August 12, 2015 

 Exemption No. 12448 

 Regulatory Docket No. FAA−2015−0813 

Mr. Thomas Petitti 

DUAV, LLC 

1704 Edgewood Drive 

Milford, IA 51351 

Dear Mr. Petitti: 

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 March 23, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of DUAV, LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography and inspections. 

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 exists for 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 F550. 

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 
2 

finds that relief from 14 CFR part 21, Certification procedures for 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 (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket 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 to relief 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 in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, DUAV, LLC 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 

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, DUAV, LLC is hereafter referred to as the operator. 

 

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 Aerial 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 

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 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 

Administrator upon request. If a discrepancy exists between the 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 
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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 if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect 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 flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

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 must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
5 

(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 flight 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. 

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. 
6 

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 to the 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. 

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. 
7 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities 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. 

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

Enclosures 
 DUAV

1704 Edgewood Drive

Milford IA. 51351

712.330.6417

Petitti@duav.org

DUAV

Okoboji Iowa

712.330.6417

Petitti@duav.org

March 23rd, 2015

 

Request for exemption under FAA Modernization & Reform Act of 

2012, Section 333, to operate an Unmanned Aerial System for Aerial 

Photography and Aerial Inspections.

Petitioner’s information 

Thomas Petitti

1704 Edgewood Drive

Milford, IA 51351

712.330.6417

Petitti@duav.org

DUAV LLC,

U.S. Department of Transportation 

Docket Management System 1200 

New Jersey Ave, SE Washington, 

DC 20590 

Petition for Exemption of CFR 14:

45.23(a)&(b);61.113(a),(b),&(2);

91.7(a)&(b); 91.119(a),(b),&(c); 

91.151(a),(1),&(b); 91.405(a); 

91.407(a)&(1); 91.409(a),(1),&(2); 

91.417(a)&(b)
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Dear Sir or Madam,

Request for relief from an airworthiness certification requirements under the FAA 

Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333.

Section 14 CFR §45.23 Display of marks; general.

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman 

capital letter “N” (denoting United States registration) followed by the registration number of the 

aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. 

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

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

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

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The UAS aircraft, will be permanently marked in multiple places with contact information 

containing P.I.C & owner’s Name, Address, & Phone Number. In compliances with 14 CFR 

Section 45.29 (f), the UAS will also be marked with “Experimental” in as large as practical size 

of print on at least two surfaces. 

Section 14 CFR §61.113 Private pilot privileges and 

limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if: 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Although no souls will be aboard, the UAS operations will be planned with the same level of 

safety as a commercial operation, under the command of a private pilot, holding an up to date 

medical certificate and photo I.D. All operations will follow a Standard weather Briefing, a 

preflight check, and a run up. All flights will follow a predetermined route, and maneuvers within 

clear airspace. The level of risk associated with the operation of the UAS are so diminished form 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

the level of risk associated with commercial operations contemplated by part 61 when drafted, 

that allowing operations of the UAS as requested with a private pilot as the operator exceeds 

the present level of safety achieved by 14 CFR Section 61.113 (a) &(b).

Section 14 CFR §91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is 

in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. 

As there is no Airworthiness certificate issued for this aircraft, should this exemption be granted, 

no FAA regulatory standard will exist for determining the airworthiness. Given the size of the 

aircraft and the requirements contained in the manual of maintenance, and use of safety

checklists prior to each flight as set forth in Section B, and Section G, an equivalent level of 

safety will be provided. 

Section 14 CFR §91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than 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

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location of operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in 

the filming activity, attempts will be made to contact all affected individuals regarding the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 551bs. UAV limit Proposed herein, and the lack of flammable fuel, any 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

risk associated with these operations is far less than those presently presented with conventional 

aircraft. In addition, the low-altitude operations of the UAV will ensure separation between these 

UAS operations and the operations of conventional aircraft that must comply with Section 

91.119.

Section 14 CFR §91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a) (1) (i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight 

level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the 

appropriate number of feet specified below, according to the current reported altimeter setting:

The UAS does not operate by use of Barometric Altimeter but instead a digital GPS altitude read 

out for AGL. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight.

Section 14 CFR §91.151 Fuel requirements for flight in 

VFR conditions.

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

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

and, assuming normal cruising speed—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

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

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes. 

The battery(s) powering the UAS varying time from 8 minutes to 12 minutes per battery. In 15 

degree Celsius, low wind, VFR conditions flight will last approximately 12 minutes with all 

powered components functioning. Given the limitations on the UAS proposed flight area and the 

location of its proposed operations within a predetermined area, a longer time frame for flight in 

daylight VFR conditions is reasonable.

An equivalent level of safety can be achieved by limiting flights to have enough battery reserve 

to ensure the UAS lands at a safe ground station with at least 20% of battery power determining 

by onboard monitoring and by the pilot. A notice in a decline of power performance or the 20% 

reserve mark has been met enough time will be adequate to return the UAS to a safe landing 

station within the predetermining route. 

Section 14 CFR §91.405 Maintenance required.

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter;

Although this sections apply only to aircraft with an airworthiness certificate; route and preflight inspections and maintenance will be accomplished by the P.I.C and owner. An equivalent 

level of safety will be meet due to the lack of size and payload of the UAS, as well as operating 

in restricted areas for short limited periods of time in only VFR conditions will ensure extreme 

precaution and safety. 

Section 14 CFR §91.407 Operation after maintenance, 

preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter;

All preventive maintenance will be performed by a licensed private pilot and owner operator. 

Although there are no engines, electric motor and amplifier component, replacement will be 

done with equivalent safety as an aircraft power plant. Camera equipment alterations will also be 

done with equal caution concerning balance, power, and weight. Any major airframe work, or 

electrical (circuit board, reprograming, or calibrating) will be done by professional UAS 

builders.

Section 14 CFR §91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter.

All Inspections will be performed in the pre-flight check and run up check near initial take off 

for each battery. No commercial UAS operation will occur after any form of maintenance unless 

a test flight in a sparsely populated areas away from any person or property has been conducted 

involving every maneuver and all electrical components. 

Section 14 CFR §91.417 Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include—
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(IV) The current inspection status of the 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 of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required.

(VI) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a) (2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall 

be retained until the defects are repaired and the aircraft is approved for return to service. 

Equal level of safety and records in accordance with CFR 14 Section 91.405. All records will be 

included in a maintenance record folder as well as a designated log book. Including date of 

maintenance started and finished, name of qualified person or company who performs the 

maintenance, and type of maintenance performed on UAS.
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Public Summary

Pursuit to 14 CFR Part 11 the following summary is provided for the publication in the Federal 

Register, should it be determined that publication is needed. 

Applicant request an exemption from the following rules Code of Federal Regulations, Title 14, 

Chapter 1; Volumes 1 & 2:

45.23(a) & (b); 61.113(a), (b), & (2); 91.7(a) & (b); 

91.119(a), (b) & (c); 91.151(a), (1), & (b); 91.405(a);

91.407(a), & (1); 91.409(a), (1), & (2); 91.417(a) & (b)

Approval for exemptions allowing commercial operations of a UAS for aerial photography and 

videography intended for inspection and video reproductions in the following industries: Real 

Estate, Advertising, Environmental Research along with Water Quality and Shoreline Research, 

and Inspection of Wind Turbines, Bridges, or other large industrial buildings. Over open and 

moving waters, dangerous or hazardous places, and unreachable places by any other category of 

aircraft.

Intended to Reduce heavy lead based pollutants in the air and reduce risk of injury to pilots and 

passenger photographers. The limited size, weight, and distance of the UAS will also protect

people and property on the ground. Compared to tradition forms of aerial photography involving 

large engine powered aircraft at low altitudes, over populated condensed areas, making abrupt 

sharp maneuvers we’ve removed almost all negative aspects with this new and growing 

technology that we hope to promote and share with the public to build a positive image and make 

the airspace safer. 

In my small and growing community in the northwest Iowa’s great lakes; we bring in millions of 

tourist each year. In efforts to promote my community with new safer technology then 

traditionally done in the area. The UAS will be used to help nonprofit organization in the local 

area such as: Historic Arnolds Park Inc., Keep Okoboji Blue, and Iowa great lakes water safety 

council. All these organizations will benefit from the future use of a UAS. Allowing closer 

steadier footage, but also reducing noise greatly over natural wildlife refuges, parks, and forests 

that surround our lakes area. Reducing bird strike issues, and insuring other large wild life safety. 

Efforts to promote real estate sale and grow the local year round community. I hope to help local 

business advertise themselves with new footage that could never be achieved before. 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Privacy

All commercial UAS operations will be conducted over private and controlled access property 

with property owner’s prior consent knowledge with respect to any temporary flight restrictions. 

Only those who have giving prior consent and have agreed to be photographed or filmed and to 

be involved in the area of operation may be near the P.I.C., subject of filming, and along 

predetermined route of UAS. Any person or owner of property (public or private) ask to have 

images removed will be allowed. All compliances will be meet by any state or local privacy

laws.

Accident & Indecent Reporting

In the event of an accident or incident all insurance or damages will be covered by DUAV LLC. 

The PIC of the UAS shall file a report on board form 6120.1/2 within 10 days after an accident. 

A report of an incident for which immediate notification is required (830.5) shall be filed only 

when requested by an authorized representative of the board. 

Drug and Alcohol 

No person may act as PIC or separate spotter/crewmember of UAS/aircraft while having a .04 

percent by weight or more alcohol in the blood or if any alcoholic beverages have been 

consumed within the preceding 8 hours. No person my act as crewmember of UAS if using any

drug the affects the persons faculties in any way contrary to safety. Any operation or attempt to 

operation under either of these conditions is grounds for denial of application for a certificate, 

rating, or authorization issued under 14 CFR Part 91.

Conclusion

Satisfaction of the criteria provided in section 333 of the Reform Act of 2012 - size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operations within 

visual line of sight and national security - provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s UAS in photography 

and inspection industry pursuant to the Manual appended hereto.
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

Thank you for your time and consideration.

Sincerely,

Thomas J Petitti, Esq. PPL

DUAV LLC,

Flight Manual & Operating Procedures

Flight Restrictions

 No commercial operation will occur with a UAS gross weight exceeding 55 pounds.

 No UAS operation in any controlled airspace.

 All UAS operations will have a secondary spotter on location at all times.

 Complete logo book of flights time and safety track records 

 All UAS flight operations will never exceed 400’ AGL and will never lose visual contact 

with the PIC.

 All commercial operations will take place over private property with prior consent from 

property owner.

 All required permits and licenses will be obtained form the local county and state of the 

commercial UAS operation. 

 The UAS will not operate over densely populated areas.

 The UAS will not operate at airshows.

 The UAS will not operate over any open air assembly of people.

 The UAS will not operate within 5 nautical miles of any airport without prior notice and 

radio communication.

 UAS operations will be restricted to civil daylight hours and VFR weather conditions.

 The PIC will brief anyone involved with or near the UAS operation on proposed route 

and maneuvers for each flight, along with any possible risks in the operating area. 
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

 No flight will be conducted without a full pre-flight inspection by the PIC before each 

operation or change to weight and balance of the UAS. 

 UAS operations will never be conducted for the purpose of hunting, trapping, or spotting. 

Pre-Flight Checklist

 Test each battery with a voltmeter before powering UAS, and check batteries periodically 

in 5 minute intervals.

 Check all wiring for loss connections and any issues.

 Check propellers for any cracks or chips, assure leading edge of blades are smooth.

 Make sure all electric motors are clean and move freely.

 Assure all structural plastic appendages are strong and screwed fully.

UAS Start Up

 Power Devo7 transmitter and first person view system and insure full battery power.

 Power any addition gimbal and camera.

 Power DJI F550

 Wait for DJI F500 to connect with GPS, and find its home point

 Recalibrate DJI F500 compass if operating in a new location. 

UAS Run Up

 Check all flight controls make sure they are free and correct.

 Check all propellers with an optical tachometer from equal power distribution.

 Throttle 50% insure UAS is properly balanced while in air.

 Check flight controls while hovering and make sure controls are correct. 

UAS Shut Down

 Idle controls and propellers

 Unplug UAS
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

 Turn off camera and gimbal

 Turn off first person viewing system

 Turn off Devo 7 Transmitter

TO REGAIN CONTROL AFTER LOST RADIO 

CONTACT

1. Failsafe = ON

2. Throttle = 50%

3. Mode = ATTI

4. Failsafe = OFF

5. Mode = GPS

DeVention 7 Transmitter

If radio contact is not restored, the UA

will automatically continue at 60 ft.

above its last elevation before losing

contact toward its takeoff point, then

descend and land there autonomously
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org
DUAV

Okoboji, Iowa

712.330.6417

Petitti@duav.org

DJI F550 Rotorcraft

F550_User_Manual_

v1.9_en.pdf

Figure 1 DJI F550 Manual 

Click to Expand

Specifications

Frame

Diagonal Wheelbase 550mm

Frame Weight 478g

Takeoff Weight 1200g ~ 2400g

ESC

Current 30A OPTO

Signal Frequency 30Hz ~ 450Hz

Battery 3S ~ 4S LiPo

Motor

Stator size 22×12mm

KV 920rpm/V

Propeller 10 × 3.8in (@3S); (Optional 8 × 4.5in (@4S))