April 3, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, uMAP, LLC (uMAP), a 

survey and aerial imagery acquisition firm, requests exemption from the following Federal Aviation 

Regulations (FARs) that are found under Title 14 of the Code of Federal Regulations (CFR): Part 21 

Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 (b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 

(a) (b), Part 91 Subpart E (91.401-91.417). Such exemptions would allow uMAP to commercially operate 

its Small Unmanned Aircraft Systems (“sUASs) to acquire aerial imagery for various industries with 

respect to the strict operation conditions outlined herein or as established by the FAA as required by 

Section 333. The value of sUASs would provide benefits to several industries and uMAP applies for 

exemption to allow operations to be conducted within Limited Access Area (LAA), which are areas that 

are sparse in population and/or where access is limited to personnel with jobsite clearance. This will 

ensure that all persons near the sUAS operations will be given an operations and safety briefing of the 

planned sUAS operations and/or uMAP can effectively prohibit persons from entering the flight 

perimeter boundaries during the flight operations. Examples of LAAs are construction sites, open-pit 

mines, and private property.

uMAP plans to operate sUASs that are rotorcraft and fixed wing aircraft, each weighing less than 55 

pounds (including payload), at speeds less than or equal to 50 knots, and at or below 400 feet AGL. The 

sUASs are constructed out of lightweight materials such as foam and/or plastic, do not carry flammable 

materials, and will be operated by a highly qualified Pilot In Command (PIC). Given these operating 

limitations, uMAP is confident that operations will not create a hazard to users of the National Air Space

(NAS) nor to the general public and that the operation guidelines herein meet the safety that the 

Congress envisioned that the FAA must, by exemption, allow commercial operation of sUAS. 
1. Company Background

uMAP, LLC. 

Tiffany Javernick PH: 719-431-1262 Email: TiffanyJavernick@gmail.com

1624 Market Street, Suite 202

Denver, CO 80202

uMAP is a female owned scientific and technological services company located in Denver, 

Colorado that provides research, analysis, monitoring, and reporting of geographic data 

captured via remote sensing. uMAP is comprised of highly experienced professionals and 

researchers that include a private pilot with 11 years of experience, a Doctor of Philosophy 

(PhD) in engineering, and a published expert on cutting edge technologies that utilize aerial 

photography. This background makes uMAP a strong competitor in the emerging commercial 

sUAS market and a prime candidate to receive an exemption for sUAS operations.

2. Statutory Authority for Exemptions

FAA Modernization and Reform Act of 2012, Section 333

Under Section 333(a), the FAA “shall determine if certain unmanned aircraft systems may 

operate safety in the national airspace system before completion of the plan and rulemaking 

required by Section 332”. Section 333 (b) of the Reform Act lists several factors that should be 

considered in determining which UAS could allowed to operate in the National Airspace System 

(NAS). Factors considered for UAS are “their size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight do not create 

a hazard to the users of the national airspace system or the public, or pose a threat to national 

security”. If a UAS satisfies Section 333 (b), Section 333 (c) states that the FAA can determine 

“whether a certificate of waiver, certificate of authorization, or airworthiness certification under 

section 44704 of Title 49, United States Code, is required for the operation of unmanned aircraft 

systems”. Therefore, if the FAA determines that UAS meets the criteria of Section 333 (b) and 

does not pose a hazard or threat to the public, NAS, and national security, then the FAA has the 

ability to allow a UAS to operate within the NAS without an airworthiness certification.

3. Meeting the Criteria of Section 333

The operation of sUASs by uMAP will meet all criteria specified in Section 333 (b) as described in 

the paragraphs below. 

3.a. Size, Weight, and Speed

All sUASs operated by uMAP will be constructed of strong, yet lightweight material 

allowing all rotorcraft and fixed wing aircraft to be well below a weight of 55 pounds 

(including payload). All sUASs will be flown at or below an altitude of 400 feet AGL and 

at speeds below 50 knots. All sUASs will be operated within the pilot’s visual line of 
sight, within 1 nautical mile, and in areas with limited access. Therefore, these small, 

lightweight, and slow moving sUASs pose minimal to no hazard to infrastructure or 

persons. Compared to traditional methods of acquiring aerial photographs, the use of 

sUASs offer a considerable risk reduction to aircraft that weigh thousands of pounds, 

carry people, and are powered by flammable materials. 

3.b. Operational Capability

The objective of uMAP aerial photography will be to provide our clients with high 

resolution georeferenced images that can be utilized for analysis including 

construction/mining progress and promotion, agricultural yield monitoring, and digital

elevation model generation. Digital imagery data has a variety of uses and benefits to 

various industries, but the most compelling argument for allowing sUASs to capture 

such data is their ability to provide safe, cost efficient, and fast methods when 

compared to tradition acquisition methods and thus benefit the economy and the public

interest. Prior to any flight, the PIC will complete a pre-flight checklist (Appendix A) and 

all flights will be conducted with a specific flight protocol (Appendix B). All sUASs will be 

launched and landed on-site without the need for a runway, all flights will be conducted 

at or below an altitude of 400 feet AGL, and within visual line of sight, and visual flight 

rules (VFR). Given the built-in safety of most operating sUASs and the extensive training 

required for all PICs (Appendix C), the safety of the aerial vehicle will provide a much 

safer option for aerial imaging and would pose a minimal hazard to the NAS or public.

3.c. Proximity to Airports/Populated Areas

All operations will be performed at considerable and safe distances to airports and 

populated areas. At a minimum, flights will be conducted 5 NM away from general 

aviation airports, at least 3 NM away from any populated area, and at an altitude of 400 

feet AGL or less, which will prevent conflict with manned aircraft operations. Further, all 

operations will be conducted in LAA environments were all persons within the area of 

interest will have explicit information of the flight operations date, time, duration and 

thus operations will not pose a threat to individuals or structures on the ground and will 

remain well clear of any and all air traffic.

3.d. Visual Line of Sight (VLOS)

The sUASs will be flown in accordance with day Visual Flight Rules (VFR) and only in 

Visual Meteorological Conditions (VMC) during day-light hours. Flights will operate 

within 1 NM and VLOS of the PIC at an altitude 400 feet AGL or less. At this time, the 

applicant is not including a safety observer given that the latest Operation and 

Certification of Small Unmanned Aircraft Systems (RIN: 2120-AJ60, Federal Register 

NUmbner 2015-03544) proposes that an observer is not necessary. However, the 

applicant will comply with all requirements of the FAA’s ruling and future guidelines. 
4. Equivalent Level of Safety

The applicant proposes that exemption be granted to our sUAS operations that have the 

characteristics and that operate with the limitations listed herein. These limitations provide an 

equivalent or higher level of safety to operations under the current regulatory structure that 

already operates safe protocols followed by helicopters and conventional aircraft with the 

purpose of acquiring aerial imagery and survey data. Therefore, uMAP sUAS flights will be 

limited to the operations described in Appendix B. 

5. Basis for Petition

5.a. Name and Address of the Petitioner

uMAP, LLC

1624 Market Street, Suite 202

Denver, CO 80202

5.b. Specific Sections of 14 CFR from which uMAP seeks the following exemptions:

o 14 CFR Part 21

o 14 CFR 45.23 (b)

o 14 CFR 63.113 (a) & (b)

o 14 CFR 91.7 (a)

o 14 CFR 91.9 (b)

o 14 CFR 91.103

o 14 CFR 91.109

o 14 CFR 91.119

o 14 CFR 91.121

o 14 CFR 91.151 (a)

o 14 CFR 91.203 (a) & (b)

o 14 CFR 91.405

o 14 CFR Part 91 Subpart E (91.401-91.417)

o 14 CFR 11.83

5.b.1. 14 CFR Part 21 Subpart H: Airworthiness Certificates 14 C.F.R §91.203(a)(1)

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate (FAR §91.203 (a) (1)). The applicatant requests exemption from Part 21 

Subpart H pursuant with Section 333 given the size, and operational capability 

(Limited Area Access described above), proximity to airports and populated areas, 

and VLOS operations with which uMAP will operate sUASs. An equal level of safety 

will be achieved with the operational limitations established in this document 

(Appendix B) for all uMAP flights. Specifically, our sUASs flights will occur within 

VLOS of the PIC, at an altitude of 400 feet AGL or less, and only over designated 

LAAs. Further, coupling our pilots experience in the NAS and with the UAS required 

training (described in Appendix C) will ensure safely operations without creating a 
hazard to any other aircraft, people, or structures on the ground and thus offers a

safer alternative for aerial imagery collection.

5.b.2. 14 CFR 45.23 (b): Marking Requirements

45.23 (b) requires certain aircraft to display the roman capital letter “N” with 

registration number and the words “restricted”, “light­sport”, “experimental”, or 

“provisional”, as applicable, on the entrance to the cabin, cockpit, or pilot station in 

lettering that is between 2 inches and 6 inches in height. The sUASs operated by 

uMAP are unmanned and have no cabin, cockpit, pilot station, or entrance to which 

these required markings could be displayed. In addition, uMAP may not have a 

registration number assigned by the FAA, and therefore seeks full exemption from 

this regulation. However, uMAP proposes to comply with 45.29 (f) by placing the 

word “EXPERIMENTAL” in the largest possible lettering on top of the aircrafts 

fuselage. To ensure an equal or greater level of safety, uMAP also proposes to place

a flag at the ground control station with the words “EXPERIMENTAL UAS” in 3 inch 

lettering. Together, the flag and sUAS marked as “EXPERIMENTAL” will serve to 

inform all persons within visual distance that UAS’ status and operations.

5.b.3. 14 CFR 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

However, since the sUASs will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of safety of current operations by 

requiring the pilot operating the aircraft to hold a Private Pilots license and to have 

completed the sUAS flight training described in Appendix C. When comparing the 

knowledge requirements of a private pilot compared to a commercial pilot (Table 

C1), the results show that “required areas of knowledge for a commercial versus 

private pilot cover the same fundamental principles” and the “experience obtained 

beyond a private pilot certificate in pursuit of a commercial pilot certificate in 

manned flight does not necessarily aid a pilot in the operational environment 

proposed” (Exemption No. 11062). Further, the risk associated with manned 

commercial flights discussed in Part 61 will be decreased with sUAS operations since 

no pilot or passengers are on board, operations will be in limited to controlled and 

restricted areas, and all flights will be planned and coordinated in advance as set 

forth in the Appendix A and B. 

5.b.4. 14 CFR 91.7 (a): Civil Aircraft Airworthiness

Regulation 91.7 (a) states “no person may operate a civil aircraft unless it is in an 

airworthy condition”. Assuming that uMAP is approved exemption for airworthiness 

certification requested in Section 5.b.1, no FAA standard will exist for determining 

airworthiness. Therefore, uMAP seeks full exemption from this regulation. To 
achieve an equal level of safety, prior to each flight uMAP will perform the pre-flight 

protocol and safety checks described in Appendix A as well as follow all 

comprehensive maintenance procedures established by the specific sUAS 

manufacturer. 

5.b.5. 14 CFR 91.9 (b): Civil Aircraft Flight Manual in the Aircraft

91.9 (b) states that no person may operate an aircraft unless there is a current 

approved flight manual for the aircraft onboard. Since the sUASs utilized are small 

and lightweight, it is not physically capable of carrying an aircraft flight manual 

onboard. Given the sUAS is an unmanned aircraft with the PIC located at the ground 

control station, accessing such documents would be impossible during a flight. 

Therefore, uMAP requests exemption from the requirement to carry the aircraft 

flight manual onboard. To provide an equivalent level of safety, uMAP proposes to 

keep the sUASs manufactures’ flight manual at the ground station and thus allowing 

the PIC immediate access. The FAA has issued several exemptions to this regulation 

and include: Exemption Nos. 8737,8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 32827, and 10700.

5.b.6. 14 CFR 91.103: Preflight Action

Regulation 91.103 requires that the PIC be familiar with specific information before 

each flight such as weather, forecast, and fuel requirements to ensure the safety of 

flight. Further, the PIC must be familiar with the information of the approved flight 

manual relating to aircraft performance and take-off and landing distances. Since 

the operated sUASs will not have fuel or a FAA-approved flight manual, uMAP

requests exemption from this regulation. To achieve an equal level of safety, uMAP 

will perform the pre-flight actions listed in Appendix A including checking for 

weather conditions, checking flight battery requirements, checking takeoff and 

landing distances, and all other actions listed.

5.b.7. 14 CFR 91.109: Flight Instruction

Section 91.109 states that “no person may operate a civil aircraft that is being used 

for flight instruction unless that aircraft has fully functioning dual controls”. Since all 

sUASs will be piloted remotely and do not have dual controls, uMAP requests 

exemption from this regulation. An equivalent level of safety can be achieved since 

pilot and passengers are not aboard the aircraft and thus the lack of dual controls 

does not pose a safety hazard. Further, the remote ‘controls’ can be passed back 

and forth between the Instructor and the Student, which will essentially provide the 

same functionality as having dual controls. Examples of exemptions the FAA has 

previously approved for aircraft without fully functional dual controls include: 

Exemption Nos. 5778K & 9862A. 
5.b.8. 14 CFR 91.119: Minimum Safe Altitude

91.119 establishes safe minimum altitude to operate civil aircraft. Section 91.119 (c) 

specifically states that over “other than congested areas” a civil aircraft cannot 

operate below 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.” Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, if the PIC of the 

helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. The functions of the uMAP’s sUASs will be to fly at low altitudes over LAAs that 

can be described as “other than congested areas.” All flight operations will be flown 

at altitudes of 400 feet AGL or less, within close proximity to the PIC to maintain

visual line of sight (VLOS). Therefore, uMAP requests exemption from this 

regulation. An equivalent level of safety will be maintained by only operating sUASs 

over areas that meet our definition of Limited Access Areas, which meet the criteria 

of “other than congested areas.” Given the small size and lightweight airframes of 

sUASs, these alternative aerial platforms offer a significant risk reduction to persons 

and structures on the ground than a manned aircraft providing the same service.

Further, by operating the sUASs at or below 400 feet AGL, uMAP will ensure that 

conflicts will be avoided between manned aircraft that are subject to the minimum 

safe altitude regulation of 91.119 and thus provide an equal or greater level of 

safety.

5.b.9. 14 CFR 91.121: Altimeter Settings

Regulation 91.121 requires aircraft to maintain cruising altitude by reference to a 

current reported altimeter that is set "... to the elevation of the departure airport or 

an appropriate altimeter setting available before departure." Since the sUASs 

operated may not have a barometric altimeter, uMAP requests exemption from this 

regulation. However, all sUASs operated by uMAP will be equipped with GPS that 

will provide both an initial altitude of the launch site prior to flight operations as 

well as real time GPS altitude readings during the flight that are visible to the PIC, 

which will ensure that flights at and below 400 feet AGL. Prior to any flight, a 

separate handheld barometer will be utilized to check that the GPS altitude

accuracy is within a tolerable range. This will ensure a level of safety equal to the 

regulation 91.121. Further details about uMAP’s altitude can be found in the preflight operations of Appendix A, and the flight protocol of Appendix B.

5.b.10. 14 CFR 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Regulation 91.151 (a) outlines fuel requirements for flights in VFR conditions and 

states that no person may begin a flight in Day VFR conditions unless there is 

enough fuel to fly to the intended landing point and fly for 30 minutes after that 
point is reached. Since the operated sUASs are battery operated and will not carry 

fuel, uMAP requests an exemption from 91.151 (a). Since most sUASs batteries will 

be exhausted after flights between 20 to 45 minutes (depending on the sUAS 

model), a 30 minute reserve would leave minimal, if any, operational flight time. 

Instead, uMAP proposes to operate its sUASs until the battery reaches 20% of its 

power (as determined by the onboard monitoring system and the PIC). Such an 

operation guideline will ensure that the sUASs will have plenty of battery to return 

to the launch site safely; however, one major advantage of a sUAS is that unlike 

manned aircraft it can easily and safely land anywhere over a Limited Access Areas 

in which its operations are limited to. Similar exemptions have been granted to 

other operations, including Exemptions 2689F, 5745,10673, and 10808.

5.b.11. 14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration

Regulation 91.203 requires all civil aircraft to have within “...an appropriate and 

current airworthiness certificate” which must be “displayed at the cabin or cockpit 

entrance so that is legible to passengers or crew.” As requested in Section 5.b.1, 

uMAP is already seeking exemption from the airworthiness certificate regulation 

and thus requires an exemption from this regulation. Further, since the small size 

and design of sUASs do not provide cabin or cockpit, there is no ability to carry 

passengers or certification and registration documents. To provide an equal level of 

safety, uMAP proposes keep these documents at the ground flight control point 

where the PIC will have immediate access, to the extent they are applicable to the 

sUAS. Numerous exemptions to this regulation have been granted and include: 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

5.b.12. Part 91 Subpart E (91.401-91.417): Maintenance, Preventative Maintenance 

and Alterations

These regulations outline the requirements for maintenance and inspections in 

reference to Part 39 and Part 43. 91.405 (a), which states that “no person may 

perform maintenance, preventive maintenance, and alterations on an aircraft other 

than as prescribed in this subpart and other applicable regulations, including part 43 

of this chapter.” Since these sections apply to only aircraft with an airworthiness 

certificate, for which uMAP has applied for exemption (Section 5.b.1), uMAP also 

seeks full exemption from these regulations. Prior to any flight, the PIC will be 

responsible for conducting pre-flight inspections and will following all inspection 

requirements specified by the manufacturer of the utilized sUAS. Further details can 

be found in Appendix A.

Preventative maintance and corrective maintance will be conducted by the 

manufacture if so stated by the manufactures’ guidelines. However, in instances 

that the manufacture does not require maintance to be performed by the 

manufacturer, then the PIC will be responsible for conducting maintenance in 
accordance with the manufactures procedures and all maintenance performed by 

the PIC and/or manufacturer will be documented in accordance with 91.407 (a) (1). 

Specifically, records will include “a description of the work performed; and the date 

of completion of the work performed; and the signature of the person approving 

the aircraft for return to service.” Further, uMAP will ensure that no modifications 

or alterations are made to the airframe that affects the flight operating 

characteristics of the sUAS. These proposals are considered to be an equivalent level 

of safety since these sUASs are very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods of time. In the event that 

mechanical issues arise, the sUAS can land immediately and will be operating from 

no higher than 400 feet AGL. 

6. Benefits to the Public

Approval of the above exemptions and commercial operation of sUASs by uMAP will benefit the 

public in the following four ways.

1) The commercial use of sUASs to acquire aerial photographs will reduce the need for manned 

aircraft operating in the NAS. With the skies of America becoming busier and Air Traffic 

Control (ATC) workloads overburdened, the use of sUASs will offer some relief to ATC since 

coordination during ground, take-off, departure, transit, arrival, and landing phases of flights 

is not necessary.

2) Reduced manned aircraft will reduce air and noise pollution. Since all sUASs operated by 

uMAP will be lightweight and battery powered, these sUASs electric motors operate much 

quieter than manned aircraft and do not burn fossil fuels. Typically, aerial photography is 

captured by twin engine fixed wing aircrafts that burn between 20 to 30 gallons of fuel per 

hour and can require significant travel time before reaching the intended area of interest. 

However, acquiring aerial imaging with sUASs can takeoff and land on site and would greatly 

reduce both air pollution and noise pollution which is of great benefit to the public.

3) Operating sUASs for the purpose of aerial photography also reduces the risk to life and 

property on the ground. When compared to a twin engine airplanes, sUASs’ size, weight, 

slow speed, and lack of flammable liquids are considerably less dangerous to people and/or 

structures on the ground.

4) Operations of sUASs offer an effective, affordable, and safe method to acquire aerial 

photography to many business industries such as mining, construction, and agriculture. Such 

cost efficiencies and improved knowledge from available data will result in greater business 

efficiency and thus the potential for economic growth for such industries. These 

high-resolution imagery data generated from sUAS flights can help mines and construction 

sites monitor progress, plan and design future improvements/work, and aid in site surveys 

in both two-dimensional maps and three-dimensional terrain models. Further, farmers and 

scientists can use this aerial data to estimate biomass, yield monitoring, leaf area indexing, 

and overall crop health. In all, this data will provide the information necessary for 

businesses of today to thrive in the future and thus in the publics’ interest. 
7. Summary for Federal Register

Pursuant to with Section 333 of the FAA Modernization and Reform Act of 2012, uMAP LLC 

requests exemption from the following Federal Aviation Regulations that are found under Title 

14 of the Code of Federal Regulations: Part 21 Subpart H, 45.23 (b), 61.113 (a) (b), 91.7 (a), 91.9 

(b), 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) (b), Part 91 Subpart E (91.401-91.417). 

Exemption from these regulations would allow uMAP, LLC to operate small unmanned vehicle 

(of 55 pounds or less) in areas with limited and controlled access for the purpose of providing 

high-resolution aerial imagery.
APPENDIX A: Pre-flight protocol

This section is divided into two areas of i) 24 hours prior to flight and ii) an immediate pre-flight 

inspection checklist.

1) 24 hours prior to flight:

 Prior to a sUAS flight, an area of operation will be established. This area of operation will 

include a defined lateral and vertical area, where the sUAS will operate. Safety procedures 

will be established for persons, property, and applicable airspace within the area of

operation.

 Flights will be operated within line of sight of the PIC.

 The sUAS will weigh less than 55 lbs total. 

 Flights will be operated in Class G airspace whenever possible. lf operation in other airspace 

is required, the relevant controlling agency will be notified at least 24 hours prior to the 

operation and, if required, any necessary permission obtained.

 Flight planning will include flight completion with at least 20% battery power remaining as 

measured by the sUAS or appropriate timing.

 lf equipped, and appropriate for the operation, sUAS aircraft will utilize GPS navigation, 

failsafe, return-to-home (RTH) and/or flight abort safety features.

 A briefing will be conducted in regard to the planned sUAS operations prior to operation at 

each new location. All personnel who will be performing duties within the boundaries of the 

area of operation will be present for this briefing. Therefore, images taken will be of 

individuals who have also consented to being photographed or otherwise have agreed to be 

in the area where aerial photography will take place.

 All required permissions and permits will be obtained from appropriate state, county or city 

jurisdictions, including local law enforcement, fire, or others appropriate governmental 

agencies.

 Written, to include electronic, and/or oral permission from the relevant property owners 

will be obtained prior to an operation.

 All employees working on-site will be thoroughly briefed on sUAS operations prior to 

operations commencing
2) Pre-flight inspection checklist

The pre-flight checklist/inspection will follow the specific pattern and sequence before each 

flight. 

A. Ground station setup:

I. Place the “EXPERIMENTAL” flag near the area of PIC

II. Visually scan the area of operation for any unforeseen hazards, persons, or 

infrastructure

III. Check that all relevant documents are on site and within easy access. These include:

i. PIC’s pilot license and medical certificate

ii. Proof of company’s FAA exemptions

iii. sUAS manufacturer’s flight manual

iv. All maintenance records

B. Pre-start sUAS inspection checklist

I. Check to ensure the sUAS power is “OFF”

II. Battery

i. Check sUAS batter is fully charged

ii. Check the hand-held controller’s battery is fully charged

III. Visually inspect the following

i. All propeller blades are free of damages

ii. All propeller blades are securely attached to the sUAS

iii. All surfaces are free from damages

iv. Antenna is undamaged

C. Pre-flight inspection checklist

I. Turn on the controller and sUAS battery

i. Ensure that all available system read-outs are clearly displayed on the 

controller and within normal range

ii. Test the functionality and free movement of:

1. Propulsion blade(s)

2. Ailerons (if applicable)

3. Check the GPS altitude reading of the sUAS is within range of a 

separate hand held barometer. 

II. Test flight

i. Prior to flying the sUAS for commercial purposes, the aircraft must 

successfully demonstrate a successful flight of approximately one minute in 

duration, in a small area free from any hazards, persons, and property and 

at an elevation at or below 10 feet AGL.
APPENDIX B: Flight protocol

Safety is the first and foremost concern of uMAP. Therefore, the following outlines the 

limitations and conditions which will govern all commercial operations conducted by uMAP PIC 

in lieu of the approved FAA exemptions and all aircraft will be limited to the specifications of 

Appendix D.

 The sUAS will be less than 55 pounds (including payload)

 All sUAS flights will be piloted by an FAA licensed airman with at least a Private Pilot 

certificate and who will have completed the training outlined in Appendix C.

 The sUAS FAA licensed airman will be considered Pilot in Command (PlC), whether flying or 

supervising, and will be responsible for safe operation of the flight.

 The sUAS will operate at or below 400 feet AGL

 No flight will be conducted if wind speeds are in excess of 20 mph.

 The sUAS will operate within 1 NM and within visual line of sight (VLOS) of the PIC

 The duration of each flight shall not exceed 20% of the sUAS battery’s power or a maximum 

total flight time of 30 minutes, whichever occurs first.

 All take-off and landings will occur on-site in accordance with the specifications of the sUAS 

manufacture’s User Manual

 Flights will avoid direct overflight of any office or maintenance buildings located on-site

 Flights will be cancelled in the event that any aircraft or ground control station equipment is 

inoperative or not fully functional

 Flights will be operated under visibility and cloud clearance requirements equivalent to 

Visual Flight Rules (VFR) and only in Visual Meteorological Conditions during daylight hours

 If the PIC identify a potential hazard, such as a manned aircraft within close proximity to the 

designated flight area, the PIC will immediately land the sUAS and operations will only 

resume after the hazard is clear of the area

 Only one sUAS will be airborne at any given time over a specific site, and at least 2NM away 

from any other sUAS operation.

 Minimum crew for each operation will consist of the sUAS PlC. An observer is not specified 

since all operations will be limited to visual line of sight (VLOS) operations and that the 

recent proposals of the ‘Operation and Certification of Small unmanned Aircraft Systems’ 

(RIN: 2120-AJ60, Federal Register Number: 2015-03544) does not require such an observer. 

However, if the FAA decides in this exemption request, or in future regulations that a flight 

observer is necessary, than uMAP will comply. 

 The sUAS PIC will establish a working relationship with a representative at the local FSDO 

with which to annually review safety procedures and other operations to further enhance 

safety.

 All operations will be confined to a Limited Access Area (LAA), which are areas that are 

sparse in population and/or where access is limited to personnel with jobsite clearance. This 

will ensure that all persons near the sUAS operations will be given an operations and safety 

briefing of the planned sUAS operations and/or uMAP can effectively prohibit persons from 

entering the flight perimeter boundaries during the flight operations.
APPENDIX C: Pilot training protocol

With safety the highest priority, proper sUAS flight training is imperative. While uMAP seeks 

highly qualified pilots who have extensive knowledge within the NAS, operations of sUAS are 

unique to manned aircraft as well as to other types of sUAS. Therefore, the following pilot 

training is required in addition to at least a Private Pilots Certificate. 

 The PIC must possess a Private Pilot’s Certificate and a valid third-class medical certificate

 The PIC must have accumulated and logged a minimum of 200 flight cycles and 25 hours of 

total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar 

UAS type (single blade or multirotor).

 The PIC must have accumulated and logged a minimum of five hours as UAS pilot with the 

make and model of UAS to be utilized for operations under the exemption and three takeoffs and landings in the preceding 90 days.

 The PIC will be trained in advance for the safe operation of the sUAS to be operated. This 

will include operation of the sUAS both in normal and emergency modes of operation, and 

will include familiarization with the operation manual (or similar) if published by the sUAS 

manufacturer. Training will also include types of maneuvers to be performed and the safe 

operation in relation to persons, property and applicable airspace.

 Further, the PIC must have also satisfied any additional qualifications/training/experience 

that are required by the sUASs manufacturer (i.e. flight operations and procedures manual). 

At this time, uMAP does not require pilots to hold a Commercial Pilot Certificate. As shown 

below in Table C1, the overall knowledge of a Private Pilot vs. a Commercial Pilot is sufficient for 

the flight maneuvers required for sUAS operations. 

Table C1: Private pilot vs. Commercial Pilot knowledge (Taken from Exemption No. 11062).

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

§ 61.125 Aeronautical knowledge. (a) General. A person 

who applies for a commercial pilot certificate must 

receive and log ground training... 

§ 61.105 Aeronautical knowledge. (a) General. A 

person who is applying for a private pilot certificate 

must receive and log ground training... 

(b) Aeronautical knowledge areas. (b) Aeronautical knowledge areas. 

(1) Applicable Federal Aviation Regulations of this 

chapter that relate to commercial pilot privileges, 

limitations, and flight operations; 

(1) Applicable Federal Aviation Regulations of this 

chapter that relate to private pilot privileges, 

limitations, and flight operations; 

(2) Accident reporting requirements of the National 

Transportation Safety Board; 

(2) Accident reporting requirements of the National 

Transportation Safety Board; 

(3) Basic aerodynamics and the principles of flight; (10) Principles of aerodynamics, powerplants, and 

aircraft systems; 

(4) Meteorology to include recognition of critical 

weather situations, windshear recognition and 

avoidance, and the use of aeronautical weather reports 

and forecasts; 

(6) Recognition of critical weather situations from the 

ground and in flight, windshear avoidance, and the 

procurement and use of aeronautical weather reports 

and forecasts; 
Table C1 continued.

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

(5) Safe and efficient operation of aircraft; 

(7) Safe and efficient operation of aircraft, including 

collision avoidance, and recognition and avoidance of 

wake turbulence; 

(6) Weight and balance computations; (9) Weight and balance computations; 

(7) Use of performance charts; (8) Effects of density altitude on takeoff and climb 

performance; 

(8) Significance and effects of exceeding aircraft 

performance limitations; 

**Related to other areas within the private 

requirements but not referenced specifically** 

(9) Use of aeronautical charts and a magnetic compass 

for pilotage and dead reckoning; 

(4) Use of aeronautical charts for VFR navigation using 

pilotage, dead reckoning, and navigation systems; 

(10) Use of air navigation facilities; 

(4) Use of aeronautical charts for VFR navigation using 

pilotage, dead reckoning, and navigation systems;

(5) Radio communication procedures; 

(11) Aeronautical decision making and judgment; (12) Aeronautical decision making and judgment; and 

(12) Principles and functions of aircraft systems; (10) Principles of aerodynamics, powerplants, and 

aircraft systems; 

(13) Maneuvers, procedures, and emergency operations 

appropriate to the aircraft; 

(7) Safe and efficient operation of aircraft, including 

collision avoidance, and recognition and avoidance of 

wake turbulence;

(11) Stall awareness, spin entry, spins, and spin recovery 

techniques for the airplane and glider category ratings; 

(14) Night and high-altitude operations; ** 

**Although not mentioned in § 61.105, 3 hours of night 

flight training is required for the private per § 61.107 

and § 61.109. For this comparison, high-altitude 

operations are considered not applicable.** 

(15) Procedures for operating within the National 

Airspace System; and 

(3) Use of the applicable portions of the “Aeronautical 

Information Manual” and FAA advisory circulars; (13) 

Preflight action that includes— (i) How to obtain 

information on runway lengths at airports of intended 

use, data on takeoff and landing distances, weather 

reports and forecasts, and fuel requirements; and (ii) 

How to plan for alternatives if the planned flight cannot 

be completed or delays are encountered. 

(16) Procedures for flight and ground training for lighterthan-air ratings. For this comparison (ASEL), these operations are 

considered not applicable.**  

§ 61.127 Flight proficiency. (a) General. A person who 

applies for a commercial pilot certificate must receive 

and log ground and flight training 

§ 61.107 Flight proficiency. (a) General. A person who 

applies for a private pilot certificate must receive and 

log ground and flight training 

(b) Areas of operation. (1) For an airplane category 

rating with a single-engine class rating: 

(b) Areas of operation. (1) For an airplane category 

rating with a single-engine class rating: 

(i) Preflight preparation; (i) Preflight preparation;
Table C1 continued. 

Commercial Knowledge Private Knowledge 

**Airplane Single Engine Land (ASEL) used for comparison** 

(ii) Preflight procedures; (ii) Preflight procedures; 

(iii) Airport and seaplane base operations; (iii) Airport and seaplane base operations; 

(iv) Takeoffs, landings, and go-arounds; (iv) Takeoffs, landings, and go-arounds; 

(v) Performance maneuvers; (v) Performance maneuvers; 

(vi) Ground reference maneuvers; (vi) Ground reference maneuvers; 

(vii) Navigation; (vii) Navigation; 

(viii) Slow flight and stalls; (viii) Slow flight and stalls; 

(ix) Emergency operations; (x) Emergency operations; 

(x) High-altitude operations; and **For this comparison, high-altitude operations are 

considered not applicable.** 

(xi) Postflight procedures. (xii) Postflight procedures. 

**Not referenced specifically** (ix) Basic instrument maneuvers; 

**Not referenced specifically** (xi) Night operations, except as provided in §61.110 of 

this part; and 
APPENDIX D: Utilized aircraft

At this time, uMAP does not own sUASs for commercial operation and has not specified the 

particular aircrafts in which will be operated. Instead, uMAP has specified that both rotorcraft 

and fixed wing UAS systems will be within our fleet of operating aircraft. With the emerging 

technologies of UAS growing rapidly and becoming more affordable, it would benefit uMAP to 

have the liberty to utilize various aircraft and to have the ability to upgrade without regard to 

the particular exemption status. In order to provide as much aircraft detail as possible, uMAP 

will be limited to the aircraft that meet the following specifications:

 All aircraft (rotor and fixed wing) will:

o Have a weight less than 55 lbs

o Operate at speeds slower than 50 knots

o All equipment mounted to the aircraft(s) will be performed by the manufacturer

o All aircraft will be products of reputable companies with at least 3 years of 

operation (e.g. SenseFly, DJI, Aeryon, Trimble, Skycatch, etc.). 

o All aircraft will use radio frequency that comply with the Federal 

Communications Commission requirements. As a general rule, flight controls

and data links will not interfere with manned aircraft communication and radio

frequencies will range between 900 mhz and 5.8 ghz. 

o Be able to safely operate in wind conditions greater than 20 mph.

o Have proven and built in safety features. These can include, but are not limited 

to:

 Emergency landing

 Return to ‘Home’

 Restart propeller

 Ground proximity detection

 Self-monitoring capabilities such as battery levels, wind speeds, etc.