U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Petition for Exemption under Section 333 of the FAA Modernization and Reform 

Act and Part 11.81 of the Federal Aviation Regulations 

January 11, 2016 

Petitioner: 

Raytheon Company 

Jason Abkowitz

8350 Alban Road 

Springfield, VA 22150 

Tel.: 303.931.4126 

Email: jason.c.abkowitz@raytheon.com

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 

11.81, Raytheon, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow 

commercial operation of its small, unmanned aircraft for photogrammetry, inspection, and analyses. All operations 

shall be conducted within and under the conditions and limitations outlined previously by the FAA as required by 

Section 333 and conducted in compliance with the attached operator’s manuals. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91: 

i. 91.103(b)(2) 

ii. 91.105 

iii. 91.109 

iv. 91.119 

v. 91.121 

vi. 91.151 

vii. 91.405 

viii. 91.407 

ix. 91.409 

x. 91.417 

2. Relief sought: 

a. Raytheon wishes to operate small Unmanned Aircraft Systems (UAS) for commercial purposes to include (but 

not be limited to) photogrammetry, aerial mapping and analyses. 
This relief is sought because commercial use of UAS is currently prohibited by law unless performed under an 

exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including 

payload and energy sources: 

i. DJI Inspire 1 (http://www.dji.com/product/inspire-1)

ii. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of UAS technology to obtain imagery, information and data currently obtained by use of manned flight or 

manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents and due to other dangerous activities that 

can be avoided. 

ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and 

maintenance work will be conducted or approved by qualified personnel such as those authorized and will require 

a test flight after such work. Records of all maintenance and repair work will be kept in a maintenance log for each 

aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal 

communication capability with each other at all times during the flight, and who will remain stationary on the 

ground during the flight operations: 

d. Pre-flight inspections (including ground control station, if any) and safety risk assessments will be conducted 

prior to each flight. 

e. Flight altitudes will remain below 400 feet above ground level. 

f. Flight ground speeds will not exceed 50 knots. 

g. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground without their prior 

permission. 

h. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. 

i. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever occurs first. 

j. Any incidents will be reported within 24 hours of occurrence. 

k. Any applicable local FSDO requirements. 

l. All other applicable regulations concerned with the operation of aircraft. 

m. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined and tested lost 

link procedures. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and 

are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

additional information or clarifications are needed.

Sincerely, 

Jason Abkowitz