May 5, 2015 

 Exemption No. 11492 

 Regulatory Docket No. FAA–2015–0322 

Mr. Joshua L. Vilches 

C.E.T. Aviation 

20 West Gilbert Road 

Southbury, CT 06488 

Dear Mr. Vilches: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

By letter dated February 6, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of C.E.T. Aviation (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial filming 

and photography that will support the needs of the advertising and marketing in a variety of 

industries. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DJI Flame Wheel F550. 
2 

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, C.E.T. Aviation is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

 

1

 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA. 
3 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, C.E.T. Aviation is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Flame Wheel 

F550 when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
4 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a 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 Columbia, 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. 
5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. 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 PIC. 

18. 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. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 
6 

22. All aircraft operated in accordance with this 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. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC 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. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All 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 the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

28. 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. 
7 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

 
8 

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

Enclosures 

 
Petition for Exemption Under Section 333 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sir or Madam, 

February 6, 2015 

Joshua L. Vilches 

C.E.T. Aviation 

20 West Gilbert Rd. 

Southbury, Connecticut 06488 

(646) 483-0110 

jvilches@cetaviation.com 

C.E.T. Aviation is requesting that the FAA review and approve this petition for exemption under 

section 333 of the FAA Modernization and Reform Act of 2012 from certain regulations, 

specified in this letter, within Title 14 Code of Federal Regulations (14 CFR) to allow for the 

commercial operation of a small Unmanned Aircraft System in the National Airspace System 

(NAS), for the purpose of providing aerial filming and photography that will support the needs 

of advertising and marketing in a variety of industries. 

C.E.T. Aviation understands the FAA's concern in the regulation of Unmanned Aircraft operating 

in the National Airspace System and believes a level of safety and efficiency can coexist with 

both manned and unmanned aircraft if certain regulations and guidelines are followed. C.E.T. 

Aviation has developed a Flight Operations Manual that will be used as guidance to conduct a 

safe operation using a risk based approach. A copy of this manual has been included in this 

petition package for your reference. This manual describes the physical specifications and 

performance data of the UAS and explains how flight operations will be conducted in greater 

detail. This manual also defines persons authorized to pilot the UAS as well as maintain it. We 

have also included manufacturer owner/user manuals for the components that are installed in 

the UAS for review. These documents provide information on how to install, operate, 

troubleshoot and maintain the UAS. These documents also contain FCC compliance statements 

for the components that transmit a radio signal. You will also find copies ofthe pilot's 

certificates and a photograph of the Unmanned Aircraft System. 

Page 1 oflS 
Name and Address of the Applicant 

Joshua Larry Vilches 

C.E.T. Aviation 

20 West Gilbert Rd. 

Southbury, C.T. 06488 

Tel: 646-483-0110 

jvilches@cetaviation.com 

Unmanned Aircraft System 

1. The small UAS that will be operated by C.E.T. Aviation is called a DJI Flame Wheel F550 

and is distributed by DJIInnovations to a dealer network. The DJI Flame Wheel F550 

arrives at its dealers in kit form and can be custom assembled by the end user. One such 

kit was assembled by RC Hobbies & More in Winsted, Connecticut and was purchased by 

C.E.T. Aviation. Its airframe, motors and propellers have been serialized. This particular 

UAS design is a vertical takeoff and landing hexa-copter, using six electric motors, each 

driving a respective propeller for thrust propulsion and flight control maneuverability. 

Its maximum takeoff weight is 5.29 pounds. Its operational flight speed is from 0 to 30 

mph. Its payload is a video camera gimbal assembly and a small high definition video 

camera. The flight time is 12 minutes plus an additional 25% energy reserve for a fully 

charged battery. The onboard flight control system assists in the flight attitude 

stabilization of the UAS; provides telemetry information such as altitude and battery 

capacity; provides position location for failsafe modes through the use of GPS and 

accelerometers and initiates the failsafe modes (return to home auto-land) for lost 

control link. Additional failsafe modes also includes 2 levels low battery capacity 

warnings and thrust equalization in the event of a failed thrust motor. Please refer to 

the C.E.T. Aviation Flight Operations Manual and supporting manuals and documents for 

additional detailed information regarding the UAS specifications and performance. 

2. C.E.T. Aviation has developed preflight, postflight and emergency checklists to be used 

during UAS operations. A maintenance program has also been developed for the UAS 

and the identification of persons authorized to perform maintenance has been 

determined. Detailed information pertaining to checklists and maintenance of the UAS 

can be found in the C.E.T. Aviation Flight Operations Manual. 

3. This DJI Flame Wheel F550 is controlled by the PIC, at a ground station, using a radio 

control transmitter that transmits on 2.4 GHz radio frequency. The radio control 

transmitter conforms to FCC Part 15 regulations as stated in its instruction manual. 

There is a live video camera feed that is shown on a video display monitor located at this 

ground station. This link is handled by a wireless video transmission system that 

transmits low power on 5.8 GHz radio frequency and it conforms to FCC Part 15 

regulations as stated in its supporting documents. Please refer to the C.E.T. Aviation 

Page 2 of 15 
Flight Operations Manual and supporting manuals and documents for additional 

detailed information regarding UAS operation and regulatory compliance statements. 

Unmanned Aircraft Pilot in Command (PIC} and Visual Observer (VO} 

4. The small UAS will be operated by a pilot in command (PICL Joshua Vilches, and a visual 

observer (VO}, Ryan Voight, who will both ensure that a constant visual line of sight is 

maintained and that the environment surrounding the intended flight path ofthe UAS is 

unobstructed and will not pose a danger to persons or property. Both the PIC and VO 

have been training together using the procedures and guidelines contained in the C.E.T. 

Aviation Flight Operations Manual. The PIC intends to pilot the UAS for at least 25 hours 

offlight time before conducting commercial flight operations in order to become 

familiar with normal and emergency procedures applicable to operating the small UAS. 

• Joshua Vilches (PIC} holds a Private's Pilot's certificate (#3461547} with 220 

hours of total flight time primarily in fixed wing, single engine aircraft and 5 

hours in rotor wing aircraft and maintains Flight Review currency. He also holds 

an Airframe and Powerplant certificate (#3461547} with Inspection Authorization 

and has been actively maintaining full size aircraft for the past 17 years. Joshua 

has graduated with a Bachelors of Science degree in Aircraft Maintenance 

Technology from Pennsylvania College of Technology. He is proficient in flying 

fixed wing, rotor wing, and multi-rotor, radio controlled model aircraft for the 

past 22 years and has approximately 1,000 hours of flight time. This has included 

fixed wing model aircraft aerobatic competition. He is also an amateur hang 

gliding enthusiast and has been piloting weight shift hang gliders for 4 years. 

• Ryan Voight (VO} has approximately 65 hours operating quad-copter type 

Unmanned Aircraft Systems that weigh under 5 lbs for recreation. He also has 20 

years of experience operating radio controlled model sailplanes and is a 

professional hang gliding instructor who has been piloting weight shift hang 

gliders for more than 20 years. His hang gliding rating class and abilities to fly 

cross country has required him to be tested on aeronautical and airspace 

knowledge. Ryan attended Marist College and majored in Communications 

specifically radio, television and film. 

5. Joshua Vilches (PIC} holds a valid Third Class Medical. Refer to the supporting 

documents contained in this petition package. 

Operation of the Unmanned Aircraft 

6. C.E.T. Aviation will ensure flight operations are conducted safely by following 

established regulations, guidelines and procedures in order to mitigate risk. The PIC will 

maintain flight currency with the UAS as outlined in the C.E.T. Aviation Flight Operations 

Manual; the PIC will be responsible for notifying the applicable FAA Flight Standards 

Page 3 of 15 
District Office of the intended flight operation 3 days prior; the PIC and/or VO will 

gather current and forecasted weather information for the day(s) of the flight 

operations; the PIC will ensure the UAS is in serviceable condition and will use preflight, 

postflight, and emergency checklists. The PIC shall not operate the UAS more than an 

altitude of 400 feet above the ground (AGL) and no more than 1,000 feet laterally from 

the UAS ground control station. More detailed information regarding UAS flight 

operation policies and procedures can be found in the C.E.T. Aviation Flight Operations 

Manual. These policies and procedures along with FAA Regulations will ensure a safe 

and efficient entry into the National Airspace System. 

7. The small UAS operated by C.E.T. Aviation has a maximum speed of 30mph (26kts) and 

shall not be operated more than 400 feet above the ground. The PIC and VO will ensure 

that the UAS is not operated when the flight visibility is 3 statute miles or less and will 

maintain cloud clearances of 500 feet below and 2,000 feet horizontal. The UAS is never 

to be flown above any cloud line therefore no cloud clearance from above is given. 

Flying in inclement weather such as visible precipitation and local lightning strikes, and 

winds greater than 15 mph or 13 knots as measured at the ground, is prohibited. Flying 

at night is prohibited. 

8. Operating close to the ground and within tight quarters may impose potential hazards. 

The small UAS operated by C.E.T. Aviation has the ability to hover and its flight attitude 

is stabilized through the use of an onboard flight control system independent of GPS 

signal. There are also built in fail safe modes in the event of lost GPS signal, lost control 

link, failed motor and weak battery levels. The UAS has the ability to autonomously 

return to the take off position and will reduce power settings in the event of a weak 

battery. The VO shall be responsible in ensuring non-essential, non-participating 

personnel do not interfere with the PIC and will monitor the UAS altitude information so 

that the PIC does not operate the UAS higher than 400 feet AGL. C.E.T. Aviation will not 

conduct any flight operations near, in or over stadiums; or over large gatherings of 

personnel. Personnel that are non-essential to the closed-set filming operations area are 

not allowed within 500 feet. This may be reduced to 200 feet if it would not adversely 

affect safety and the Administrator has approved it. 

9. C.E.T. Aviation will not conduct any flight operations at any publicly open, towered or 

non-towered airport. The PIC shall ensure that flight operations are restricted to greater 

than 5 nautical miles of the geographic center of all publicly open, towered or nontowered airports as denoted on a current FAA published aeronautical charts. The UAS 

may not operate in Class B, C, or D surface airspace. 

10. Regarding the FAA's concern with visual line-of-sight (VLOS), at least one crew member 

of the operating flight crew will maintain unobstructed (corrective lenses and sunglasses 

allowed), visual line of sight of the UAS at all times. Sometimes it is necessary for the PIC 

to momentarily view a separate, "live feed" monitor linked to the on board camera to 

keep the recorded subject matter in view. When this occurs, the PIC will call out, "Clear 

Page 4 of 15 
to look down?" The VO will maintain line of sight to the UAS and ensure that it will not 

be in danger of flying into any obstructions. The VO shall respond with ul see the 

aircraft, clear". Once the PIC looks back up to the UAS, he or she shall respond with ul 

see the aircraft". The use of First Person View goggles by the PIC or VO is strictly 

prohibited. 

11. C.E.T. Aviation has established a preflight checklist as outlined in the Flight Operations 

Manual. This checklist ensures flight planning has been performed and ensures the UAS 

is in serviceable condition before flight operations are conducted. 

12. The PIC will be responsible for notifying the local governing FAA Flight Standards District 

Office (FSDO) at least 3 days prior to the scheduled day of flight. This will be in the form 

of a written Plan of Activities which will include at least the following information: 

A) Dates and times of all flights 

B) Name and phone number of the operator of the UAS 

C) Name and phone number of the person responsible for the on-scene operation of 

the UAS 

D) Make, model, serial number and N-number ofthe UAS to be used 

E) Name and certificate number of UAS PICs involved in the flight operations event 

F) A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the flight operations even; the list of those who 

gave permission must be made available to the inspector upon request 

G) Signature of exemption-holder or representative 

H) A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which flight operations will be conducted and the 

altitudes essential to accomplish the operation 

Public Interest and National Security 

C.E.T. Aviation intends to service the needs of aerial filming and photography for the purposes 

of movie making, advertising and marketing in a variety of industries. Traditional methods of 

aerial filming and photography are handled by full sized, fixed and rotor wing aircraft which are 

no longer competitive when compared to the low acquisition and operating costs of small 

unmanned aircraft systems. These cost savings can be transferred to the advertiser then 

ultimately to the consumer to promote competitiveness in the market place. Full sized aircraft 

have a greater environmental impact. They are significantly louder to operate than small, fully 

electric unmanned aircraft systems and carry a much larger ucarbon footprint" adding to the 

growing concern of the emissions of greenhouse gases. Being all electric is beneficial in that it is 

significantly quieter and less likely to disrupt the peace of the surrounding flight operations 

area. Full sized aircraft carry flammable fuels and flight crew and/or passengers. There is a great 

deal of danger imposed to the flight crew and/or passengers and to those on the ground in the 

event of an emergency with regard to full size aircraft. This danger is considerably less in 

Page 5 of15 
comparison with the UAS due to its small size, maximum forward speed and lack of flammable 

fuels. Because C.E.T. Aviation will have a public presence for commercial UAS aerial filming and 

photography, we will be available and willing to assist in disaster relief. 

There is no threat to National Security due to the Transportation Security Administration 

security screening of certificated airmen. Both the PIC and VO are U.S. Citizens and are greatly 

concerned in ensuring the public maintains their right to privacy. 

We believe that because of advancing technologies, small unmanned aircraft systems are much 

less expensive to acquire, easier to operate, and less demanding to maintain when compared to 

full size aircraft. UAS aerial services, such as filming, surveying, inspection and surveillance will 

undoubtedly promote public interest. As C.E.T. Aviation becomes experienced in aerial filming 

and photography, it will look to further service other industries that would benefit from the use 

of unmanned aircraft systems. 

Relief Sought By Petitioner (14 CFR) 

CET Aviation is requesting exemption from the following regulations as they are written in 14 

CFR: Part 21; Part 45.29; Part 61.113(a)&(b); Part 91.7(a); Part 91.9(b) and (2); Part 91.103; Part 

91.109(a); Part 91.119(c)(d); Part 91.121(a)(1); Part 91.151(a); Part 91.203(a) and (b); Part 

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

Part 21- Certification of Procedures for Products and Parts 

This part prescribes the procedural requirements for issuing and changing design approvals; 

production approvals; airworthiness certificates; and airworthiness approvals. 

Part 45.29- Size of Marks 

This part prescribes 

(a) Except as provided in paragraph (f) of this section, each operator of an aircraft must 

display marks on the aircraft meeting the size requirements of this section. 

(b) Height. Except as provided in paragraph (h) ofthis part, the nationality and registration 

marks must be of equal height and on-

(1) Fixed-wing aircraft, must be at least 12 inches high, except that: 

(i) An aircraft displaying marks at least 2 inches high before November 1, 1981 and an 

aircraft manufactured after November 2, 1981, but before January 1, 1983, may display those 

marks until the aircraft is repainted or the marks are repainted, restored, or changed; 

(ii) Marks at least 3 inches high may be displayed on a glider; 

(iii) Marks at least 3 inches high may be displayed on an aircraft for which the FAA has 

issued an experimental certificate under §21.191 (d), §21.191 (g), or §21.191 (i) of this chapter 

to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft when the 

maximum cruising speed of the aircraft does not exceed 180 knots CAS; and 

(iv) Marks may be displayed on an exhibition, antique, or other aircraft in accordance with 

§45.22. 

Page 6 of 15 
(2) Airships, spherical balloons, nonspherical balloons, powered parachutes, and weightshift-control aircraft must be at least 3 inches high; and 

(3) Rotorcraft, must be at least 12 inches high, except that rotorcraft displaying before 

April18, 1983, marks required by §45.29(b)(3) in effect on April17, 1983, and rotorcraft 

manufactured on or after April 18, 1983, but before December 31, 1983, may display those 

marks until the aircraft is repainted or the marks are repainted, restored, or changed. 

(c) Width. Characters must be two-thirds as wide as they are high, except the number "1", 

which must be one-sixth as wide as it is high, and the letters "M" and "W" which may be as 

wide as they are high. 

(d) Thickness. Characters must be formed by solid lines one-sixth as thick as the character 

is high. 

(e) Spacing. The space between each character may not be less than one-fourth of the 

character width. 

(f) If either one of the surfaces authorized for displaying required marks under §45.25 is 

large enough for display of marks meeting the size requirements of this section and the other is 

not, full size marks must be placed on the larger surface. If neither surface is large enough for 

full-size marks, marks as large as practicable must be displayed on the larger of the two 

surfaces. If no surface authorized to be marked by §45.27 is large enough for full-size marks, 

marks as large as practicable must be placed on the largest ofthe authorized surfaces. 

However, powered parachutes and weight-shift-control aircraft must display marks at least 3 

inches high. 

(g) Uniformity. The marks required by this part for fixed-wing aircraft must have the same 

height, width, thickness, and spacing on both sides of the aircraft. 

(h) After March 7, 1988, each operator of an aircraft penetrating an ADIZ or DEWIZ must 

display on that aircraft temporary or permanent nationality and registration marks at least 12 

inches high. 

Part 61.113(a)&(b)- Private Pilot Privileges and Limitations: Pilot in Command 

-Section (a) prescribes that 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. 

-Section (b) of this part prescribes that 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. 

Part 91.7(a)- Civil Aircraft Airworthiness 

Section (a) prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Part 91.9(b)(2)- Civil Aircraft Flight Manual, Marking, and Placard Requirements 

Section (b)(2) prescribes that no person may operate a U.S.-registered civil aircraft for which an 

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

Page 7 of 15 
available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual, approved 

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

Part 91.103(b)- Preflight Action 

Section (b) prescribes that each pilot in command shall, before beginning a flight, become 

familiar with runway lengths at airports of intended use, and the following takeoff and landing 

distance information. 

Part 91.109(a)- Flight Instruction; Simulated Instrument Flight and Certain Flight Tests 

-Section (a) prescribes that 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. However, instrument flight instruction may be given in an airplane that is equipped 

with a single, functioning throw over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when: 

1) The instructor has determined that flight can be conducted safely; and 

2) The person manipulating the controls has at least a private pilot certificate with 

appropriate category and class ratings. 

Part 91.119(c)(d)- Minimum Safe Altitudes; General 

Section 91.119 prescribes that no person may operate an aircraft, except when necessary for 

takeoff or landing, below the following altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. lfthe operation is 

conducted without hazard to persons or property on the surface-

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) 

or (c) of this section, provided each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA; and 

{2) A powered parachute or weight-shift-control aircraft may be operated at less than 

the minimums prescribed in paragraph (c) of this section. 

Part 91.121(a)(1)- Altimeter Settings 

Section (a)(1) of this part prescribes that each person operating an aircraft shall maintain 

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. 

Page 8 oflS 
Part 91.151(a)- Fuel Requirements for Flight in VFR Conditions 

Section (a) of this part prescribes 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. 

Part 91.203(a)&(b)- Civil Aircraft: Certifications Required 

Section (a) of the part prescribes no person may operate a civil aircraft, except as provided in 

§91.715, unless it has within it the following: 

1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a copy 

of the applicable operations specifications issued under §21.197(c) ofthis chapter, 

appropriate sections ofthe air carrier manual required by parts 121 and 135 ofthis 

chapter containing that portion of the operations specifications issued under §21.197(c), 

or an authorization under §91.611) must have on it the registration number assigned to 

the aircraft under part 47 of this chapter. However, the airworthiness certificate need 

not have on it an assigned special identification number before 10 days after that 

number is first affixed to the aircraft. A revised airworthiness certificate having on it an 

assigned special identification number, that has been affixed to an aircraft, may only 

obtained upon application to an FAA Flight Standards district office. 

2) An effective U.S. registration certificate issued to its owner or, for operation within 

the United States, the second copy of the Aircraft registration Application as provided 

for in §47.31(c), or a registration certification issued under the laws of a foreign country. 

Section (b) of this part prescribes that no person may operate a civil aircraft unless the 

airworthiness certificate required by paragraph (a) of this section or a special flight 

authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

Part 91.405(a)- Maintenance Required 

Section (a) ofthis part prescribes that each owner or operator of an aircraft shall have that 

aircraft inspected as prescribed in subpart E ofthis 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. 

Part 91.407(a)(1)- Operation After Maintenance, Preventative Maintenance, Rebuilding or 

Alteration 

Section (a)(1) of this part prescribes that no person may operate any aircraft that has 

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

approved for return to service by a person authorized under §43. 7 of this chapter. 

Page 9 oflS 
Part 91.409(a)(2)- Inspections 

Section (a)(2) of this part prescribes that no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. 

Part 91.417(a)&(b)- Maintenance Records 

Section (a) of this part prescribes that each registered owner or operator shall keep the 

following records, except for work performed in accordance with §§91.411 and 91.413, for the 

periods specified in paragraph (b) ofthis section: 

1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include: 

(i)A description (or reference to data acceptable to the Administrator) ofthe work 

performed; and 

(ii)The date of completion of the work performed; and 

(iii)The signature and certificate number of the person approving the aircraft for return 

to service. 

2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD of safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances. 

Section (b) ofthis part prescribes that the owner or operator shall retain the following records 

for the periods prescribed: 

1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed. 

2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

3) A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until defects are repaired and the aircraft is approved for 

return to service. 

Page 10 of 15 
Reasons for relief 

Part 21 -Certification of Procedures for Products and PartsC.E.T. Aviation requests relief from 14 CFR part 21"Certification procedures for products and 

parts" based on the UAS small size, weight, speed, limited operating area, limited flight time 

and inability to carry crew or passengers. A Flight Operations Manual has been established that 

will be a guideline for conducting safe operations as well as identify persons authorized to pilot 

and maintain the UAS. For these reasons, operating the UAS without an Airworthiness 

Certificate would meet an equivalent level of safety. 

Part 45.29- Size of MarksC.E.T. Aviation requests relieffrom 14 CFR part 45.29 "Size of marks" due to the physical size 

and space available to properly display the Roman capitai"N" and assigned registration number 

on the UAS at the minimum requirement height. C.E.T. Aviation will display such marks and 

numbers as large as possible and in contrasting color, on the UAS using the available space both 

under and above the airframe once the registration number has been assigned. 

Part 61.113{a}&{b)- Private Pilot Privileges and Limitations: Pilot in CommandC.E.T. Aviation requests relief from 14 CFR part 61.113(a)&(b) which limits private pilots to noncommercial flight operations. Because the small UAS cannot carry crew or passengers, has a 

limited operational range and limited flight time, an equivalent level of safety can be 

guaranteed by using the established procedures and guidelines contained in the C.E.T. Aviation 

Flight Operations Manual. The PIC does possess a Private's Pilots Certificate, has a current Third 

Class Medical Certificate, is current in his Flight Review requirements and has considerable 

experience operating fixed wing, rotor wing, and multi-rotor radio controlled aircraft. 

Part 91.7{a)- Civil Aircraft AirworthinessC.E.T. Aviation requests relieffrom 14 CFR part 91.7(a) which requires that no one operate an 

aircraft unless it is in airworthy condition. There are currently no airworthiness standards for 

small UAS, nor is C.E.T. Aviation seeking an "Experimental" airworthiness certificate. Given the 

size, weight, speed and limited operational range and flight time of the UAS; and the 

maintenance guidelines and flight operational procedures and limitations established in the 

C.E.T. Aviation Flight Operations Manual, and all available UAS component manuals and/or 

guides, an equivalent level of safety can be established. 

Part 91.9{b}{2}- Civil Aircraft Flight Manual, Marking, and Placard RequirementsC.E.T. Aviation requests relief from 14 CFR part 91.9(b)(2) which requires that no one operate a 

U.S. -registered civil aircraft unless there is available in the aircraft a current approved Airplane 

or Rotorcraft Flight Manual, approved manual materiat markings, and placards. The small UAS 

does not have the capacity to carry crewmembers and flight and/or approved manuals. The PIC 

of the UAS shall have available the C.E.T. Aviation Flight Operations manual and checklists, and 

all available UAS component manuals and/or guides, located at the ground control station at all 

times during flight operations. 

Page 11 oflS 
Part 91.103- Preflight ActionC.E.T. Aviation requests relief from 14 CFR part 91.103 which requires the pilot in command, 

before a flight, to become familiar with all information concerning that flight. Because the small 

UAS cannot carry crew or passengers, has a limited operational range and limited flight time, 

and will not have approved manuals, an equivalent level of safety can be maintained by the use 

of established procedures and guidelines contained in the C.E.T. Aviation Flight Operations 

manual, which requires the PIC to conduct a preflight action. The PIC shall be responsible for 

FSDO notification, weather forecasts, the serviceability of the UAS, battery capacities and 

battery serviceability, and the proper training and flight currency requirements. For these 

reasons, an equivalent level of safety can be met. 

Part 91.109{a)- Flight Instruction; Simulated Instrument Flight and Certain Flight TestsC.E.T. Aviation requests relief from 14 CFR part 91.109(a) which requires that no one 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. The small UAS in its design does not 

utilize conventional controls. It is remotely operated by the PIC through the use of a radio 

control transmitter at the ground control station and the UAS onboard radio receiver. This 

transmitter/receiver system has the ability to connect to a second radio control transmitter 

(known as a {{buddy box") using an electrical cable connection that allows for training a student 

pilot. The buddy box is always slaved to the PIC's radio control transmitter allowing for 

immediate take over from the student pilot. 

Part 91.119- Minimum Safe Altitudes; GeneraiC.E.T. Aviation requests relief from 14 CFR part 91.119 which establishes safe altitudes for 

aircraft in the event of a power unit failure. The PIC shall keep all UAS flight altitudes restricted 

to no higher than 400 feet above the ground (AGL). This will significantly reduce the potential of 

a midair collision with full sized aircraft operating at higher altitudes. The small UAS shall only 

be operated in a sterile, confined flight operations area that is restricted to a maximum 

perimeter of 400 feet AGL and 1,000 feet latterly from the ground control station. Both the PIC 

and VO shall listen for approaching aircraft near the UAS flight operations area and will 

terminate the flight if there is a threat of a midair collision. Also, given the size, weight, speed, 

limited operational range and limited flight time of the UAS, an equivalent level of safety will be 

achieved. 

Part 91.121{a}{1}- Altimeter SettingsC.E.T. Aviation requests relief from 14 CFR part 91.121(a)(1) which requires each person 

operating an aircraft maintain cruising altitude or flight level of that aircraft by reference to an 

altimeter that is set to the current reported altimeter setting along the route or adjusted to the 

elevation of the departure airport. The small UAS is not equipped with a barometric altimeter 

but instead uses a GPS signal for sensing altitude above the ground. This information is 

transmitted to a video monitor display for viewing by the PIC and/or VO. This altitude 

information will be verified during the initial calibration procedure during the preflight action. 

For these reasons and equivalent level of safety can be met. 

Page 12 of 15 
Part 91.151{a)- Fuel Requirements for Flight in VFR ConditionsC.E.T. Aviation requests relief from 14 CFR part 91.151(a) which requires that no person may 

begin a flight in an airplane under daylight VFR conditions unless there is enough fuel to fly to 

the first point of intended landing and after that for another 30 minutes. The small UAS has a 

maximum flight time of 16 minutes per fully charged battery; however the PIC shall restrict 

cumulative flight time for each fully charged battery to no more than 12 minutes. This allows 

for a 25% power reserve. After the 12 minutes is consumed, the battery will be recharged to 

100% capacity. The UAS built in failsafe modes also allow for pilot notification of low battery 

power through the use of a flashing red LED indicator on the UAS. The next level of failsafe 

would trigger the automatic reduction of available power. This signals the pilot to land the 

aircraft as soon as possible allowing for an equivalent level of safety. 

Part 91.203{a)&(b)- Civil Aircraft: Certifications RequiredC.E.T. Aviation requests relief from 14 CFR part 91.203(a)&(b) which requires that no person 

operate a civil aircraft unless it has within it a current airworthiness certificate and a U.S. 

registration certificate displayed at the cabin or cockpit entrance. There are no current 

airworthiness certification standards for small unmanned aircraft systems nor is C.E.T. Aviation 

seeking an airworthiness certificate for its UAS under the "Experimental" category. The PIC shall 

ensure the UAS is properly registered and marked as appropriately, however he is unable to 

display the U.S. registration certificate in the UAS as it does not have a cabin or cockpit. The PIC 

will maintain such documents at the ground control station. 

Part 91.405{a)- Maintenance RequiredC.E.T. Aviation requests relief from 14 CFR part 91.405(a) which requires that each owner or 

operator of an aircraft have that aircraft inspected as prescribed in Subpart E and shall between 

required inspections have discrepancies repaired as prescribed in part 45. Because the small 

UAS does not have an airworthiness certificate or a manufacturer designated maintenance 

program, every effort shall be made by the PIC to ensure the UAS is in serviceable condition. 

Supporting component manufacturer documents are available and maintenance guidelines 

have been published in the C.E.T. Aviation Flight Operations Manual to ensure the serviceability 

of the UAS. 

Part 91.407{a}{l}- Operation After Maintenance, Preventative Maintenance, Rebuilding or 

AlterationC.E.T. Aviation requests relief from 14 CFR part 91.407(a)(1) which requires that no person may 

operate an aircraft that has undergone maintenance, preventative maintenance, rebuilding or 

alteration unless it has been approved for return to service by an authorized person. The small 

UAS will not have an airworthiness certificate and persons authorized to perform maintenance 

have not yet been established by the FAA. C.E.T. Aviation has defined persons authorized to 

perform maintenance on the UAS in its Flight Operations Manual. The PIC shall ensure the UAS 

is in serviceable condition, is maintained accordingly by authorized personnel, and such 

maintenance is documented in the UAS maintenance logbook. 

Page 13 oflS 
Part 91.409(a}{2} -lnspectionsC.E.T. Aviation requests relief from 14 CFR part 91.409(a)(2) which requires that no person may 

operate an aircraft unless within the previous 12 calendar months it has an inspection for the 

issuance of an airworthiness certificate. There are currently no airworthiness standards for 

small UAS nor is C.E.T. Aviation seeking an airworthiness certificate in the ~~Experimental" 

category. A maintenance program for the UAS has been established and is identified in the 

C.E.T. Aviation Flight Operations Manual. This includes an annual or 100 hour inspection, as 

applicable, and a 10 hour progressive inspection that will ensure serviceability of the UAS. This 

will ensure that an equivalent level of safety will be met. 

Part 91.417(a}&(b)- Maintenance RecordsC.E.T. Aviation requests relief from 14 CFR part 91.417(a)&(b) which requires each registered 

owner or operator keep maintenance, alteration and inspection records and keep those records 

for the time prescribed in the §(b) ofthis part. The small UAS will not have an airworthiness 

certificate and no maintenance authority for UAS has been established by the FAA therefore 

the certificate number of the person or entity to perform the UAS maintenance cannot be 

provided. C.E.T. Aviation has determined persons authorized to perform maintenance, 

alterations and inspections and shall document such work in the aircraft maintenance logbook. 

Such maintenance entries shall be retained for 7 years after the transfer of ownership of that 

particular UAS. 

Foreign Operations 

C.E.T. Aviation does intend to service the aerial filming and photography needs outside of the 

United States as required by the customer. Certain landscapes and backgrounds are not 

available here is the United States and such geographic features found in other countries would 

greatly enhance the captured filming and photography's emotional impact for the viewer, 

providing a uniqueness to the subject matter. We will take the same measures and precautions 

as stated in our Flight Operations Manual both domestically and abroad. We will research and 

obtain appropriate authorizations from those foreign governing agencies and will not operate if 

such requested authorization is not granted. C.E.T. Aviation will always be headquartered in the 

U.S. and it anticipates that 95% of its operation will be located domestically. 

Page 14 of 15 
Conclusion 

C.E.T. Aviation looks forward to your response. We are very excited to be part of advancing 

technologies in aeronautics. Unmanned aircraft systems will undoubtedly be here to stay as it is 

in human nature to progress forward. With your exemption, we will make safety our number 

one priority. We will continuously look for ways to improve operations and comment on ways 

to make unmanned aircraft systems safer. 

Thank you, 

Joshua L. Vilches 

C.E.T. Aviation 

Page 15 of 15