Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 1

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Richard Wygant

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

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

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF  THE FAA MODERNIZATION 

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

Submitted on November 09, 2015 

Richard Wygant

13499 Biscayne Blvd.

Suite 1708

Miami, FL 33181

Tel: 513-593-3441

Fax: 866-725-0974

Email: ricktca@gmail.com
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 2

Table of Contents

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

Introduction and Interests of Richard Wygant..............................................................4

Executive Summary .................................................................................................................4

Expeditious Summary Grant Approval Request......................................................................4

Description of Type, Make and Models of sUAV/UAS Requested:.............................................5

Commercial (Mission, Operation) Purpose:........................................................................................5

Regulations from which the Exemption Relief is requested:.......................................................6

The name and address of the Petitioner: .............................................................................................6

Background...........................................................................................................................................7

Commitment to Safety..................................................................................................................................7

Expertise & Experience................................................................................................................................7

The Exemption Request .........................................................................................................8

Operator Requirements ................................................................................................................ 10

Aircraft and Equivalent Level of Safety.................................................................................... 13

Specific Uses Public Benefits ....................................................................................................... 17

Equivalent Level of Safety............................................................................................................. 18

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command;

.............................................................................................................................................................................18

14 C.F.R. § 91.7(a): Civil aircraft airworthiness..............................................................................19

14 C.F.R. §91.119: Minimum safe altitudes ......................................................................................19

14 C.F.R. §91.121 Altimeter Settings...................................................................................................20

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions ..............................20

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance 

Inspections.....................................................................................................................................................21

Federal Register Publication............................................................................................. 22

Privacy and National Security........................................................................................... 22

Summary................................................................................................................................... 23

APPENDIX A - EXEMPTION REFERENCES ................................................................................ 25

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS........................................... 26

APPENDIX C – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS MANUAL 

VERSION 1.0....................................................................................................................................... 27
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS    Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle 

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Take-Off and Landing
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 4

Introduction and Interests of Richard Wygant

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

“Reform Act”) and 14 C.F.R. Part 11, Richard Wygant (“Petitioner”) Operator of 

Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand 

commercial UAS operations for a host of industries and applications and to perform 

the purposes listed below, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of his sUAV’s/UAS, so 

long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA in an exemption granted under either 

Section 333 or Section 49 U.S.C. §44701(f) 

As described more fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in airspace that is 1) limited; 2) 

predetermined; and 3) would provide safety enhancements in the fields in which it 

will operate, which now depend upon conventional aircraft or humans climbing 

high on dangerous structures, walking in insect laden swamps, and working 

adjacent to treacherous infrastructure. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “... establish requirements for the safe operation 

of such aircraft systems in the national airspace system.” Section 333(c) of the 

Reform Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The petitioner requests the agency issue a summary grant process for this 

application. Petitioner has provided in a confidential document attachment labeled 

as petitioner proprietary information, specific exemption numbers whereby the FAA 

has already granted a previous exemption similar or identical to each and every 

request, herein. 

 

1 Petitioner relies upon the following exemptions where specific reference to an 

exemption is not provided: Exemptions 11062 thru 11067, 11080, 11109 through 

11112, 11114, 11213, and as recent as 11857.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 5

Petitioner has identified a number of previously approved exemptions for each of 

the Petitioners FAA submission requests:

 Commercial (mission/operation) purposes;

 Type of sUAV’s (UAS);

 Title 14 Exemptions2

Description of Type, Make and Models of sUAV/UAS Requested:

The petitioner is seeking an exemption to commercially operate sUAVs makes and 

models as follows: 

DJI - Phantom 2, DJI - Phantom 3, DJI - Inspire 1, DJI – Spreading Wings S800, DJI –

Spreading Wings S900, DJI – Spreading Wings S1000, Cinestar 8 Octo, Blade 350-

QX3, 3DRobotics X8, 3DRobotics Iris, 3DRobotics Solo, Yuneec Q500 Typhon, 

DraganFlyer X4-ES, Microdrones MD4

Each separately weighs 55 lbs. or less, with imaging payload and applicable 

equipment.

Equipment operation manuals for each sUAV are included for your reference and 

are considered confidential information for each respective company’s UAS and are 

affixed separately in these documents labeled Appendix.

Commercial (Mission, Operation) Purpose:

This exemption request, once granted would allow the petitioner to operate a small 

unmanned aerial vehicle (sUAV), unmanned aircraft system (UAS) to conduct bridge 

Inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection, photography and videography of residential and 

commercial real estate, weddings, aerial inspection, photography and videography 

of utility infrastructure including but not limited to electrical power lines, wind 

turbines and cell towers, pipeline inspection and patrolling, filmmaking, 

cinematography, and videography, precision agriculture with on board sensors, 

wildlife and forestry monitoring and mosquito and insect control, aerial surveying, 

construction site inspection and monitoring, public entity support operations, Aerial 

imaging for safety, monitoring and comparing work efforts and completion 

percentages, and security of controlled environment of various sites, aerial video 

and live video feed to assist with search and rescue operations under the authority 

and support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and 

live news gathering, training to persons individually or belonging to both private 

 

2 Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b).
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 6

and public organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS, special events: including high schools. 

colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production3 surface mining, closed set filming4, 

disaster and catastrophe events.

Regulations from which the Exemption Relief is requested:

14 C.F.R. § 61.113 (a) & (b)

14 C.F.R. § 61.133(a)

14 C.F.R. § 91.7(a)

14 C.F. R.§ 91.119

14 C.F.R. § 91.121

14 C.F.R. § 91.151 (a)

14 C.F.R. § 91.405 (a)

14 C.F.R. § 407 (a) (1)

14 C.F.R. § 409 (a) (2)

14 C.F.R. § 417 (a) & (b)

The name and address of the Petitioner:

Richard Wygant

13499 Biscayne Blvd.

Suite 1708

Miami, FL 33181

Tel: 513-593-3441

Fax: 866-725-0974

Email: ricktca@gmail.com

 

3 Motion Picture and Television Flight Operations Manual is herein attached as 

Appendix C.

4 Motion Picture and Television Flight Operations Manual for closed set filming is 

herein attached as Appendix C.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 7

Background

The Petitioner is a highly accomplished, capable, experienced and trusted 

professional.

Petitioner is currently the North American Technical Services Director for Micro 

Focus International, a highly respected company in the Information Technology 

Sector.

Petitioner grew up in Pennsylvania and was a Computer Science major at 

Westminster College in New Wilmington, PA.

Petitioner is an avid aviation enthusiast and a Private Pilot with a Multi-Engine 

rating.

Commitment to Safety

As part of its commitment to safety and innovation, Petitioner is asking for this 

exemption in part, to reduce the risk of injury to its employees and contractors who 

participate in the proposed activities the Petitioner requests, including but not 

limited to damage to agriculture, natural habitat, buildings and other structures 

within the United States. 

Expertise & Experience

Richard Wygant (“Petitioner”), due to his experience, is extremely qualified and is 

considered an up and coming subject matter expert in the Florida area for UAS of all 

types, models and makes.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 8

The Exemption Request

Petitioner proposes the use of the sUAVs will be for capture of high resolution 

imagery and video of residential or commercial applications and purposes to a level 

of quality that allows the Petitioner to use the imagery to identify, record, 

memorialize events and objects according to the purposes noted. 

The imagery and video will be used to identify the condition of landscapes, 

agriculture, events, disasters and infrastructure to conduct bridge inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection, photography and videography of residential and commercial real estate, 

weddings, aerial inspection, photography and videography of utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial imaging for safety, monitoring 

and comparing work efforts and completion percentages, and security of controlled 

environment of various sites, aerial video and live video feed to assist with search 

and rescue operations under the authority and support of local authority officials, 

aerial video and photography for public and private use including television, public 

events, and cinematography live feed and live newsgathering, training to persons 

individually or belonging to both private and public organizations to increase 

awareness and improve safety for current and future UAS operations within the 

NAS, special events: including high schools, colleges, professional sports, open air 

events and fairs research, risk management and assessment, motion picture 

production, surface mining, closed set filming, disaster and catastrophe events.

The UAS will be operated by the Petitioner and/or contracting operators on 

occasion to capture high-resolution imagery/video of large structures (wide and 

tall) such as warehouses, high rise buildings, bridges, and construction sites, as well 

as “bird’s eye” views of fire and explosion sites. Given the small size of the sUAVs 

involved, no more than 55 lbs., majority of the speed of operation be between 5-15 

mph and the restricted environment within which they will operate, the Petitioner 

falls 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 UASs to commence immediately.

This exemption application is submitted to fulfill Congress’ express goal in passing 

Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may 

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

rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 9

create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following:

 The UAS’ size, weight, speed, and operational capability;

 Operation of the UAS in close proximity to airports and populated areas; and

 Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” 

Id. §333(c). (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. This statutory authority, by its terms, includes exempting civil aircraft, 

as the term is defined under §40101 of the Act: The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or 

(b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant 

exemptions reaches such issues as authorization of commercial operation of aircraft 

without an FAA issued pilot’s license.5

Petitioner, in filing this application, is requesting that the FAA combine the grant of 

the Section 333 exemption with a standard Certificate of Operation (COA) that will 

allow commercial operations of Petitioner’s sUAVs without the necessity of filing for 

a COA for each flight, unless such flight is to be conducted in an area not approved in 

the exemption. Compliance with the conditions agreed to herein and that may be 

imposed by the FAA, as set forth in prior Section 333 exemptions, provide the 

separation needed from other aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no 

closer than 5 nautical miles of the geographic center of an airport as denoted on a 

current FAA published aeronautical chart, unless a letter of agreement with that 

airport’s management is obtained, the Petitioner requests that operations over 

congested or densely populated areas be allowed. The new sUAVs do have GPS geofencing, it will operate at a very low altitude, within confined areas, at low speed and 

weighs no more than 55 lbs. Such operations will only be under-taken with the 

approval of the land or home owner, as set forth herein, and will comply with the 

requirements that operations be no closer than 500 feet to the adjacent building 

 

5 Applicant interprets this provision to place a duty on the Administrator to not only 

process applications for exemptions under section 333, but for the Administrator to 

craft conditions for the safe operation of the UAS, if it should be determined that the 

conditions set forth herein do not fulfill the statutory requirements for approval.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 10

unless the land owner has provided permission, and the Operator has made a safety 

assessment of the risk from such operations. 

Operator Requirements

Given the sUAV proposed by Petitioner, Operators should not be required to hold a 

private pilot license. Petitioner believes that 1) the operator, instead of 

understanding how to operate a passenger carrying aircraft, should have knowledge 

and experience that enables the safe operation of a small, remotely piloted sUAV 

should understand airspace restrictions and know how to ensure separation from 

other aircraft as well as non-participants and property; 2) the sUAV has built-in 

technical capabilities that limit the potential for unsafe operation and 3) there are 

other security screening mechanisms already in existence that the Petitioner will 

utilize to ensure the operators are acting consistently with national security 

interests. 

Given the sUAV safety features outlined below, Petitioner proposes that its 

operations under this Exemption request should not be required to hold a 

commercial or private pilot certification. Instead, Operators should be required to: 

have successfully completed, at a minimum, FAA private pilot ground instruction 

and passed the FAA Private Pilot written examination or FAA-recognized 

equivalents; have completed Petitioners’ training program for operation of the UAS.

Petitioner notes that 1) the FAA has found that safety factors permitted operation of 

sUAV’s by Operators with these qualifications in the case of operations pursuant to 

public COAs when the mandatory operating conditions specified above were 

present; and 2) that the Notice of Proposed Rulemaking entitled Operation and 

Certification of Small Unmanned Aircraft Systems, 80 F.R. 9544 (February 23, 2015) 

(“NPRM”), does not require the operator to hold a private pilot license or a third 

class medical.

Advanced sUAVs have a navigation and control system and auto-pilot that allow it to 

execute very accurate pre-programed flights. Flights are pre-programmed with GPS 

waypoint to establish perimeters beyond which the aircraft will not operate. Flights 

under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto-pilot. In the case of 

unplanned events, the Operator inputs preprogrammed evasive maneuvers from the

control unit, and the autopilot executes those maneuvers. Pre-programmed 

Operator interventions include: initiation of holding at present position; suspension 

of mission; fly back to launch point; abort mission and land immediately; and 

emergency power cut off and land (flight termination system). Additional 

automated safety functions and safety enhancing features of the Advanced sUAVs 

may include the following:

1) Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing, 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 11

2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% 

levels. Low power below 10% triggers an immediate landing, 

3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold 

position at its current location for 5 seconds and if the signal is not restored, 

execute a return to home and land, 

4) Redundant “kill switches” that enable completely shutting the aircraft down 

in flight in the event of a loss of control or un-commanded deviation from the 

flight path, 

5) The aircraft, weighs less than 55 lbs., fully loaded, 

6) The motors are driven by pulse width modulated signals, not analog signals, 

7) The aircraft will operate for the Purposes at no more than 30 mph (while 

imaging) nor above 200 feet above the structure (imaging altitude) or a 

maximum of 400 feet AGL.

See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft 

Systems (UAS) Operational Approval, at 20-21 (July 30, 2013); As the FAA has 

determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), 

in comparing the requirements for private pilot knowledge and the knowledge 

required for a commercial pilot, that knowledge associated with a private pilot 

license, and therefore private pilot ground school, was sufficient to allow private 

pilots to operate sUAVs under those exemptions. 

Based upon that analysis, Petitioner believes successful completion of FAA private 

pilot ground school is a suitable predicate to operating the sUAV under this 

exemption. Petitioner proposes that the Operator accumulate required sUAV flight 

training hours through the operation of sUAV’s rather than flight hours in 

conventional aircraft. Those hours are more relevant to the operations proposed 

herein than hours gained in obtaining a private pilot’s certificate in conventional or 

rotor aircraft. Those aircraft are orders of magnitude heavier than the sUAS and 

carry not only the pilot himself, but also passengers and fuel, none of which is 

carried in the sUAS. These conventional aircraft fly over all sorts of airspace without 

the permission or knowledge of the landowner. 

A handheld radio controller controls the sUAV and the vehicle is operated within the 

line of sight. The requirements of Part 61.127 (commercial flight proficiency) and 

§61.107 (private flight proficiency), to the extent they are relevant to UAS 

operations, can be taught in the training proposed herein. As a review of the 

requirements of part 61.127 and 107 demonstrate, the issues presented as they 

relate to a 55 pound aircraft, operating at less than 30 mph during filming 

operations are those taught in ground school and in flight training with the 

particular UAS and not gained from accumulating flight hours in a fixed wing or 

rotorcraft gas or jet A powered aircraft completing cross country flights and take 

offs and landings at controlled and uncontrolled airports.

As to national security review of pilots, each of Petitioner’s pilots/operators will 

obtain internally provided certified training (Ground and Practical) from Petitioner
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 12

to operate the sUAV. This review and certification could reasonably vet the 

Operators against any known terrorist or no fly listings that are relevant and 

publically available.

Petitioner additionally asks that the exemption be issued without the requirement 

for a visual observer. As set forth herein, an equivalent level of safety is provided by 

the size, speed and control capabilities of the aircraft, as well as the operational 

procedures that will be applicable to all flight hereunder. These obviate the need for 

the visual observer. 

The Operator will be operating the aircraft, always within line of sight. He or she will 

walk and follow the aircraft around the inspection area so that while it is flying its 

pre-programed and at times, manual flight path, the UAS will always be directly in 

his or her line of sight. The Operator will not be distracted by viewing the pictures 

taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty 

will be to watch the flight of the UAS over the structure and intervene to address 

flight path deviations or other issues that arise during the flight. The functions that 

an observer performs where the aircraft is flown at long distances from the launch 

area will not be necessary as the Operator will always have the aircraft in his or her 

direct sight. The observer also will not be necessary because the Operator will 

conduct a pre-flight inspection of the area, will and if needed, cordon off the area 

and will perform frequent visual scans of the area while the vehicle is operating.

Petitioner again notes that the NPRM does not require the use of a visual observer. 

Given the clear direction in Section 333 of the Reform Act; the authority contained 

in the Federal Aviation Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing battery powered sUAV’s for these functions instead of 

turbine or gas power aircraft/rotorcraft and operations with pilots having at least a 

private pilot license, the grant of the requested exemptions is in the public interest. 6

 

6 Should the FAA determine that it cannot grant such an exemption for operations 

without a FAA licensed private pilot, despite the showing made herein, under the 

statutory authority the FAA already has, Petitioner will operate its aircraft with 

pilots holding at least a private pilot certificate issued by the FAA. In that event, 

Petitioner requests that the exemption be granted with conditions similar to those 

contained in numbered paragraphs 14-15 in Exemption 11136
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 13

Aircraft and Equivalent Level of Safety

The Petitioner proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety to 

operations under the current regulatory structure because the proposed operations 

represent a safety enhancement to the operations conducted with conventional 

aircraft or with humans climbing up and around structures. These conditions are 

drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 

11112, and 11213 and as recent as 11857.

These limitations and conditions to which the Petitioner (referred to as “Operator”) 

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 aircraft described in the Operator’s manual, which is a multirotor weighing up to 55 pounds: 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 30 

mph (10 mph during inspections). 

3) The UA must be operated at an altitude of no more than 400 feet 

above ground level (AGL), as indicated by the procedures 

specified in the Operator’s manual. All altitudes reported to ATC 

must be in feet AGL. 

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

Aircraft Operator at all times. This requires the Aircraft Operator 

to be able to use human vision unaided by any device other than 

corrective lenses.. 

5) The Exemption Holder’s Manuals must be amended to include all 

conditions and limitations required by the FAA. The Manuals 

must be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and 

limitations in the exemption and the procedures outlined in the 

Exemption Holder’s Operator’s manual, the conditions and 

limitations in the exemption take precedence and must be 

followed. Otherwise, the Aircraft Operator must follow the 

procedures as outlined in its Aircraft’s manual. The Exemption 

Holder may update or revise its Manuals. It is the Exemption 

Holder’s responsibility to track such revisions and present 

updated and revised documents to the Administrator upon 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 14

request. The Exemption Holder must also present updated and 

revised documents if it petitions for an extension or amendment 

of this exemption. If the Exemption Holder determines that any 

update or revision would affect the basis upon which the FAA 

granted this exemption, then the Exemption Holder must 

petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator 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 aircraft 

is prohibited from operating until the necessary maintenance 

has been performed, and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records.

7) Any UAS that has undergone maintenance or alterations that 

affect the UAS operation or flight characteristics, e.g., 

replacement of a flight critical component, must undergo a 

functional test flight in accordance with the Exemption holder’s 

Manuals. The Aircraft Operator who conducts the functional test 

flight must make an entry in the UAS aircraft records of the 

flight. The requirements and procedures for a functional test 

flight and aircraft record entry must be added to the Exemption 

Holder’s Operator’s manual.

8) The Exemption Holder must follow the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements, with particular attention 

to flight critical components that may not be addressed in the 

manufacturer’s manuals.

9) The Exemption Holder must carry out its maintenance, 

inspections, and record keeping requirements in accordance 

with the Operator’s Manuals. Maintenance, inspection, and 

alterations must be noted in the aircraft logbook, including total 

flight hours, description of work accomplished, and the signature 

of the authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training 

referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this exemption must comply with all 

manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a 

record entry in the UAS logbook or equivalent document of the 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 15

corrective action taken against discrepancies discovered 

between inspections.

13) If the UAS loses communications or loses its GPS signal, the UA 

must return to a pre-determined location within the private or 

controlled-access property and land or be recovered in 

accordance with the Exemption Holder’s Manuals.

14) The Aircraft Operator must abort the flight in the event of 

unpredicted obstacles or emergencies, including unauthorized 

people entering the flight area, in accordance with the 

Exemption Holder’s Manuals.

15) The Aircraft Operator is prohibited from beginning a UAS flight 

unless (considering wind and forecast weather conditions) there 

is enough power to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 10 

minutes.

16) All aircraft operated in accordance with the 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.

17) 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.

18) The documents required under 14 CFR 91.9 and 91.203 must be 

available to the Operator at the Ground Control Station of the 

UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement 

official upon request. 

19) The UA must remain clear and yield the right of way to all other 

manned operations and activities at all times (including, but not 

limited to, ultra-light vehicles, parachute activities, parasailing 

activities, hang gliders, etc.).

20) The UA may not be operated by the Aircraft Operator from any 

moving device or vehicle.

21) UAS operations may not be conducted during night, as defined in 

14 CFR 1.1.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 16

22) All operations must be conducted under visual meteorological 

conditions (VMC). 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 Operator.

23) During operations the UA may not operate within 5 nautical 

miles of the geographic center of an airport as denoted on a 

current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the 

operation is conducted in accordance with a NOTAM, if as 

required by the Operator’s COA. The letter of agreement with the 

airport management must be made available to the 

Administrator upon request.

24) The UA may not be operated over congested or densely 

populated areas unless the conditions set for in #26 are satisfied. 

These populated areas include but are not limited to the yellow 

areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). 

However, aeronautical charts may not reflect pertinent local 

information. Ultimately, it is the Operator’s responsibility to 

maintain the minimum safe altitudes required by § 91.119 (d) 

(1). 

25) 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 debris in the event of an 

accident. The Aircraft Operator must ensure that 

nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such 

protection and are within 30 feet of the UA, flight 

operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures 

where the land owner/controller has granted permission 

and/or the Aircraft Operator has made a safety assessment 

of the risk of operating closer to those objects and;

c. Operations near the Aircraft Operator do not present an 

undue hazard to the Operator per § 91.119(a).

26) All operations shall be conducted over private or controlledaccess property with permission from the land owner/controller 

or authorized representative. Permission from land 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 17

owner/controller or authorized representative will be obtained 

for each flight to be conducted.

27) Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined 

by the applicable COA must be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

Specific Uses Public Benefits

The Petitioner proposes use of its sUAV provided equivalent or augmented levels of 

safety for each of the uses proposed herein: 

The present systems of photography and videography and mapping of inspecting 

the roofs, agriculture land, buildings and large structures site surveys, wild life 

monitoring, mosquito and insect control are now conducted by either humans 

wading through swamps, climbing on the roofs and structures that are steep, tall, 

slippery, weakened or otherwise hazardous or by the use of conventional aircraft. 

The current procedures can result in significant injuries to the people who must 

climb on the roofs or require the use of aircraft that are orders of magnitude greater 

in size than the sUAV. Either method, manual inspection or large conventional 

aircraft, results in increased risk of injury due to personnel falling off roofs or 

ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or 

increased risk from low altitude flyovers with helicopters or fixed wing aircraft 

inspecting buildings after damage from storms or other disasters, such as 

earthquakes or fires. Such flights are, of course, significantly more expensive than 

those undertaken with a sUAV. 

The present system exposes those not only in the immediate area of inspection, but 

those who are along the path of flight associated with the arrival and departure of 

the conventional aircraft at the inspection site because the aircraft must be flown to 

and from the site. By contrast, the sUAV is carried to the site and transits no other 

property. Conventional aircraft carry flammable fuels that are not carried by the 

UAS and emit pollutants associated with internal combustion engines. The sUAV’s 

proposed herein are battery powered and have no emissions.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 18

Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in 

Command;

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the Petitioner’s

sUAVs are remotely controlled with no passengers or property of others on board. 

Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot 

in command of an aircraft for compensation or hire. 

Petitioner respectfully proposes that Operator requirements should take into 

account the characteristics of the particular UAS. Petitioner’s sUAVs have a high 

degree of pre-programmed control and various built-in technical capabilities that 

strictly limit the potential for operation outside of the operating conditions set forth 

in the exemption application. Petitioner’s sUAVs have navigation and control system 

comprised of a Ground Control Station (GCS) and auto-pilot system that can be preprogrammed to set operational boundaries. All flights are pre-programmed with 

precision GPS guidance. In the case of unplanned events, the Operator may input 

pre-programmed evasive maneuvers from the control unit, and the onboard 

autopilot executes those maneuvers. Pre-programmed Operator interventions 

include initiation of holding at present position; suspension of mission; fly back to 

launch point; abort mission and land immediately; and emergency power cut off and 

land (Flight Termination System). 

Additional automated safety functions and safety enhancing features of Petitioner’s

sUAVs may include the following:

1.1. Auto-pilot detection of lost GPS or of insufficient satellites initiates an 

immediate landing.

1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 

10% levels. Low power below 10% triggers an immediate landing.

1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will 

hold position at its current location for 5 seconds and if the signal is not 

restored, execute a return to home and land.

1.4. Redundant “kill switches” that enable completely shutting the aircraft 

down in flight in the event of a loss of control or un-commanded 

deviation from the flight path. 

1.5. The aircraft, weighs less than 55 lbs., fully loaded.

1.6. The motors are driven by pulse width modulated signals, not analog 

signals.

1.7. The aircraft will operate for the Purposes at no more than 30 mph 

(while imaging) nor above 200 feet above the structure (imaging 

altitude) or a maximum of 400 AGL. 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 19

Given these safety features, Petitioner proposes that Operators of the Petitioner’s

sUAVs should not be required to hold a commercial or private pilot certification. 

Instead, Operators should be required to: have successfully completed, at a 

minimum, FAA private pilot ground instruction and passed the FAA Private Pilot 

written examination or FAA-recognized equivalents; have completed the 

manufacturer’s or Petitioner’s training program for operation of the UAS.

Petitioner notes that the FAA has found that safety factors permitted operation of 

UASs by Operators with these qualifications in the case of operations pursuant to 

public COAs where the mandatory operating conditions specified above were 

present. See, Federal Aviation Administration, Notice N-8900.227, Unmanned 

Aircraft Systems (UAS) Operational Approval, at 20-21 (July 30, 2013). Likewise, 

Petitioner notes that the NPRM does not require that the Operator hold a private 

pilot license issued by the FAA.

Given these conditions and restrictions, an equivalent level of safety will be 

provided by allowing operation of Petitioner’s sUAVs without a private pilot’s 

certificate or a commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the Petitioners’ sUAVs (given its size, 

speed, operational capabilities, and lack of combustible fuel) are so diminished from 

the level of risk associated with private pilot operations or commercial operations 

contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that 

allowing operations of the UAS as set forth above meets or exceeds the present level 

of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of 

requiring a commercial pilot to operate the aircraft under § 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. Should the exemption be granted allowing commercial 

operation of the UAS without an airworthiness certificate, no standard will exist for 

airworthiness of the UA. Given the size of the aircraft and the requirements that the 

Operator has agreed to as it relates to airworthiness, as contained in the manual, an 

equivalent level of safety will be achieved by insuring compliance with the manuals 

prior to each flight. The FAA has granted exemptions to conduct similar operations 

in Exemptions 11062 through 11067, 11080 and 11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for sUASs that are
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 20

helicopters and the exemption requests authority to operate at altitudes up to 400 

AGL, an exemption may be needed to allow such operations. 

The equivalent level of safety will be achieved given the size, weight, and speed of 

the UAS as well as the location where it is operated. No flight will be taken without 

the permission of the property owner, facility owner, and/or local officials. Because 

of the advance notice to the property owner and participants, all affected individuals 

will be aware of the planned flight operations as set forth in the Manuals. Compared 

to flight operations with aircraft or rotorcraft weighing far more than the maximum 

55 lbs. and the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented by conventional aircraft operating at or 

below 500 AGL in the aerial photography industry. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small-UAS operations 

and the operations of conventional aircraft that must comply with Section 91.119. 

The FAA has granted exemptions to conduct similar operations in Exemptions 

11062 through 11067, 11080 and 11110.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires 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.” As the 

Petitioners sUAVs, in manual or emergency mode, will not have a barometric 

altimeter display, but instead a GPS altitude display, an exemption will be needed. 

The Operator, pursuant to the procedures set forth in the Manuals as indicated 

before flight, will achieve an equivalent level of safety. The FAA has granted 

exemptions to conduct similar operations in Exemptions 11062 through 11067, 

11080 and 11110.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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.” 

The battery powering the sUAS provides approximately 40 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights 

would be limited to approximately 10 minutes in length. Given the limitations on the 

UAS’ proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight is reasonable. 

Petitioner believes that an exemption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 21

to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes 

of reserve fuel, does not engender the type of risks that Section 91.151(a) was 

intended to alleviate given the size and speed of the small UAS.

Petitioner believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of remaining battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 

and Exemptions 11062, through11067, 11080 and 11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

These regulations require 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...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the Petitioner. Maintenance will be 

accomplished by the Operator or manufacturer pursuant to the flight manual and 

operating handbook as referenced in the Manuals attached as confidential Exhibits.

An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in defined areas for 

limited periods of time. If mechanical issues arise, the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. As provided in the Aircraft 

Flight Operations Manual the Operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the Operator and manufacturer are most 

familiar with the aircraft and best suited to maintain the aircraft in an airworthy 

condition to provide the equivalent level of safety. The FAA has granted exemptions 

for similar operations in Exemptions 11062 through 11067, 11080 and 11110.

*********
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 22

Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in 

the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a);

91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small 

unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge 

inspections, flare stack inspection, utility-power generation system inspections and 

patrolling, aerial inspection and photography of residential and commercial utility 

infrastructure including but not limited to electrical power lines, wind turbines and 

cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and 

videography, precision agriculture with on board sensors, wildlife and forestry 

monitoring and mosquito and insect control, aerial surveying, construction site 

inspection and monitoring, public entity support operations, aerial video and live 

video feed to assist with search and rescue operations under the authority and 

support of local authority officials, aerial video and photography for public and 

private use including television, public events, and cinematography live feed and 

live newsgathering, training to persons individually or belonging to both private and 

public organizations to increase awareness and improve safety for current and 

future UAS operations within the NAS, special events: including high schools,

colleges, professional sports, open air events and fairs, research, risk management 

and assessment, motion picture production, surface mining, closed set filming, 

disaster and catastrophe events.

Privacy and National Security

All flights will occur over private or controlled access property with the property 

owner’s prior consent and knowledge. Inspection will be of inanimate objects in 

areas where the owners will have consented to the inspections or otherwise have 

agreed to allow the UAS and the Operator to be in the area where operations will 

take place. 

The size of the UAS, its speed and restricted area of operation do not raise national 

security issues.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 23

Summary

Approval of exemptions allowing commercial operations of sUAVs for petitioner to

operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare 

stack inspection, utility-power generation system inspections and patrolling, aerial 

inspection and photography of residential and commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers, 

pipeline inspection and patrolling, filmmaking, cinematography, and videography, 

precision agriculture with on board sensors, wildlife and forestry monitoring and 

mosquito and insect control, aerial surveying, construction site inspection and 

monitoring, public entity support operations, aerial video and live video feed to 

assist with search and rescue operations under the authority and support of local 

authority officials, aerial video and photography for public and private use including 

television, public events, and cinematography live feed and live newsgathering, 

training to persons individually or belonging to both private and public 

organizations to increase awareness and improve safety for current and future UAS 

operations within the NAS, special events: including high schools. colleges, 

professional sports, open air events and fairs, research, risk management and 

assessment, motion picture production, surface mining, closed set filming, disaster 

and catastrophe events, will enhance safety by reducing risk. 

Conventional operations, using jet or piston powered aircraft, ladders or placing 

people in swamps, on roofs or tall, hazardous or weakened structures, exposes them 

to higher risks than those created by use of a sUAVs. Conventional aircraft that 

operate at extremely low altitudes just feet from the subject being inspected and in 

extreme proximity to people and structures present the risks associated with 

vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other 

fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project 

location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries 

eliminates virtually all of that risk given the reduced mass and lack of combustible 

fuel carried on board. The sUAV is carried to the target area and not flown. The 

sUAV will carry no passengers or crew and, therefore, will not expose them to the 

risks associated with manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted under the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant of the exemptions requested herein. These lightweight aircraft operate at slow 

speeds, close to the ground, and in areas that are under the control of the customer 

for the operations and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and 

people or the use of individuals to climb the structures to conduct the operations.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 –size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than 

adequate justification for the grant of the requested exemptions allowing 
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 24

commercial operation of Petitioner’s UAS for the Purposes outlined herein and are 

consistent with exemptions already granted, including Exemptions number 11171 

through 11174, 11176, 11177, 11062, 11109, 11112,11213, 11857 and as recent as 

12402.

Sincerely,

Richard Wygant (Petitioner)

13499 Biscayne Blvd.

Suite 1708

Miami, FL 33181

513-593-3441

ricktca@gmail.com
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 25

APPENDIX A - EXEMPTION REFERENCES

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b). 

Submitted under separate cover.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 26

APPENDIX B - TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain 

proprietary confidential business information that is not released to the public and is 

protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 

333 (b). 

Submitted under separate cover.
Richard Wygant / 513-593-3441 / ricktca@gmail.com

13499 Biscayne Blvd, Suite 1708, Miami FL 33181

Submitted on: 11-09-15

Page 27

APPENDIX C – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS 

MANUAL VERSION 1.0

Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they 

contain proprietary confidential business information that is not released to the 

public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 

Reform Act Section 333 (b). 

Submitted under separate cover.

.