained.

8. UAS flights will operate within visibility and cloud clearance requirements equivalent to Visual 

Flight Rules (VFR). 

9. UAS operations will not be conducted during night, as defined within 14 CFR § 1.1. 

10. UAS flights over land will not be operated by the PIC from any moving vehicle or device. UAS

flights conducted entirely over water may be operated from a suitable vessel. 

11. UAS will not be operated from a raised platform. 

12. The UAS will remain clear of and yield right of way to manned aviation operations. 

13. UAS will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use 

human vision unaided by device other than corrective lenses as specified on PIC’s FAA medical 

certificate or driver’s license. 

14. UAS operations will employ a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC maintains VLOS capability. The VO and PIC must be able to 

communicate verbally for the duration of the flight. Electronic messaging or texting is not 

allowed during flight operations. 

15. The VO will perform no duties other than assisting the PIC see and avoid other aircraft, 

obstacles, persons, or property. 

16. UAS will be equipped with an autopilot system. The UAS will utilize GPS navigation, failsafes, 

return-to-home (RTH), and flight abort safety features. 

17. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. 

Checklists developed from manufacturer operating documents will be the basis for this 

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

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

UAS is found to be in a safe condition for flight. The Ground Control Station must be included in 

the preflight inspection. 

18. All UAS operations will be conducted over sole use property. Permission for flight will be 

obtained in advance from property owners or controlling agency. A Ground Station will be 

connected by radio communication to the UAS during the entire flight, which will give the PIC 

flight information such as GPS position, altitude, air speed, battery remaining, and other 

telemetry information. 

19. Flight boundaries will be established for each flight and such boundaries will be designed such 

that the UAS will pass no closer than 500 feet from nonparticipating persons, vehicles, or 

structures. 

20. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined 

location within the established flight boundary and land or be recovered in accordance with 

manufacturer operations documents. 

21. The PIC will abort any flight in the event of unpredicted obstacles, occurrence of adverse 

weather, or loss of UAS flight control capability in accordance with manufacturer operations 

documents. 
22. The PIC is prohibited from beginning a flight unless (considering wind and forecast conditions) 

there is enough power to fly the planned route to the intended landing point and land the UAS 

with 25% of battery capacity remaining. 

23. Documents required by 14 CFR § 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS whenever the aircraft is operating. These documents will be made 

available to the Administrator or any law enforcement official upon request. 

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

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

appropriate government oversight agency requirements. 

25. A Flight Operations and Maintenance Log will be maintained for each UAS. Cumulative flight 

hours, maintenance activities, repairs, alterations and inspections will be noted. 

26. Any UAS maintenance or alterations that affect 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 Flight Operations and Maintenance 

Log. 

SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H – Airworthiness Certificates and 14 CFR § 91.203(a)(1) 

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

11 and Section 333 of the Reform Act that the UAS selected provides an equivalent level of 

safety when compared to civil aircraft normally used for the same application. The petitioner 

submits that given the small size of the UAS, the limited operating areas and procedures defined 

within the training and operations section of the petition, an equivalent level of safety is 

obtained and exemption is not required (see Grant of Exemption to Astraeus Aerial, Docket No. 

FAA-2014-0352). If however, the FAA determines that there are some characteristics of the 

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

14 CFR Part 23 and 27 – Airworthiness Standards: Normal Category Aircraft and Rotorcraft 

14 CFR Parts 23 and 27 sets forth the procedural requirements for airworthiness certification of 

normal category aircraft and rotorcraft. To the extent petitioner’s UAS would otherwise require 

certification under Parts 23 and 27, petitioner seeks exemption for the same reasons identified 

in the request for exemption from 14 CFR Part 21, Subpart H. 

14 CFR § 45.23 (a)(b) and 91.9 (c) – Marking of the Aircraft 

Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks 

consisting of the Roman capital letter “N” (denoting United States registration) followed by the 

registration number of the aircraft. Each suffix letter used in the marks displayed must also be a 

Roman capital letter. (b) When marks include only the Roman capital letter “N” and the 

registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or 

“provisional,” as applicable. 
Regulation 91.9 (c) provides: No person may operate a U.S.-registered civil aircraft unless that 

aircraft is identified in accordance with part 45 of this chapter. 

The UAS has no entrance to the cabin, cockpit or pilot station on which markings can be placed. 

Given the small size of the UAS, two-inch lettering will not be possible. In a previous Grant of 

Exemption, the FAA determined that exemption from these requirements was warranted 

provided that the aircraft “have identification (N-Number) markings in accordance with 14 CFR 

Part 45, Subpart C if the markings are as large as practicable.” The petitioner additionally 

proposes to place all required markings, placards, flight envelope restrictions, cautionary notices 

in an easily visible location at the UAS Ground Control Station. The FAA has issued several 

exemptions to this regulation: see Exemptions Nos. 8738, 10167, 10167A and 10700. 

14 CFR § 91.9(b)(2) – Aircraft Flight Manual in the Aircraft 

Regulation 91.9 stipulates (b) No person may operate a U.S.-registered civil aircraft— (2) For 

which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

Given the size of the UAS, they have no place or ability to carry a flight manual aboard the 

aircraft. An equivalent level of safety will be achieved by keeping the flight manual at the 

Ground Control Station where the pilot operating the UAS will have immediate access to it. The 

FAA has issued several exemptions to this regulation: see Exemptions Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 10167, 10602, 32827 and 10700. 

14 CFR § 61.113 (a)(b) and 61.133(a)(i)(ii) – Private and Commercial Pilot Privilege and 

Limitations 

Regulation 61.113 stipulates (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. 

Regulation 61.133 stipulates (a) Privileges—(1) General. A person who holds a commercial pilot 

certificate may act as pilot in command of an aircraft—

(i) Carrying persons or property for compensation or hire, provided the person is qualified in 

accordance with this part and with the applicable parts of this chapter that apply to the 

operation; and 

(ii) For compensation or hire, provided the person is qualified in accordance with this part and 

with the applicable parts of this chapter that apply to the operation. 

Unlike a conventional aircraft that carry pilot, passengers and cargo, the proposed UAS are 

remotely controlled and carry no persons or cargo. The UAS are capable of a high degree of 

flight automation and employ technical capabilities that limit the potential for operation in an 

unintended manner. It is the petitioner’s belief that given the size, weight, speed, operating 

environment and operating capabilities of the UAS, an equivalent level of safety may be 
obtained by stipulating the UAS PIC 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 Colombia, Puerto Rico, 

a territory, a possession, 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 FAA has issued several exemptions to this regulation: see Exemptions Nos. 

11284, 11281, 11282 and 11296. 

14 CFR § 91.7(a) – Civil Aircraft Airworthiness 

Regulation 91.7 stipulates (a) No person may operate a civil aircraft unless it is in an airworthy 

condition. 

Should this exemption be granted allowing commercial operation of UAS without an 

airworthiness certificate, no FAA regulatory standard will exist for airworthiness of the UAS. An 

equivalent level of safety will be obtained by ensuring compliance with UAS operator and 

maintenance manuals and safety checklists prior to each flight. 

14 CFR § 91.121 – Altimeter Settings 

Regulation 91.121 requires that (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. 

Conventional aircraft are provided altitude data by a barometric altimeter that is most 

commonly set to a local barometric pressure and therefore reports altitude relative to MSL 

(Mean Sea Level). UAS operations are restricted to altitudes no greater than 200 feet AGL 

(Above Ground Level). For those UAS with a barometric sensor, greater utility and an equivalent 

level of safety will be obtained by setting the altimeter to read “zero altitude” when the UAS is 

on the ground prior to takeoff thus providing an AGL altitude readout. If no barometric sensor is 

aboard the UAS, a GPS derived altitude similarly set to zero at the takeoff point will provide an 

equivalent level of safety. The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 11066, 11065, 11062 and 11063. 

14 CFR § 91.151 – Fuel Requirements for Flight in VFR Conditions 

Regulation 91.151 stipulates that (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. 

This regulation is written based on the capabilities of traditional civil aircraft which typically 

have flight times with full fuel of several hours. For the majority of UAS which have flight times 
of an hour, or much less, this regulation would effectively deny an ability for the UAS to operate. 

The petitioner submits that an equivalent level of safety will be obtained by requiring that no 

UAS flight will begin unless (considering wind and forecast conditions) there is enough fuel 

(battery) to fly the planned route to the first point of intended landing and land with 25% of 

battery capacity in reserve. This restriction would be more than adequate to return the sUAS to 

its planned landing zone from anywhere in its limited operating area. 

The FAA has issued several exemptions to this regulation: see Exemptions Nos. 2689F, 5745, 

10673 and 10808. 

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) – Maintenance Inspections 

Regulation 91.405(a) requires that an aircraft operator or owner “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...” Regulation 91.407(a)(1) similarly makes reference to requirements in Part 43. 

Regulation 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness 

certificate. Regulation 91.417(a) and (b) requires the owner or operator to keep records showing 

certain maintenance work that has been accomplished by certificated mechanics, under Part 43, 

or licensed pilots and records of approval of the aircraft for return to service. 

Exemption from these regulations is needed because Part 43 and these sections apply only to 

aircraft with an airworthiness certificate. An equivalent level of safety will be obtained by 

requirement that each UAS will have a flight and maintenance log. Maintenance and inspections 

will be accomplished in accordance with manufacturer recommendations. The FAA has issued 

several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065. 

14 CFR § 91.103 – Preflight Action 

Regulation 91.103 stipulates each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must 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; and (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. 

The petitioner seeks exemption to the extent that an FAA-approved Flight Manual is required. 

An equivalent level of safety will be provided by following the Operations Manual provided by 

the manufacturer. Additionally, the PIC will conduct preflight actions, to include performing all 

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

distance, aircraft performance data, and contingency landing areas, before initiation of flight. 
14 CFR § 91.109 – Flight Instruction 

Regulation 91.109 stipulates, in part, that (a) No person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. 

UAS by their design do not have fully functional dual controls. Flight control is accomplished 

through the use of a control interface that communicates with the aircraft via radio. Given the 

size, speed and limited operational parameters of the UAS, an equivalent level of safe training 

can be performed without dual controls. The FAA has issued several exemptions to this 

regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065. 

14 CFR § 91.119 – Minimum Safe Altitudes 

Regulation 91.119 stipulates, in part, 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. 

An exemption to 91.119(c) is required because UAS operations will be conducted at altitudes no 

greater than 400 feet above the surface. The size, speed, weight and limited operational 

parameters of the UAS allow for an equivalent level of safety.

WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST

As introduced above, the requested exemption would authorize the Applicant to perform commercial 

operations with sUAS that will provide significant benefits to the public interest:

1. The commercial use of sUAS to perform aerial data collection activities will provide a public 

service through use of data collection in support of land surveying as well as the ability to use 

these assets in support of local search and rescue organizations.

2. A significant reduction in costs to conduct data collection and training programs. At present, 

such programs that use aerial platforms can cost thousands of dollars. By incorporating sUAS 

into these programs we can incur significant savings and more efficiently conduct data collection 

with more rapid response than traditional methods.

3. The use of sUAS will decrease congestion in the National Airspace System along with reducing 

the noise and air pollution generated during traditional manned aircraft flight operations.

4. When using UAS to complement field personnel, they reduce safety concerns when gathering 

data from locations difficult to reach by personnel.

5. Operation of sUAS will substantially reduce the risk to life and property in the air and on the 

ground, which is commonly associated with traditional manned aircraft flight operations.

6. Similar to the current manned aircraft flight operations that have been conducted for many 

decades, sUAS used for similar tasks will not generate any new privacy issues.
Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act 

to "establish requirements for the safe operation of such aircraft systems in the national airspace 

system." Approval of this exemption will allow for safer, more efficient, and less costly aerial data 

collection missions, and produce much higher data quality.

SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H14 CFR Part 23 

14 CFR Part 27 

14 CFR 45.23(a)(b) 

14 CFR 61.113(a)(b)

14 CFR 61.133(a)(i)(ii)

14 CFR 91.7(a) 

14 CFR 91.9(b)(2)(c) 

14 CFR 91.103 

14 CFR 91.109(a) 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203(a)

14 CFR 91.405(a) 

14 CFR 91.407(a)(1) 

CFR 91.409(a)(1) and (a)(2) 

14 CFR 91.417(a)(b)