### 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 existsfor 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 proceduresfor 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 (seeDocket No. FAA

−2014

−0352), 11109 to Clayco, Inc. (seeDocket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA

−2014

−0382), and 11213 to Aeryon Labs, Inc. (seeDocket 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 torelief 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 inthe 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

1Aerial 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 betweenthe 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 ifquestions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect 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 f light 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 mustbe 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 f light 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 tothe 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 ofActivities 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 ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 NewJersey 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 thatthe FAA review and approve this petition for exemption under section 333 ofthe FAA Modernization and Reform Act of2012 from certain regulations, specified in this letter, within Title 14 Code of Federal Regulations (14 CFR) to allow for the commercial operation ofa small Unmanned Aircraft System in the National Airspace System (NAS), for the purpose of providing aerial filming and photographythat will support the needs ofadvertising 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 ofsafety and efficiency can coexist with both manned and unmanned aircraft ifcertain 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 ofthis manual has been included in this petition package for your reference. This manual describes the physical specifications and performance data ofthe UAS and explains howflight 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 howto install, operate, troubleshoot and maintain the UAS. These documents also contain FCC compliance statements forthe components thattransmit a radio signal. You will also find copies ofthe pilot's certificates and a photograph ofthe Unmanned Aircraft System.

Page 1 oflSName and Address ofthe 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 bythe 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 propellerfor thrust propulsion and flight control maneuverability. Its maximum takeoffweight 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 flighttime 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 ofthe UAS; provides telemetry information such as altitude and battery capacity; provides position location forfailsafe modesthrough the use ofGPS 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 ofafailed thrust motor. Please referto 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 pertainingto checklists and maintenance ofthe 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 transmitterthattransmits on 2.4 GHz radio frequency. The radio control transmitter conformsto 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 referto the C.E.T. Aviation

Page 2 of 15Flight 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 ofsight is maintained and that the environment surroundingthe intended flight path ofthe UAS is unobstructed and will not pose a dangerto persons or property. Both the PIC and VO have been trainingtogether usingthe 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 orderto become familiar with normal and emergency procedures applicable to operatingthe small UAS.

• Joshua Vilches (PIC} holds a Private's Pilot's certificate (#3461547} with 220 hours oftotal 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 maintainingfull size aircraft for the past 17 years. Joshua has graduated with a Bachelors ofScience degree in Aircraft Maintenance Technology from Pennsylvania College ofTechnology. He is proficient in flying fixed wing, rotor wing, and multi-rotor, radio controlled model aircraft forthe past 22 years and has approximately 1,000 hours offlight 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-coptertype Unmanned Aircraft Systems that weigh under 5 lbs for recreation. He also has 20 years ofexperience operating radio controlled model sailplanes and is a professional hang gliding instructorwho has been pilotingweight 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 ofthe Unmanned Aircraft

6. C.E.T. Aviation will ensure flight operations are conducted safely byfollowing established regulations, guidelines and procedures in orderto 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 notifyingthe applicable FAA Flight Standards

Page 3 of 15District Office ofthe intended flight operation 3 days prior; the PIC and/orVO will gather current and forecasted weather information for the day(s) ofthe 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 of400 feet above the ground (AGL) and no more than 1,000feet laterallyfrom 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 intothe National Airspace System.

7. The small UAS operated by C.E.T. Aviation has a maximum speed of30mph (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 theflight visibility is 3 statute miles or less and will maintain cloud clearances of500 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 greaterthan 15 mph or 

### 13 knots as measured atthe 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 ofan onboard flight control system independent ofGPS 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 abilityto autonomously return to the take off position and will reduce power settings in the event ofa weak battery. The VO shall be responsible in ensuring non-essential, non-participating personnel do not interfere with the PIC and will monitorthe UAS altitude information so that the PIC does not operate the UAS higherthan 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 itwould 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 ofthe geographic center ofall 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 ofthe operatingflight crew will maintain unobstructed (corrective lenses and sunglasses allowed), visual line ofsight ofthe UAS at all times. Sometimes it is necessary for the PIC to momentarilyview a separate, "live feed" monitor linked to the onboard camera to keep the recorded subject matter in view. When this occurs, the PIC will call out, "Clear
Page 4 of 15to look down?" The VO will maintain line ofsight to the UAS and ensure that it will not be in danger offlying 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 bythe 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 notifyingthe local governing FAA Flight Standards District Office (FSDO) at least 3 days priorto the scheduled day offlight. This will be in the form ofa written Plan ofActivities which will include at least the following information:

A) Dates and times of all flights B) Name and phone number ofthe operator ofthe UAS 

### C) Name and phone number ofthe 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 statementthat the operator has obtained permission from property owners and/or local officials to conduct the flight operations even; the list ofthose who gave permission must be made available to the inspector upon request G) Signature ofexemption-holder or representative H) A description ofthe flight activity, including maps or diagrams of any area, city, town, county, and/or state overwhich 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 ofaerial filming and photography forthe 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 ofsmall unmanned aircraft systems. These cost savings can be transferred to the advertiserthen ultimatelyto the consumer to promote competitiveness in the market place. Full sized aircraft have a greater environmental impact. They are significantly louderto operate than small, fully electric unmanned aircraft systems and carry a much larger ucarbon footprint" adding to the growing concern ofthe emissions ofgreenhouse gases. Being all electric is beneficial in that it is significantly quieter and less likelyto disrupt the peace ofthe surroundingflight operations

area. Full sized aircraft carry flammable fuels and flight crew and/or passengers. There is a great deal ofdanger imposed to the flight crew and/or passengers and to those on the ground in the event ofan emergency with regard to full size aircraft. This danger is considerably less in

Page 5 of15comparison with the UAS due to its small size, maximum forward speed and lack offlammable fuels. Because C.E.T. Aviation will have a public presence for commercial UAS aerial filming and photography, we will be available and willingto assist in disaster relief.

There is no threat to National Security due to the Transportation Security Administration security screening ofcertificated 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 ofadvancing technologies, small unmanned aircraft systems are much less expensive to acquire, easier to operate, and less demandingto 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 lookto 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) ofthis section, each operator ofan aircraft must display marks on the aircraft meetingthe size requirements ofthis section. (b) Height. Except as provided in paragraph (h) ofthis part, the nationality and registration marks must be ofequal 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 beforeJanuary 1, 1983, may displaythose marks until the aircraft is repainted orthe 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) ofthis chapter to operate as an exhibition aircraft, an amateur-built aircraft, or a light-sport aircraft when the maximum cruising speed ofthe 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 orthe 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 ofthe character width. (f) Ifeither one ofthe surfaces authorized for displaying required marks under §45.25 is large enough for display of marks meetingthe size requirements ofthis 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 ofthe two surfaces. If no surface authorized to be marked by §45.27 is large enough forfull-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 ofthe aircraft. (h) After March 7, 1988, each operator ofan 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 ofan aircraftthat is carrying passengers or propertyfor compensation or hire; nor may that person, for compensation or hire, act as pilot in command ofan aircraft. -Section (b) ofthis part prescribes that a private pilot may, for compensation or hire, act as pilot in command ofan 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 ofthis chapter, unless there is

Page 7 of 15available 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, instrumentflight instruction may be given in an airplane that is equipped with a single, functioningthrow over control wheel that controls the elevator and ailerons, in place offixed, 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 otherthan 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) ofthis section, provided each person operatingthe helicopter complies with any routes or altitudes specifically prescribed for helicopters bythe FAA; and {2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) ofthis section.

Part 91.121(a)(1)- Altimeter Settings Section (a)(1) ofthis part prescribes that each person operating an aircraft shall maintain cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, when operating: 1) Below 18,000feet MSL, to- (i) The current reported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure.

Page 8 oflSPart 91.151(a)- Fuel Requirements for Flight in VFR Conditions Section (a) ofthis 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 afterthat for at least 30 minutes; or 2) At night, to fly afterthat for at least 45 minutes.

Part 91.203(a)&(b)- Civil Aircraft: Certifications Required Section (a) ofthe part prescribes no person may operate a civil aircraft, except as provided in §91.715, unless it has within itthe 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 ofthe 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 ofthe operations specifications issued under §21.197(c),

or an authorization under §91.611) must have on itthe registration number assigned to the aircraft under part 47 ofthis chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days afterthat number is first affixed tothe 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 ofthe Aircraft registration Application as provided for in §47.31(c), or a registration certification issued underthe laws ofa foreign country. Section (b) ofthis part prescribes that no person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis 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 ofan aircraft shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter.

Part 91.407(a)(1)- Operation After Maintenance, Preventative Maintenance, Rebuilding or Alteration Section (a)(1) ofthis 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 ofthis chapter.

Page 9 oflSPart 91.409(a)(2)- Inspections Section (a)(2) ofthis 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 ofthis chapter.

Part 91.417(a)&(b)- Maintenance Records Section (a) ofthis 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 ofthe maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (includingthe airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include: (i)A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii)The date ofcompletion ofthe work performed; and (iii)The signature and certificate number ofthe person approvingthe aircraft for return to service. 2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe 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 ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD ofsafety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe forms prescribed by §43.9(d) ofthis 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) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year afterthe work is performed. 2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft atthe time the aircraft is sold. 3) A list of defects furnished to a registered owner or operator under §43.11 ofthis chapter shall be retained until defects are repaired and the aircraft is approved for return to service.

Page 10of 15Reasons for relief

Part21 -Certification ofProceduresforProducts and PartsC.E.T. Aviation requests relieffrom 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 inabilityto 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, operatingthe UAS without an Airworthiness Certificate would meet an equivalent level ofsafety.

Part45.29- 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 andLimitations: Pilot in CommandC.E.T. Aviation requests relieffrom 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 ofsafety 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 operatingfixed wing, rotor wing, and multi-rotor radio controlled aircraft.

Part91.7{a)- CivilAircraftAirworthinessC.E.T. Aviation requests relieffrom 14 CFR part 91.7(a) which requires that no one operate an aircraft unless it is in airworthycondition. 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 ofthe 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 ofsafety can be established.

Part91.9{b}{2}- CivilAircraft Flight Manual, Marking, and Placard RequirementsC.E.T. Aviation requests relieffrom 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 ofthe 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 duringflight operations.

Page 11 oflSPart 91.103- PreflightActionC.E.T. Aviation requests relieffrom 14 CFR part 91.103 which requires the pilot in command, before aflight, 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 ofsafety can be maintained by the use ofestablished 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 ofthe UAS, battery capacities and battery serviceability, and the propertraining and flight currency requirements. For these reasons, an equivalent level ofsafety can be met.

Part91.109{a)- Flight Instruction; SimulatedInstrument Flight and Certain Flight TestsC.E.T. Aviation requests relieffrom 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 bythe PIC through the use ofa radio control transmitter at the ground control station and the UAS onboard radio receiver. This transmitter/receiver system has the abilityto 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 immediatetake overfrom the student pilot.

Part 91.119- Minimum Safe Altitudes; GeneraiC.E.T. Aviation requests relieffrom 14 CFR part 91.119 which establishes safe altitudes for aircraft in the event ofa power unit failure. The PIC shall keep all UAS flight altitudes restricted to no higherthan 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 of400 feet AGL and 1,000feet latterlyfrom the ground control station. Both the PIC and VO shall listen for approaching aircraft nearthe UAS flight operations area and will terminate the flight ifthere is athreat of a midair collision. Also, given the size, weight, speed, limited operational range and limited flight time ofthe UAS, an equivalent level ofsafetywill be achieved.

Part 91.121{a}{1}-AltimeterSettingsC.E.T. Aviation requests relieffrom 14 CFR part 91.121(a)(1) which requires each person operating an aircraft maintain cruising altitude orflight level ofthat aircraft by reference to an altimeterthat is set to the current reported altimeter setting along the route or adjusted to the elevation ofthe 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 displayforviewing by the PIC and/or VO. This altitude information will be verified duringthe initial calibration procedure duringthe preflight action. For these reasons and equivalent level ofsafety can be met.

Page 12of 15Part91.151{a)- Fuel RequirementsforFlight in VFR ConditionsC.E.T. Aviation requests relieffrom 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 flyto the first point of intended landing and afterthat for another 30 minutes. The small UAS has a maximum flight time of 16 minutes perfully charged battery; howeverthe PIC shall restrict cumulative flight time for each fully charged batteryto no more than 12 minutes. This allows for a 25% power reserve. Afterthe 12 minutes is consumed, the batterywill be recharged to 100% capacity. The UAS built in failsafe modes also allowfor pilot notification of low battery powerthrough the use ofa flashing red LED indicator on the UAS. The next level offailsafe would triggerthe automatic reduction ofavailable power. This signals the pilot to land the aircraft as soon as possible allowingfor an equivalent level ofsafety.

Part91.203{a)&(b)- CivilAircraft: Certifications RequiredC.E.T. Aviation requests relieffrom 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 underthe "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.

Part91.405{a)- Maintenance RequiredC.E.T. Aviation requests relieffrom 14 CFR part 91.405(a) which requires that each owner or operator ofan aircraft have that aircraft inspected as prescribed in Subpart Eand 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 bythe 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 ofthe UAS.

Part91.407{a}{l}- Operation AfterMaintenance, Preventative Maintenance, Rebuilding orAlterationC.E.T. Aviation requests relieffrom 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 notyet been established bythe 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 oflSPart91.409(a}{2} -lnspectionsC.E.T. Aviation requests relieffrom 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 forthe 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 ofthe UAS. This will ensure that an equivalent level ofsafety will be met.

Part91.417(a}&(b)- Maintenance RecordsC.E.T. Aviation requests relieffrom 14 CFR part 91.417(a)&(b) which requires each registered

owner or operator keep maintenance, alteration and inspection records and keep those records forthe time prescribed in the §(b) ofthis part. The small UAS will not have an airworthiness certificate and no maintenance authorityfor UAS has been established bythe FAA therefore the certificate number ofthe person or entityto 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 afterthe transfer ofownership ofthat particular UAS.

Foreign Operations

C.E.T. Aviation does intend to service the aerial filming and photography needs outside ofthe 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 impactforthe 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 14of 15Conclusion

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

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