November 16, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re. Meteorlogik Aerial Resources, LLC Request for Exemption from 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, Meteorlogik Aerial Resources, LLC (“Meteorlogik”), the operator of

Unmanned Aircraft Systems (“UAS”) hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARS”) identified below, to allow for commercial and public service 

operations of its UAS so long as such operations are conducted within and under the conditions 

outlined herein or as may be listed by the FAA as required by Section 333.

I. INTRODUCTION

Meteorlogik Aerial Resources, LLC seeks an exemption to allow for commercial and public 

service operations in the following sectors: agriculture; archeology; construction site planning, 

inspection and monitoring; natural resource management; mining; oil and gas (including pipeline 

inspection and associated infrastructure); power generation utilities and infrastructure inspection; 

freight and transportation infrastructure inspection; structural assessment/inspection of tall 

structures (i.e., wind turbines, communication towers, flare stacks); UAV flight instruction; 

education and research; aerial filmmaking and photography; recreational and event imagery; real 

estate and development promotion; news gathering; insurance assessment and estimation; public 

entity support operations; search and rescue; disaster response and support.

Meteorlogik seeks an exemption to operate the following UAS for compensation or hire within 

the National Airspace System (NAS): DJI Phantom 3, DJI Inspire 1, DJI F550 Flamewheel, DJI 

Spreading Wings S1000, 3D Robotics Y6 and 3D Robotics X8. 

Meteorlogik requests exemption from the following regulations:

14 C.F.R Part 21, Subpart H;

14 C.F.R Part 27;

14 C.F.R § 45.23(b);

14 C.F.R. § 45.27(a);

14 C.F.R § 61.113;

14 C.F.R § 91.7(a);

14 C.F.R § 91.9(b)(2);
14 C.F.R § 91.9(c);

14 C.F.R § 91.103;

14 C.F.R § 91.109(a);

14 C.F.R § 91.119;

14 C.F.R § 91.121;

14 C.F.R § 91.151(a) & (b)

14 C.F.R § 91.203 (a) & (b);

14 C.F.R § 91.405(a);

14 C.F.R § 91.407(a)(l);

14 C.F.R § 91.409(a)(2);

14 C.F.R § 91.417 (a) & (b).

II. METEORLOGIK’S PROPOSED OPERATIONS DO NOT CREATE 

SIGNIFICANT HAZARDS

Meteorlogik’s UAS are rotorcraft weighing 55 or fewer lbs. including payload. They operate under 

normal conditions at a speed of no more than 50 knots and have the capability to hover, and move in 

the vertical and horizontal plane simultaneously. They will operate only in visual line of sight 

(VLOS), remain under 400 ft. AGL and will operate with property owner permission or property 

representative; such operations will insure that the UAS will “not create a hazard to users of the 

national airspace system or the public” as per the reform Act Section 333.

III. METEORLOGIK’S PROPOSED OPERATIONS ARE IN THE PUBLIC 

INTEREST

Granting the present Petition will further the public interest by allowing Meteorlogik to safely, 

efficiently, and economically conduct aerial video and photography.

Additionally, use of the UASs will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Meteorlogik’s proposed 

operation of the UASs will be realized without implicating any privacy issues.

IV. SPECIFIC LIMITATIONS ON PROPOSED FLIGHT OPERATIONS

Meteorlogik’s Operations Manual contains all the procedures and limitation to successfully 

perform commercial and public sector operations. Listed below is a summary of operational 

limitations and conditions which, will ensure a level of safety equal to or exceeding the level of 

safety for operations that are conducted under the current regulatory structure:

1. The UAS will weigh less than 55lbs.

2. Flights will be operated within the line of sight of both the pilot and observer at all 

times.

3. Maximum total flight time for each flight will be limited to the amount of time the 

UAS can be flown and still land with at least 20% battery power remaining.
4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Minimum crew for each operation will consist of the PIC and the VO.

6. The PIC will have at least a sport pilot’s license and will have sufficient knowledge of 

the area where the operation is taking place, as well as training to safely operate the UAS 

in accordance with the standards set forth in the Operations Manual and aircraft 

manufacturers’ user manual(s).

7. The designated VO will be in constant voice contact with the PIC during the entire 

operation.

8. The UAS will operate in accordance with the safety and operational requirements of 

the aircraft manufacturers’ user manual(s).

9. Prior to any operation a Mission Plan will be created setting forth the limitations for 

the flight as well as any hazard information.

10. A briefing will be conducted in regard to the planned UAS operations prior to each 

flight activity. It will be mandatory that all personnel involved with the operational 

duties of the flight be present for this briefing.

11. If the UAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location and land autonomously.

12. The PIC will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Meteorlogik seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 

61, and 91 for purposes of conducting the requested operations using UASs. Listed below are (1) 

the specific FAR sections for which exemption is sought, and (2) the operating procedures and 

safeguards that Meteorlogik has established which will ensure a level of safety better than or 

equal to the rules from which exemption is sought. See 14 C.F.R. §11.81 (e).

14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R.

§ 91.203(a)(1)

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

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no 

exemption is needed. See Grant of Exemption to Astraeus Aerial, Docket No. FAA 2014-0352 at 

pages 13-14, 22. If, however, the FAA determines that there are some characteristics of

Meteorlogik’s UASs that fail to meet the requirements of the Reform Act, an exemption is 

requested.

Equivalent Level of Safety: The UASs identified in Section I are safe when taking into account 

size, weight, speed, and operational capability. The UASs utilized by Meteorlogik weigh less 

than 55 pounds and will be flown at speeds under 50 kts. and in visual line of sight of the 

operator. The UAS does not carry pilots, passengers, explosive materials, or flammable liquid 

fuels. The UAS will be operated within the parameters of the aircraft manufacturers’ user 

manual(s).
Operations that occur under this exemption will be closely monitored and controlled by the PIC 

and will be conducted in compliance with local public safety requirements. Meteorlogik will 

also provide the FAA with advance notice of all operations via NOTAM and coordination with 

the local FSDO. The proposed operations will be at least as safe as, or safer than, conventional 

rotorcraft operating with an airworthiness certificate without the restrictions and conditions 

proposed here. The proposed operations will also be as safe, or safer than, traditional power line 

monitoring and/or wind turbine inspection methods.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal 

category rotorcraft. To the extent Meteorlogik’s UASs would otherwise require certification 

under Part 27, Meteorlogik’s seeks an exemption from Part 27’s airworthiness standards for the 

same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification 

Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

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

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

“provisional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on 

both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

14 C.F.R. § 91.9(c) states: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements 

was warranted provided that the aircraft “have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C if the markings are “as large as practicable.” See 

Exemption No. 11062, Docket No. FAA 2014-0352, p. 14.

Equivalent Level of Safety: Meteorlogik will mark all UAVs with their N-Number in a 

prominent spot on the fuselage with markings that are as large as practicable.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Meteorlogik seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying 
aircraft for compensation or hire and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in 

which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire.

While the UASs will be operated as part of a commercial operation, it carries neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined 

that the unique characteristics of UAS operation outside of controlled airspace did not warrant 

the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot 

certificate and a class II medical certificate. The FAA has also determined that the required 

knowledge for a commercial pilot covers the same fundamental principles as a private pilot.

Equivalent Level of Safety: Meteorlogik will ensure that an equivalent level of safety will be 

maintained as no PIC will be allowed to operate the UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate the UAS in 

a manner consistent with the operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures.

Further, Meteorlogik submits that all flights of the UAS, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to Meteorlogik business; and (2) will not carry 

passengers or property for compensation or hire

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

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

in airworthy condition to be operated. The FAA has stated that no exemption is required to the 

extent that the requirements of Part 21 are waived or found inapplicable. Accordingly, 

Meteorlogik requests that the requirements for Section 91.7 be treated in accordance with FAR 

Part 21 Subpart H.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to person 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

 ...

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of 

this chapter, unless there is available in the aircraft a current approved Airplane or

Rotorcraft Flight Manual, approved manual material, markings, and placards, or

any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has

 within it the following:

(1) An appropriate and current airworthiness certificate.
(b) 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.

Meteorlogik does not request an exemption from this section but instead notifies the FAA

that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, 

the UAS aircraft manufacturers’ user manual(s), registration certificate and other 

documentation will be kept at the control station with the PIC during flight. The Chief 

Counsel’s Office has held that for all UAS operations, this alternate method constitutes 

full compliance with the regulations. 

14 C.F.R. § 91.103: Preflight Action

Meteorlogik seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all 

information necessary to safely conduct flight operations, an exemption is requested to the extent 

that an FAA approved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the

Operations Manual and aircraft manufacturers’ user manual. The PIC will take all required 

preflight actions - including performing all required checklists and reviewing weather, flight 

requirements, battery charge, landing and takeoff distance, aircraft performance data, and 

contingency landing areas - before initiation of flight. The Operations Manual and aircraft 

manufacturers’ user manual will be kept at the ground station with the operator at all times.

14 C.F.R. § 91.109(a): Flight Instruction

Meteorlogik seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 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.” UASs and remotely piloted

aircraft, by their design, do not have functional dual controls. Instead, flight control is

accomplished through the use of the Flight Control System/Ground Control Station (GCS) that 

communicates with the aircraft via radio communications.

Equivalent Level of Safety: Given the size and speed of the UASs, an equivalent level of safe 

training can still be performed without dual controls because no pilot or passengers are aboard 

the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences 

any difficulties during flight instruction. In addition, Meteorlogik will conduct flight training at 

a remote facility away from population centers. These training flights will be conducted in a 

sterile training area and will otherwise comply with the provisions in the Operations Manual and 

aircraft manufacturers’ user manual. In addition, Meteorlogik’s proposed method of operation 

provides superior levels of safety.
14 C.F.R. § 91.119: Minimum Safe Altitudes

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

C.F.R. § 91.119. Section 91.119 prescribes that an aircraft may not be operated closer than

500 feet to any person, vessel, vehicle, or structure in non-congested areas. See 14

C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those 

minimum altitudes when it can be operated “without hazard to person or property on the 

surface,” provided that “each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA.”

Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more

than the maximum weights 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 locations where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to 400 feet AGL or below. 

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

Meteorlogik 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 to the extent 

that the UAS does not have a barometric altimeter setting, but rather a GPS altitude read out.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety can be

achieved if the aircraft will be operated at or below 400 feet AGL and within VLOS in addition 

to GPS based altitude information relayed in real time to the operator. See Grant of Exemption 

No. 11062, p. 20-21. As the attached Operations Manual and aircraft manufacturers’ user 

manual indicate, the UAS will be operated at or below 400 feet AGL and complies with the 

limitations in the Grant of Exemption No. 11062.

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

Meteorlogik requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in 

VFR conditions. Section 91.151 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; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. Meteorlogik proposes 

that all flights comply with this requirement by mandating that the aircraft be safely landed with 

no less than 20% of remaining battery life.

Equivalent Level of Safety: The FAA has stated that an equivalent level of safety is provided if
the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated

with at!least!5!minutes!or!with!the!reserve!battery!power!recommended!by!the!

manufacturer!if!greater. See Grant of Exemption No. 11062, p. 21- 22. The Operations 

Manual and aircraft manufacturers’ user manual confirms this limit, which provides an 

equivalent level of safety.

14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and

(b): Maintenance Inspections

Meteorlogik seeks an exemption from the maintenance inspection requirements contained in 14 

C.F.R. § 91.405(a), 91.407(a)(l), 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 from these regulations is 

needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, 

which the UAS will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance

and inspections will be performed in accordance with the aircraft manufacturers’ user manual. 

This includes maintenance, overhaul, replacement, and inspection requirements for the aircraft 

and procedures to document and maintain maintenance records for the aircraft. This also 

includes preflight inspection procedures. As provided in the Operations Manual, flights will not 

be conducted unless a flight operations checklist is performed that includes all of the aircraft’s 

components. The Operations Manual and aircraft manufacturers’ user manual also set 

requirements for maintenance log books and record keeping as well as routine and post-flight 

maintenance. The Operations Manual and aircraft manufacturers’ user manual set requirements 

for both annual maintenance and preventative maintenance.

VI. SUMMARY FOR FEDERAL REGISTER

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: 

Meteorlogik seeks an exemption from the following rules: 14 C.F.R Part 21, Subpart H; 14 

C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 

91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 

C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 

C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & 

(b).

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners from the hazards associated with performing the same work with conventional 

rotorcraft and aircraft. 
VII. CONCLUSION 

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested exemptions to permit Meteorlogik to operate the selected UASs in the 

manner described within.

Granting the requested exemption will benefit the public interest as a whole in many ways, 

including (1) significantly improving safety and reducing risk to human life; (2) improving the 

quality of services offered; and (3) decreasing the operating costs compared to those of 

conventional aircraft and rotorcraft.

Respectfully submitted, 

Joseph A. Kimmet, owner/operator

Meteorlogik Aerial Resources, LLC 

1141 Sabraton Ave

Morgantown, WV 26505

Tel: (304) 376-9616

JAKimmet@gmail.com