March 31, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

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, Witt Tech LLC, the operator of the 3D Robotics IRIS+ 

(“sUAS” or “IRIS+”), seeks an exemption from the Federal Aviation Regulations 

(“FARs”) listed below and discussed in Appendix A.

The requested exemption would permit commercial operation of the 3D Robotics IRIS+, 

which weighs approximately 4 lbs. and is capable of capturing still imagery and video. 

Applications for this sUAS include remote sensing with a focus in mapping, real estate, 

insurance evaluations, and industrial inspection. Use of the IRIS+ for these purposes 

provides high quality data more safely and at a fraction of the cost of using conventional 

aircraft.

Operations under the exemption will be subject to strict operating requirements and 

conditions to ensure at least an equivalent level of safety to currently authorized 

operations using manned aircraft.

As described more fully below, the requested exemption would authorize commercial

operations of remote sensing using the IRIS+, which at 4 lbs. is small in size. The IRIS+ 

will be operated under controlled conditions at low altitude in airspace that is limited in 

scope, as described more fully herein; it will have automated control features, as 

described below. The IRIS+ also will be operated by an individual who has at least a 

private pilot’s certification with at least a third class medical and sUAS flight training. 

Finally, the airspace in which the sUAS will operate will be disclosed to the FAA in 

advance through the use of a COA and NOTAMs.

Witt Tech LLC respectfully submits that because this small unmanned aerial vehicle—the 

IRIS+—will be used in lieu of comparatively hazardous operations now conducted with 

fixed wing and rotary conventional aircraft, the FAA can have confidence that the 

operations will achieve at least an equivalent or greater level of safety. Approval of this 
exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the 

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

“establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

The name and address of the applicant are:

Witt Tech LLC

Address: 1648 S Ohio St #117, Salina, KS 67401

Ph: 785-280-3529

Email: witttechuas@gmail.com

The regulations from which the exemption is requested are as follows:

14 C.F.R. 61.113(a)&(b);

14 C.F.R. 91.7(a);

14 C.F.R. 91.119(c);

14 C.F.R. 91.121;

14 C.F.R. 91.151(a)(1);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a) (1);

14 C.F.R. 91.409(a) (2);

14 C.F.R. 91.417(a)&(b).

Appendix A discusses each rule listed above and explains why exemptions pursuant to 

the proposal set forth in this letter are appropriate, provide an equivalent level of safety, 

and are in the public interest.

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Witt Tech LLC submits that grant of this exemption application for use of the IRIS+ for 

remote sensing with a focus in mapping, real estate, insurance evaluations and industrial 

inspection will advance the Congressional mandate in Section 333 of the Reform Act to 

accelerate the introduction of UASs into the national airspace system (“NAS”) if it can be 

accomplished safely. This law directs the Secretary of Transportation to consider whether 

certain UASs may operate safely in the 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 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’s 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.

The grant of the requested exemption is in the public interest based on the clear direction 

in Section 333 of the Reform Act; the additional authority 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 and cost savings associated with 

transitioning to UASs for remote sensing. Accordingly, the applicant respectfully requests 

that the FAA grant the requested exemption without delay.

The sUAS

The IRIS+ complies with the requirements set forth by Section 333 by its small size, 

weight, speed, and operational proximity to airports and densely populated areas. As a 

result under this exemption the IRIS+ is not deemed airworthy by an airworthiness 

certificate, but rather it is deemed airworthy by the operator conducting a thorough 

preflight of the aircraft. This aircraft will also be registered in accordance to 14 CFR Part 

47, marked in accordance to 14 CFR Part 45 Subpart C, and accompanied by a letter of 

alternative marking due to the unconventional design of a quadcopter. Markings will be 

as large as practicable. This aircraft is of the same size, configuration, and operational 

capabilities of the aircraft granted in exemptions 11138, 11153, and 11157.

Aircraft Make and Model: 3D Robotics IRIS+

Configuration: Quad copter

Aircraft Performance/Specifications:

 Ground Control Station (GCS): The aircraft will be primarily controlled through 

the use of a typical 2.4 GHz RC transmitter. The aircraft can also be preprogrammed to conduct a mission through the use of a laptop or tablet via a 915 

MHz telemetry link. Whenever operations are conducted in this matter, the RC 

Transmitter will be able to take control of the aircraft if the need arises.

 Video Downlink: 5.8 GHz at 200mW

 Lost Com: Aircraft will autonomously return to the launch location and safely 

land.

 Emergency Procedure: Should the need arise the aircraft can be commanded by a 

switch on the RC transmitter to safely land immediately or return and land at the 

launch location. 

 Power Supply: 3S 5.1Ah 8C Lithium Polymer Battery

 Dimensions: 550mm motor to motor

 Maximum Speed: 44 knots

 Normal operating speed: Less than 30 knots

 Weight without payload: 1282g (2lb 13oz)

 Weight with payload: 1656g (3lb 10oz)

Aircraft manuals and operations checklist will be included as additional information to 

this petition for exemption. 
Operator Requirements

To operate the sUAS under this exemption an operator will be required to have at least a 

private pilot’s certification, at least a third class medical, and aircraft specific flight 

training as defined below.

Aircraft specific flight training to include:

25 hours as a UAS rotorcraft pilot including,

10 hours logged as a UAS pilot with a multi-rotor UAS,

5 hours with the specific make and model of the UAS, and

At least 3 take-offs and landings within the preceding 90 days

Mandatory Operating Conditions

Grant of the exemption to Witt Tech LLC will be subject to the following mandatory 

conditions for flight operations.

 Operations shall not occur over congested, actively, or densely populated areas as 

defined by the local FSDO.

 Permission from land owner is required before commencing any flight.

 Operations will only occur during Visual Flight Rules Meteorological Conditions 

(VMC).

 Operations will not occur 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.

 The sUAS will remain clear of manned aircraft and yield right of way.

 A flight test will be conducted after any major repair or alteration.

 A preflight check will be conducted before each flight to assure airworthiness.

 Aircraft will remain within Visual Line of Sight (VLOS) of the operator.

 All operations will be conducted with a Visual Observer (VO).

 Operations will be limited to daylight hours.

 Operations will be concluded with no less than 25% battery power remaining.

 Operations will not exceed 400ft AGL.

 Operations will not occur within 5nm of any airport unless a letter of agreement 

with that airport’s management is obtained.

 Operations will take place under a COA.

 Operator will file a NOTAM for each flight.

 All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire, or other 

appropriate governmental agencies.

 All non-participants will keep 500ft away from operations unless there are 

adequate barriers to protect them.

 All operations will be conducted according to the manufacturer’s manuals. 
 All documents that will be kept at the GCS include but are not limited to; the 

aircraft manuals, maintenance logs, aircraft registration, grant of exemption, and 

COA.

Public Interest

Consistent with the requirements of 14 C.F.R. §11.81(d), Petitioner offers the following 

reasons why granting this petition for exemption is in the public interest, i.e., how 

granting it would benefit the public as a whole.

Approval of this exemption allowing commercial operations of sUAS in the mapping, 

real estate, insurance evaluation, and industrial inspection industries benefits the public as 

a whole in the following ways:

 It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform 

Act, namely, the FAA Administrator's assessment of whether certain UAS may 

operate safely in the National Airspace System before completion of the 

rulemaking required under Section 332 of the Reform Act.

 The operation significantly improves safety and reduces risk by alleviating human 

exposure to danger associated with current aerial remote sensing methods, namely, 

full size helicopters. Reducing human exposure to death or serious injury 

associated with manned aircraft performing these tasks furthers the public’s 

interest.

 Petitioner's sUASs are battery powered and create no emissions. If Petitioner's 

sUAS crashes, there is no fuel to ignite and explode. Any impact of Petitioner's 

lightweight sUASs is far less than a full size manned aircraft. The public's interest 

is furthered by minimizing ecological impact of an accident and by reducing 

human exposure to potentially harmful emissions associated with manned aircraft.

 Remote sensing is as valuable tool for mapping, real estate, insurance evaluations, 

and industrial inspection. However, problems with safety, cost, statistical integrity, 

and logistics continue to impede remote sensing from conventional manned 

aircraft. The use of sUAS addresses these problems and is a powerful tool for 

performing a wide-range of remote sensing applications. The public as a whole 

will benefit from the safer and more cost-effective remote sensing services that 

sUAS operations provide.

Privacy 

All flights will occur over property with the landowner’s prior consent. 
Conclusion

Witt Tech LLC seeks an exemption from the FARs set forth above and in Appendix A to 

allow commercial operations of a sUAS conducting remote sensing with a focus in 

agriculture, real estate, insurance evaluations and industrial inspection.

Approval of this exemption allowing commercial operations of the IRIS+ for remote 

sensing will enhance safety by reducing risk. Conventional remote sensing operations, 

using turbine or piston-powered aircraft present risks associated with vehicles that can 

weigh 5,000 to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in 

some cases, cargo. In contrast, an IRIS+ weighing less than 4 lbs. and powered by 

batteries eliminates a portion of that risk given the reduced mass and lack of combustible 

fuel carried on board. The IRIS+ will carry no passengers or crew and, therefore, will not 

expose any individuals to the risks associated with manned aircraft flights.

Additionally, no national security issue is raised by the grant of the requested exemptions 

due to all pilots being certified through the FAA.

The operation of the IRIS+, weighing less than 4 lbs., for remote sensing in accordance 

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

supporting the grant of the exemptions requested herein.

The IRIS+’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, 

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

operation within visual line of sight, and national security—and its showing of an 

equivalent level of safety provides more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of the IRIS+ in the remote sensing

business.

Best Regards,

Trevor D Witt

President, Witt Tech LLC
APPENDIX A:

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS 

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Witt Tech LLC requests an exemption from the following regulations, all of which have 

been granted by every approved Section 333 exemption at the time of this submission.

14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in command.

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to 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.

Equivalent Level of Safety

Currently, there are no applicable areas identified for sUAS in either the private or 

commercial sector and therefore an exemption is required to conduct commercial 

operations. As flight operations will be conducted in a restricted environment as 

described in the operations section, these strict guidelines will achieve an equivalent level 

of safety for each individual flight especially when compared to commercial flights 

identified in Part 61 when originally developed.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness 

certificate issued for the sUAS, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness.

Equivalent Level of Safety

Given the size of the IRIS+ and the preflight procedures including the review of 

maintenance logs and preflight check lists, an equivalent level of safety will be provided 

to assure the aircraft is in an airworthy condition.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14 

C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above 

the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas.

To provide the intended operations, the sUAS is operated below 400 feet AGL.
Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the 4 pounds 

proposed herein, and given the lack of flammable fuel, any risk associated with these 

operations is far less than those that presently exist with conventional aircraft. An 

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. As set forth in the operations section of this 

exemption, the sUAS will be operated away from densely populated areas and at least 

5nm away from airports (unless a letter of agreement from the airport’s management is 

obtained), where buildings and people will not be exposed to operations without their 

pre-obtained consent. Because of the advance notice to the property owners and 

participants, all affected individuals will be well aware of the planned flight operations.

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

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person 

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

altimeter that is set to the elevation of the departure airport or barometric pressure. An 

exemption is required because the sUAS does not have a barometric altimeter, but rather 

a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by the operator confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will 

use the GPS altitude indicator to constantly monitor the sUAS's height, thus ensuring 

operation at safe altitudes.

14 C.F.R. § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(1)'s fuel requirements for 

flight in VFR conditions during the day. Section 91.151(a)(1) states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes;

Here, the battery powering the IRIS+ provides approximately 16 minutes of flight. To 

meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, sUAS flights could not 

be conducted. Given the limitations on the sUAS's proposed flight area and the location 

of its proposed operations within a predetermined area, a safety margin based on a 

reserve amount of battery life is needed.
Equivalent Level of Safety

An equivalent level of safety will be achieved because the operations will be conducted 

on-site without significant transit time by the sUAS. All flights will be planned to be 

terminated with no less than 25% reserve battery power still available. This restriction 

would be more than adequate to return the sUAS safely to the ground and its planned 

landing zone from anywhere in its limited operating area even in the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 

does not include the type of risks that Section 91.151(a)(1) was intended to alleviate 

given the size and speed of the small UAS, and the proximity of the flight operation to 

the landing zone.

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

Inspections

Petitioner also seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These 

regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 

43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft 

"[s]hall have the aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections ...have discrepancies repaired as prescribed in part 43 of 

this chapter"). An exemption to these regulations is needed because Part 43 and these 

sections only apply to aircraft with an airworthiness certificate, which the sUAS will not 

have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operator will ensure that the 

sUAS is in working order prior to initiating flight by following the preflight checklist, 

perform required maintenance, and keep a log of any maintenance performed. The 

operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition.
APPENDIX B: SUMMARY OF WITT TECH LLC SECTION 333 EXEMPTION 

REQUEST

Witt Tech LLC hereby provides pursuant to Part 11 a summary of its exemption

application to allow commercial operation of the IRIS+ unmanned aircraft in remote sensing. An exemption is requested from the following regulations:

14 C.F.R. 61.113(a)&(b);

14 C.F.R. 91.7(a);

14 C.F.R. 91.119(c);

14 C.F.R. 91.121;

14 C.F.R. 91.151(a)(1);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a) (1);

14 C.F.R. 91.409(a) (2);

14 C.F.R. 91.417(a)&(b).