U.S. Department of Transportation, Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE., Washington, DC 20590 

August 4, 2015 

Re: Raven Petition for Exemption 

Dear Sir or Madam, 

Raven is a sUAS delivery platform startup founded by three young engineers with mechanical, 

robotics, and software engineering backgrounds. This petition is submitted on our behalf 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R Part 

11, Ravi Gangele (Raven), a Virginia based startup operating small unmanned aerials systems 

or sUAS equipped to transport cargo for various industries, hereby applies for an exemption 

from the Federal Aviation Regulations described below to allow our sUASs to operate under the 

pretense of research and development, and demonstrations over private property with consent 

of the landowner and terms of operating specified by the Federal Aviation Administration. 

Use cases, or commercial pursuits that the research conducted from the requested exemption 

will allow Raven to partake in is, but is not limited to, as follows: 

• Emergency Aid Supply delivery 

• Food delivery 

Flights conducted on private property for demonstration purposes will always be pre-planned 

flights coordinated with the owner or management team of the private property to ensure the 

landing area designated within line of site is isolated from the vicinity of any person on said 

property. 

Raven sUAS are custom-built multicopters and are fully detailed in Appendix A. We currently 

have two sUAS models, the F8 and the F6. The F8 is an octocopter 1727 mm in diameter. The 

F6 is 845 mm in diameter. Both the F8 and F6 sUAS utilize a 3DR Pixhawk flight controller; it is 

the same unit found in 3DR Iris+ sUAS and numerous other sUAS products sold by 3DR and 

granted Section 333 exemption for several companies. The Raven F6 and F8 do not have video 

recording equipment. The focus of Raven sUAS is safe and reliable transport of cargo along a 

predetermined, and pre-inspected path. From here on, the F6 and F8 will be collectively treated 

as a singular sUAS due to the indistinguishability of their architectures, and will be referred to as 

‘this sUAS,’ or ‘sUAS.’ 

1
Information Required by 14 C.F.R. §11.81 for this Petition 

 

A. NAME AND MAILING ADDRESS

Ravi Gangele 

Founder 

Raven 

21892 Larchmont Way 

Ashburn, VA 20148 

703-505-9182 

ravi.gangele@flyraven.io 

www.flyraven.io 

B. SPECIFIC SECTION(S) OF 14 C.F.R THAT RAVEN SEEKS TO BE EXEMPT FROM 

 

1. 14 C.F.R Section 21.185 (a) Airworthiness Certificate 

2. 14 C.F.R Section 45.23 (b) Display of marks; general. 

3. 14 C.F.R Section 61.113 (a) (b) Private pilots privilege & limitations PIC 

4. 14 C.F.R Section 91.7 (a) Civil Aircraft Airworthiness 

5. 14 C.F.R Section 91.9 (b)(2) Civil Aircraft Manual 

6. 14 C.F.R Section 91.103 Preflight Actions 

7. 14 C.F.R Section 91.109 Flight Instructions 

8. 14 C.F.R Section 91.121 Altimeter 

9. 14 C.F.R Part 21, Subpart H: Airworthiness Certificates - 14 C.F.R Section 91.203 (a) (1) 

10. 14 C.F.R Section 91.405 (a) Maintenance required 

11. 14 C.F.R Section 91.407 (a) Operation After Maintenance 

12. 14 C.F.R Section 91.409 (a) (1) (2) Inspections 

13. 14 C.F.R Section 91.417 (a) (b) Maintenance Records 

 

C. EXTENT OF RELIEF NEEDED, REASON RELIEF IS BEING REQUESTED, AND 

HOW SAFETY IS NOT ADVERSELY AFFECTED 

 

 14 C.F.R Section 21.185 (a) Airworthiness Certificate 

 

While the FAA is developing standards for sUASs and UAV’s, this sUAS is seeking exemption 

from the requirements from 14 C.F.R 91.203 (a)(1) and 14 C.F.R Part 21. Since this sUAS will 

carry no pilot or passengers, fly under 100ft AGL, at a moderate speed, and given this sUASs 

size and weight it would seem unnecessary to go through the Airworthiness Certificate process 

to maintain or exceed the equivalent level of safety expected by the FAA. Furthermore this 

sUAS will operate on either private property or on one of the six FAA testing grounds. 

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14 C.F.R Section 45.23 (b) Display of marks; general 

 

Since there is no cabin or like location on this sUAS placing “Experimental” in 2 inch lettering 

would be difficult. A practical size lettering of will be placed on the sUAS stating “Experimental”, 

if deemed necessary by the FAA. We respectfully propose that all relevant documentation and 

relevant materials be kept with the operator at the time of any flight to uphold the equivalent 

level of safety that the FAA expects from all aircrafts. Prior FAA rulings have deemed that this 

would be safe and granted this exemption in the past. 

 

14 C.F.R Section 61.113 (a) (b) and 61.133(b) Private Pilot Privileges and 

Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations 

 

This sUAS will not carry a pilot or passengers and all flights will be pre-planned and on private 

property or one of six FAA testing areas all controlled remotely. We believe that with the size of 

this sUAS and the precaution we will take, we will achieve equivalent if not higher levels of 

safety than a commercial pilot. Prior FAA rulings have granted this exemption without a Pilot in 

Command (PIC). We propose that these requirements as well as a deep level of preprogrammed control and many built-in technical capabilities via Mission Planner software. This 

software lets the operator and the operator’s team, view all aspects of the flight in real time. This 

Mission Planner software allows for advanced features that were only previously available to 

larger and more complex unmanned aircrafts. This software has features that have several failsafes in place to enabling this sUAS to have consistently safe, reliable and well-documented 

flights. The Mission Planner software would assist the operator in the flight of sUAS, ensuring a 

safe, predetermined path. To clarify, the operator is always in control of the sUAS while the 

software aids the operator in ease of use through streamlined telemetry readouts, and simple 

flightpath routes.

Features that the Mission Planner software are as follows: 

• A “Return to home/Return to Launch” feature that would immediately return the sUAS if any 

emergency situation would occur 

• No-Fly Zones are pre-built into the software to ensure no flights are within this area 

• A live telemetry feed of the sUAS before, during, and after the flight. 

 

Flight safety is the most important priority of this sUAS. This sUAS has created a platform that 

exceeds the safety levels of any manned aircraft by taking the operator out of the aircraft and 

any potentially unsafe situations by keeping limiting the operator’s ability in only a safe range. 

We would also like to note that the FAA has in the past granted this exemption. 

 

With the conditions and restrictions in place the equivalent level of safety will be provided 

without a private or commercial pilot.

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

 

If the exemption 21.185 were granted (there will no airworthiness certificate issued) there would 

be no FAA regulation to determine airworthiness. The operator of the flight would then 

determine the airworthiness. Prior FAA rulings have granted this exemption under the same 

circumstance. With the specification of this sUAS and all flights being done on private property 

or at one of six FAA testing areas this sUAS would achieve the equivalent level of safety. An 

equivalent level of safety would also be achieved with a combination of several monitoring 

systems on board the sUAS as well as following FAA guidelines (on when deemed safe to fly) 

and a written protocol that the operator of the sUAS will use before, during and after each flight. 

(This includes but is not limited to inspecting the sUAS before/after each flight, planning each 

flight prior to flying, insuring weather conditions for flying, being aware of all airports and no fly 

zones, etc.) 

 

14 C.F.R Section 91.9 (b)(2) Civil Aircraft Manual 

 

Due to the size and configuration of this sUAS, it would be impossible to carry the flight manual 

on the aircraft. Keeping the flight manual on the ground with the operator at the time of the flight 

would maintain an equivalent level of safety. The FAA has granted this exemption before under 

the same circumstances and also deemed it unnecessary to seek relief from 14 C.F.R section 

91.9 but we would like to make sure that this is documented to ensure this sUAS is compliant 

with FAA regulations. 

 

14 C.F.R Section 91.103 Preflight Actions 

 

If granted section 91.9 (b) exemption the flight operator will make sure all pre-flight conditions 

and checks are completed before take off. These include but are not limited to weather, aircraft 

battery levels, flight plan, wind speeds, along with the overall condition of the aircraft. The FAA 

has granted this exemption in the past and has deemed the operator of a sUAS of this size and 

specification is qualified to complete all pre-flight checks. Safety is the number one priority of 

each flight and the operator will achieve the equivalent levels of safety with is exemption. 

 

14 C.F.R Section 91.109 Flight Instructions 

 

While the operator is using the primary radio transmitter, Mission Planner, the ground control 

station software of the sUAS running on a laptop and using a second radio transmitter, can 

allow the instructor and student to simultaneously control the sUAS, along with fail-safe 

programming in place to safely land the sUAS or place it in Loiter mode if needed. We believe 

this method should meet the purpose of 91.109 with a parallel level of safety. It should be noted 

that the FAA has granted exemption for this type of setup. 

4
14 C.F.R Part 21, Subpart H: Airworthiness Certificates - Section 91.203 (a) (1) 

 

The sUAS at max weight will be less than 55 pounds and unmanned. This sUAS will not be able 

to carry or display certifications and registration documents onboard. The equivalent level of 

safety will be achieved by keeping these documents on the ground during flights. The FAA has 

deemed this safe in the past and approved this exemption. 

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

 

The sUAS has two batteries onboard that provide 15 minutes of flight time, and all flights that 

take place with said sUAS would be under 5 minutes long. To exceed the level of safety the FAA 

expects, this sUAS would return to its “Launch/Home” position prior to having a low battery. With 

this safety precaution in-built into this sUASs system, we would eliminate any risk that could 

have been created by not having a 30-minute reserve on the batter prior to a flight. Furthermore, 

all flights would be conducted on private property; with no pilot or passengers onboard and due 

to the specifications of this sUAS we would uphold and exceed the equivalent level safety 

without having a 30-minute reserve. 

 

14 C.F.R Section 91.405 (a), 91.407 (a), 91.409 (a) (1) (2), 91.417 (a) (b) - 

Maintenance required, Operation After Maintenance, Inspections and Maintenance Records 

 

Maintenance of this sUAS will be performed by the operator in accordance with the instruction 

material provided by the manufacturers of all components of this sUAS. When these instructions 

are followed from each given manufacturer, an exceeded amount of safety would be achieved in 

the C.F.R because of the characteristics of this sUAS, as follows: 

Moderate size and mechanical simplicity 

The lack of a pilot, crew, passengers, and cargo 

Flights will be done on private property or one of six FAA testing grounds 

The entire team is trained to have a deep understanding of all the maintenance points of the 

aircraft prior to and after the flight 

All of the flight data will be logged into the software Mission Planner’s logs and are available for 

the operator and their team to review at anytime. This sUASs frame is unique among most other 

sUAS, in that, it is made from strong but light carbon fiber. 

5
D. Public Benefits 

With our sUAS models, the F6 and F8, we would be able to prove reliable and quick 

transportation of emergency supplies to natural disaster areas in the United States. Our 

exemption is to conduct the appropriate research and development of the F6 and F8 to serve 

this purpose in the future through agencies such as FEMA and the American Red Cross. 

Commercial businesses such as golf courses would be able to utilize a Raven sUAS to deliver 

food in a quick and safe manner, while boosting their business with increased food revenue. 

Raven is a safe and affordable alternative to traditional land and air based delivery methods. 

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Appendix A - Technical specifications of the Raven sUAS 

models 

RAVEN F6 

• Weight (including battery, no payload): 8 lb.

• Weight with max payload; max takeoff weight: 12.5 lb.

• Fuel type: Two Lithium Polymer batteries monitored via telemetry for low voltage levels 

• Motors: 6 Electric brushless DC motors; KDE 2814XF

• Landing type: Vertical landing, Two T-shaped carbon fiber landing legs 

• Size: 

• Diameter: 845 mm (including 13” propellers) 

• Height: 298 mm 

• Frame type: Tarot 680 Pro carbon fiber frame, hexacopter configuration 

RAVEN F8 

• Weight (including battery, no payload): 20 lb.

• Weight with max payload; max takeoff weight: 39 lb.

• Fuel type: Two Lithium Polymer batteries monitored via telemetry for low voltage levels 

• Motors: 8 Electric brushless DC motors; KDE 4012XF

• Landing type: Vertical landing, Two T-shaped carbon fiber landing legs 

• Size: 

• Diameter: 1227 mm (including 18” propellers) 

• Height: 546 mm 

• Frame type: Tarot T18 carbon fiber frame, octocopter configuration 

RELIABILITY 

While the Raven F6 and F8 sUAS utilize different motor sizes, both are supplied by KDE, a 

leading manufacturer of reliable, high-performance, heavy-lift sUAS motors. They also provide 

extensive documentation on motor performance and maintenance. Routine wear on 

components such as motors (ball bearings), and batteries will be both observed by physical and 

software-based inspections prior to and after flights. 

7

We respectfully request that pages 7-11, i.e Appendix A, B, and C not be republished 

for public viewing.
Appendix B - Motor Specifications 

Motors being used on the Raven F6 sUAS:

8
Motors being used on the Raven F8 sUAS

9
 Appendix C - Sample Flight Path 

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Safety Precautions: 

• Private Golf course / Country club will help us determine safe, 

secluded landing areas and make patrons aware. 

• No flights during bad weather i.e rain, high wind. 

• Flights can ONLY occur when course is near empty, and no 

patrons playing within 30 ft. from the flightpath. 

• Flightpath has been surveyed and is well within the operator’s 

line of sight. 

• Only one sUAV will operate at a time. 

• Operator will be operating the sUAS via an industry standard 

radio transmitter, and a secondary operator will be 

monitoring the sUAS and it’s flight via the assistance software 

Mission Planner on a laptop next to the operator. 

• Secondary operator in addition to operator would be able to 

activate failsafes such as Loiter or Return to Launch if deemed 

necessary. 

• Max altitude will be 100 ft. and more than 5 miles from any 

airport. 

Golf Course example
11

Private field test example (disaster relief testing)

Safety Precautions: 

• Private property owner aware of sUAS operations. 

• No flights during bad weather i.e rain, high wind. 

• No humans are in or near the vicinity of the flightpath. 

• Flightpath has been surveyed and is well within the 

operator’s line of sight. 

• Only one sUAV will operate at a time. 

• Operator will be operating the sUAS via an industry 

standard radio transmitter, and a secondary operator will 

be monitoring the sUAS and it’s flight via the assistance 

software Mission Planner on a laptop next to the operator. 

• Secondary operator in addition to operator would be able 

to activate failsafes such as Loiter or Return to Launch if 

deemed necessary. 

• Max altitude will be 350 ft. and more than 5 miles from any 

airport.