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United Aerial LLC

225 Albert Hart Drive 

Baton Rouge, LA 70808

September 24, 2015

tjacobsen@unitedaerial.com

U.S. Department of Transportation

Mr. Anthony R. Foxx 

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal 

Aviation Regulations from 14 C.F.R Part 21; 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 

14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a);; and 14 C.F.R. 91.417.

Dear Sir and or Madame:

In accordance to Section 333 of the FAA modernization and Reform Act of 2012 (the Reform 

Act), United Aerial, LLC (“UA”), equipped to inspect construction sites with Small Unmanned 

Aircraft Systems (“sUAS”) applies for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow commercial operation of its sUAS. United Aerial (“UA”) will 

only operate under such conditions, outlined herein or as may be established by the FAA as 

required by Section 333. 

Approval of exemptions for United Aerial will allow for commercial operations from their sUAS 

to scan and inspect controlled construction sites and other areas of interest to include farm areas. 

Our pilot(s) in command (PIC) will have a minimum of 1 year experience or 250 hours, 

whichever comes first, in order to fly our standard sUAS, DJI Phantom 2 vision plus. UA will 

provide an equivalent level of safety while operating their sUASs by conducting strict conditions 

outlined below, therefore a requested exemption should be granted for commercial operation The 

seven factors Congress directed the FAA to consider when approving Section 333 exemption 

petitions are as following, size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation with visual line of sight – each support our request. 

By using the lightweight UAS, DJI phantom 2 vision plus, UA will provide a safer alternative 

than today’s conventional operations conducted with helicopters and fixed wing aircrafts, 

weighing several thousand pounds and carrying hundreds of pounds of fuel and flight crew over 
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populated areas.. UA will only fly sUASs that are internally programmed to restrict flight near 

any airports, federal buildings or fly over 400 feet AGL, the dji phantom. 

In accordance to 14 C.F.R. 11.35, United Aerial requests confidential treatment for certain 

information provided with this request for exemption. In specific, United Aerial requests that 

information contained in its flight operations, which includes United Aerials operating 

procedures, not made public due to case sensitive client and project procedures. United Aerial 

also requests that any personal information not be made public to protect the identity of our 

workers and clients. 

A table of contents has been formed for your ease, which begins on page three. If we can help 

answer any questions of provide any additional information to assist your understanding or 

review of this document, please do not hesitate to contact us at 704-962-0210 or via email at 

t.jacobsen@unitedaerial.com

Thank you, 

Taylor Jacobsen 

COO of United Aerial LLC 

Clint Conroy

CEO of United Aerial LLC 
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Table of Contents

I. Publishable Summary .....................................................................................4

II. Petitioner’s Contact Information.........................................................................5

III. United Aerial LLC’s Operations.........................................................................5

a. The sUAS....................................................................................5

b. Flight Conditions ...........................................................................5

c. Flight Operations............................................................................6

d. Flight Procedure..............................................................................7

IV. Privacy ................................................................................................8

V. Aircraft and Equivalent Level of Safety ..........................................................9

VI. Public Interest and Safety...........................................................................9

VII. Regulations from Which Exemption is Requested .............................................10

A. 14 C.F.R. 21(h): Airworthiness Certificates.........................................................11

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, 

appliances, or component parts for return to service after maintenance, preventive maintenance, 

rebuilding, or alteration.....................................................................................11

C. 14 C.F.R.43.11 Content form and disposition of records for inspections conducted under parts 

91 and 125 and &* 135.411(a) (l) and 135.419 of this chapter 

Exhibit ...................................................................................................14-20
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Additional documents have been submitted to the FAA confidentially and it is requested 

that they be held confidential and not made available to the public to the extent that 

allowed by the governing regulations as provided to other petitioners who have made the 

same or similar confidentiality requests

I. Publishable Summary 

In accordance to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, if it is deemed necessary for public release: 

RE:Applicant seeks an exemption from the following rules: 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 

C.F.R.43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 

91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 

14 C.F.R. 91.119(b)(c); 14 C.F.R. 91.121; 14 C.F.R. 151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 

215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409; and to commercially 

operate a small unmanned aircraft system (sUAS) 

Approval of exemptions for United Aerial will allow for commercial operations from their sUAS 

to scan and inspect construction sites. Our pilot(s) in command (PIC) will have a minimum of 1 

year experience or 250 hours, whichever comes first, in order to fly our standard sUAS, DJI 

Phantom 2 vision plus. UA will provide an equivalent level of safety while operating their 

sUASs by conducting strict conditions outlined below, thus providing an equivalent level of 

safety, therefore a requested exemption should be granted for commercial operation The seven 

factors Congress directed the FAA to consider when approving Section 333 exemption petitions 

are as following, size, weight, speed, operational capability, proximity to airports, proximity to 

populated areas, and operation with visual line of sight – each support our request. By using the 

lightweight aircraft, DJI phantom 2 vision plus, UA will provide a safer alternative than today’s 

conventional operations conducted with helicopters and fixed wing aircrafts, weighing several 

thousand pounds and carrying hundreds of pounds of fuel and flight crew over populated areas.. 

UA will only fly sUASs that are internally programmed to restrict flight near any airports, 

federal buildings or fly over 400 feet AGL. 
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II. Petitioner’s Contact Information 

United Aerial, LLC 

225 Albert Hart Drive 

Baton Rouge, LA 70808

Tel: (704)-962-0210 – (832)-248 - 4661

Email: t.jacobsen@unitedaerial.com

III. United Aerial LLC’s Operations 

A. Our equipment (sUASs) 

The requested exemption will permit the operation of small, unmanned multirotor aircraft 

(“sUAS”), the DJI 2 vision plus (“DV2”) to be flown over controlled construction, when no 

workers or other persons are directly underneath or within its flight path. All bystanders will be 

wearing the following, but not limited to, hard hats, steel toe boots, brightly colored reflective 

vest, and safety goggles. 

1. The DJI 2 vision plus 

The DJI 2 vision plus is a small, unmanned aircraft, weighing no more than 3 pounds, 

carrying a small lithium ion battery and a camera, the DJI 14.1 MP HD camera. The aircraft 

can operate up to a speed of 22 mph. The FAA has previously granted Exemption No. 11138, 

allowing commercial flight of a DJI product. Exhibit 14m

The following specifications will be for the DJI Phantom 2 Vision plus V.1 + V.3: 

Frame: DJI Phantom 2 vision plus (“DV2”) – 1242 g = 2.73 (lbs.) (weight with battery and 

propellers) 

Dimensions: 12.5 x 8.1 x 17 inches

Flight Control System: This includes the main controller (MC),which receives the battery 

voltage, capacity, and current, the internal measurement unit (IMU),which receives telemetry

data (visible at the ground station), compass, GPS, and radio receiver

(Rx).

Transmitter: DJI phantom 2 Remote Control 

Receiver: Internal to DJI phantom 2 receiver 

Motor: 920 Kv, 12N, 14P configuration 
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Batteries: DJI 5200mAh Lipo Battery

Propeller: DJI self-tightening 9 inch propellers 

Data and Video Combined Link: HD Lightbridge Video Downlink 

Gimbal: DJI Phantom 2 Vision plus 

Camera: 14mp DJI phantom 2 vision plus 

Please Refer to Exhibits (BLANK BLANK) for further information about the DJI Phantom 2 

vision plus.

B. Flight Conditions 

UA will only fly their sUASs in Class G airspace clear of other aircraft and under 400 

feet above ground level (“AGL”), away from airport safety zones and under controlled 

conditions in a secured construction site. United Aerial will only operate its sUASs in Visual 

meteorological conditions (“VMC”): no less than 500 feet below and no less than 2,000 feet 

horizontally from a cloud or when visibility is at least 3 statute miles from the PIC. The flight 

crew will always make a safety risk assessment (“SRA”) of every operation, and will only

operate when it is determined no hazards to be present on site. 

UA will also be teaming up with Local Yokel Weather (“LYW”), an 8 year old weather data 

company, specifically focusing on micro climates meteorology. UA and LYW will be 

working together to build weather stations on site, if said site does not already possess one. 

This will allow for the most precise data collection for determining safe flight conditions for 

each mission. UA also plans to hand over any weather station data to any city officials who 

may benefit from its finding. UA will be also conducting a city data set on the annual wind 

and rain reports to create the most favorable flying scheduling, these findings will also be 

made public for sUAS pilots. 

UA will enter on site and fly a preplanned mission based on the progress of each project. UA 

will need to fly as many missions as it will take to produce an accurate scan of the project’s 

scope. Before any flight is performed, UA will perform a site analysis and test flight of each 

to ensure no restrictions are present, they will also be working with Flight Standards District 

Offices (FSDO). 

The flight crew, consisting of one Pilot in Command (PIC), one Visual Observers(s) (VOs) 

will act as visual property line posts, ensuring controlled flight paths and any hazardous 

materials in the way of the sUAS. United Aerial pilots will be required to run the pre-flight 

check list (“PFCL”), checking the following before each flight. Weather analysis, Air Traffic 

Control (“ATC”) approval, crane location, and notify the site of the launch. The flight crew 

will have each individual involved in the scanning of the site. To accurately scan the site, the 

sUAS will fly a grid like flight and capture downward facing images every 5 meters at a 

height of 50 meters or less. 
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C. Flight Operations 

Each member of the flight crew will be noticeable by their fluorescent blue vest and white 

hard hats and will have the ability to communicate to one another by any two way

communication device. The flight crew will inspect the construction site for any changes to 

the project, they will then perform the PFCL and then notify the site superintendent of the 

sUASs launch. They will act out these actions for every sUAS launch. The purpose of each 

sUAS flight will be to collect aerial images of the site with predetermined locations and 

flight plan; this flight mission will be repeated until the necessary images are captured. Each 

flight will be performed by a trained sUAS pilot, PIC and one visual observer. UA will have 

up to 3 hours to cancel a scheduled flight based on their weather report and project delays or 

setbacks.

A launch site will be established for each project and will have enough space for each flight 

member, any project related team members, and a landing zone, no less than 150 square feet. 

Once the home base has been established, and clearly marked, the flight crew will go through 

an extensive PFCL and confirm any safety zones. The flight crew will also program two 

safety zones into the DJI Phantom 2 vision plus, in the event of a failure of the flight plan and 

a bailout will be necessary. A bailout height will be set 200 feet high with a clear max of 400 

feet AGL. In the case of a bailout and the home base is unsafe for a landing, the PIC will 

direct the sUAS to any of the 3 designated safety zones. A bailout can be performed 

manually by the PIC or programmed to rise automatically to set height and travel 

horizontally till is over the designated safe zone, in which it will descend at a rate of 1 foot a 

second. 

Both DJI phantom vision plus (sUAS) will have updated “return to home” function in their 

flight controller. Exhibit 6 (Manual 27)

Once the home base has been cleared for launch the PIC will notify anyone on site of the 

flight by projecting in a loud voice or over a mega phone to their North, South, East and 

West, 

“taking off, taking off, taking off, taking off” 

Once upon take off the PIC will fly the approved mission. Each flight member and any 

bystander will be able to view the flight from our 23” display monitor at home base. If there 

are any flights over water, the sUAS will be equipped with flotation devices to ensure 

gathering of the sUAS in the case of a bailout. 

1. DJI phantom 2 vision plus Flight Procedure 
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To start the DJI Phantom 2 vision plus, United Aerial will follow the procedures set out by

the manufacturer, Exhibit (14-20 Manual). Before launch United Aerial will conduct a 

communications check with the transmitter and DJI phantom 2 vision plus. After the flight 

inspection has been completed and the DJI Phantom 2 vision plus has secured a home base, 

gps lock, the PIC will conduct the flight set out by the project. 

When flying the DJI Phantom 2 Vision 2 plus, the low battery failsafe is triggered when 

the DJI intelligent flight battery is depleted to a point that may affect the safe return of the 

aircraft. This threshold is automatically determined based on the current aircraft altitude and 

its distance from the home spot. For more information regarding this safety feature, please 

refer to exhibit. (20 M) Along with this automated feature the PIC will be flying the sUAS 

manually in VLOS. 

IV. Privacy 

There will be very little concern when it comes to any invasion of privacy, for each flight will 

only take place over approved construction sites for imaging and each flight will require the 

camera to be facing land features and structures. This will ensure that the sUAS will only be 

flying over (controlled privately owned construction sites) the designated locations, capturing 

only the necessary information, never engaging any public interest. 

V. Aircraft and Equivalent Level of Safety

United Aerial proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These Limitations provide for at 

least an equivalent or higher level of safety to operate under the current regulatory structure. 

These limitations and conditions to which United Aerial agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. UA will not operate a sUAS over the 55 lbs. limit. 

2. Flights will be operated with approved missions and will always be accompanied by an 

visual observer.

3. In flight, the DJI phantom 2 vision plus, the low battery failsafe is triggered when the 

DJI Intelligent Flight Battery is depleted and needs to return to home base. This 

percentage is determined by the aircraft's current altitude and distance from home base. 

For more information regarding this safety procedure, please refer to Exhibit___ (20 M) 

5. The sUAS will remain clear of any moving equipment such as, cranes, ground vehicles 

and any manned aerial vehicles.

6. Flights will be operated at an altitude of no more than 400 feet AGL.

7. Minimum crew for each operation will consist of the sUAS PIC and a visual observer.
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8. Prior to each day’s activity, the flight crew will run a 5 point inspection on their sUAS, 

then run through their Pre-Flight Check List to ensure the safest flight possible. 

9. The operator will obtain a FAA UAS Civil COA prior to conducting any operations 

under this grant of exemption.

10. The flight crew has gone through 150 flight cycles with the DJI phantom 2 vision 

plus, which comprises 250 hours of flight time. The flight crew will also spend a 

minimum of 25 hours a year training with the DJI phantom 2 vision plus, preparing them 

for any updates to the machine’s software.

12. The PIC, safety technician, and VOs will at all times be able to 2 way communicate 

through hands free headsets. 

13. Written and/or oral permission from the landowner's/authorized project managers of 

the land will be required before each flight. 

17. All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

18. Both DJI phantom 2 vision plus will have the capability to abort a flight in case of

unexpected obstacles or emergencies. Prior to each flight, two separate safety zones will 

be programmed into the sUAS autopilot, in the event that the home area is unsafe for an

emergency landing. (see exhibit 20M)

19. For both DJI phantom2 vision plus, if the sUAS and its radio controller disconnects 

during flight, the system’s failsafe protection will come to the rescue and the multirotor

will return to home and land automatically, rather than flying off uncontrollably or 

landing at an unknown location.

20. Approval of commercial flights as outlined in this petition presents no national 

security issue for each flight will be within visual line of sight and under 400 feet AGL 

and only flown over approved construction sites.

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 operation 

within visual line of sight and national security, provides more than enough justification for the 

grant of the requested exemptions allowing commercial operations of applicant’s sUAS in the 

construction industry In accordance to United Aerial’s rules of operation. 

VI. Public Interest and Safety
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By eliminating the current method of project tracking which is conducted by a helicopter 

operated by multiple crew members, weighing several thousand pounds and carrying 

hundreds of gallons of fuel, we could add a new level of safety for the city and site crew. 

Manned helicopter or fixed wing aircrafts pose many risks, the use of a sUAS weighing 

under 3 pounds and can take off from the site, eliminates any need for a manned aircraft 

flight over the city and their inhabitants. United Aerials sUAS use only Lithium batteries, 

eliminating the concerns of fuel and any concerns that may arise in the occurrence of a 

bailout. The DJI Phantom 2 vision plus can take off from a controlled home base of 150 sq. 

feet, eliminating the need for a runway. 

VII. Regulations from Which Exemption is requested 

A. 14 C.F.R 21(h): Airworthiness Certificates 

United Aerial LLC requests an exemption from 14 C.F.R 21(h), which “prescribes 

procedural requirements for the issue of airworthiness certificates.” 14 C.F.R. 21.171. 

Both DJI phantom 2 vision plus small size, weight and speed, and limiting operating area 

associated with the aircraft and their operation meet the statutory considerations of 

Section 333. 

Equivalent level of safety: United Aerial’s proposed exemption meets the requirements 

for an equivalent level of safety of this section, in accordance to section 333, based upon 

the following factors: 

● Small size: 

o DJI phantom 2 vision plus: 12.5 x 8.1 x 17 inches

● Light weight: 

o DJI phantom 2 vision plus: weighs no more than 3 pounds, including 

technical equipment and batteries

● Relatively slow speed:

o DJI phantom 2 vision plus: cannot travel any faster than 22 mph 

● Operational capacity

o DJI phantom 2 vision plus: the low battery failsafe is triggered when the 

DJI intelligent flight battery is depleted to a point that may affect the safe 

return of the aircraft.

● Proximity to airports: United Aerial will only operate outside of the specified safe 

distance from airports, and in G airspace, and will notify ATC and the local 

FSDO prior to operations, as described above. 

● Proximity to populated areas: United Aerial will be only flying over empty 

construction sites. 

● Operation within visual line of sight: the PIC will always fly the sUAS within his 

or her line of sight. 

● Altitude: United Aerial will never fly more than 400 feet AGL.
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● Restricted area in which the sUAS will be operated: as described previously in 

this petition, United Aerial will not fly outside of the approved construction zone. 

The sUAS will not exit the property line and each flight crew member will act as 

guide lines to ensure each flight is staying within the flight approval. Flights can 

easily be aborted if the PIC feels the site is unsafe for a sUAS in the air. 

B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines,

propellers, appliances, or component parts for return to service after maintenance,

preventive maintenance, rebuilding, or alteration.

United Aerial requests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, 

that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, 

airframe, aircraft engine, propeller, appliance, or component part for return to service.

The DJI phantom 2 vision plus, the requested exemption will provide an equivalent level of 

safety because United Aerial will repair and maintain the sUAS in accordance with the 

manufacturer’s directions and recommendations. 

D. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections 

conducted under parts 91 and 125 and §§135.411(a) (1) and 135.419 of this chapter.

United Aerial requests an exemption from 14 C.F.R. 43.11(b). This part provides, inter 

alia, for the listing of discrepancies and placards by inspectors. The sUAS, due to its small size, 

does not have room for placards to be placed in or on it and no inspections for sUAS have been 

certified by FAA at the present time.

Equivalent level of safety: United Aerial will achieve an equivalent level of safety by keeping 

log books on all maintenance and repair to the DJI phantom 2 vision plus. These log books will 

include information meant for the placards. This meets an equivalent level of safety to 14 C.F.R 

43.11 (b) because, as envisioned in the August 8, 2014 Memorandum, “Interpretation regarding 

whether certain required documents may be kept at an unmanned aircraft’s control station.” The 

flight crew will have access to these logs for every flight as well as make them public to each 

client if requested. 

E. 14 C.F.R. 45.27: location of mark; non fixed-wing aircraft 
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United Aerial requests an exemption from 14 C.F.R. 45.11. United Aerial requests an 

exemption from the 14 C.F.R 45.27. This part provides, inter alia. That each operator of a 

rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, 

boom, or tail the marks required by SS45.23. The DJI phantom 2 vision plus, due to its small 

size, does not have a cabin, fuselage, boom or tail to display marks required by SS 45.23. 

Equivalent level of safety: United Aerial will achieve an equivalent level of safety by keeping 

all manufacturers user manuals and log books for the DJI phantom 2 vision plus at the home 

base, and affix their N- numbers, once obtained the FAA Registration Office, as large as 

practicably possible. They will place the N-Numbers for the DJI phantom 2 vision plus on the 

“arms” or fuselage or the aircraft as large as practicably possible. The requested exemption 

provides an equivalent level of safety to 14 C.F.R.45.27 because the sUAS will be registered 

with the FAA Aircraft Registration Branch. In the unfortunate event of an incident, United Aerial 

will be traced by to the sUAS. 

F. C.F.R. 45.29: Size of Marks 

United Aerial requests an exemption from 14 C.F.R. 45.29. This part provides, inter alia, 

at subpart (3) that the registration marks for the rotorcraft must be at least 12 inches high. Such 

displays will be impracticable, due to the small size of the sUAS. 

Level of Equivalent level of safety: United Aerial will affix its registration number as large as 

practicably possible on the “arms” or fuselage of the DJI Phantom 2 vision plus. The requested 

exemption provides an equivalent level of safety to 14 C.F.R.45.29 because the sUAS will be 

registered with the FAA Aircraft Registration Branch. In the unfortunate event of an incident, 

United Aerial will be traced by to the sUAS. 

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

The FAA has previously stated that no exemption is required for this section in the MPAA 

Exemptions. Exhibit 1 at 19. United Aerial requests the same determination be made for this 

petition. 

Alternatively, United Aerial requests exemption from C.F.R. 91.7(a). The regulation 

requires that no person may operate a civil aircraft unless it is in airworthy condition. As there 

will be no airworthiness certificate issued for the aircraft should this exemption be granted, no 

standard will exist for determining airworthiness. 

Equivalent level of safety: United Aerial, at all times, will keep a flight log, maintenance 

and repair log, and the DJI phantom2 vision plus manufacturer manual at home base, where the 

PIC and VO have access, before, during and after operations. Thus, this exemption provides an 

equivalent level of safety to 14 C.F.R. 91.7(a) because the PIC, based on his flight experience 
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with the sUAS and documents available, will be able to determine as to the airworthy condition, 

in accordance with 14 C.F.R. 91(b)

H. 14. C.F.R. 91.9 (c): Civil aircraft flight manual, marking, and placard requirements. 

United Aerial requests exemption from 14 C.F.R 91.9(c). This part provides: “(c) No 

person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance 

with part 45 of this chapter. 

As stated above, United Aerial will submit AC Form 8050-1 to the FAA Registration Office in 

order to obtain its N-numbers, which will be placed on the “arms” of the fuselage of the aircraft 

in lettering as large as practicably possible. The sUAS, due to its small size, does not have the 

room to contain a fireproof placard or to display aircraft marks in a conventional size. Once 

obtained from the FAA, United Aerial will place its N-Numbers on the “arms” of the sUAS. 

Equivalent level of safety: Once obtained by the FAA, United Aerials will place the 

sUASs N-numbers on the “arms” of the aircraft as large as practically possible. An equivalent 

level of safety to 14 C.F.R. 91.9(c) is met because the 

will be registered with the FAA and identifiable in the event of an incident. 

14 C.F.R. 91.417.

As stated above, United Aerial will submit AC Form 8050-1 to the FAA Registration Office in 

order to obtain its N-numbers, which will be placed on the “arms” of the fuselage of the aircraft 

in lettering as large as practicably possible. The sUAS, due to its small size, does not have the 

room to contain a fireproof placard or to display aircraft marks in a conventional size. Once 

obtained from the FAA, United Aerial will place its N-Numbers on the “arms” of the sUAS. 

Equivalent level of safety: Once obtained by the FAA, United Aerials will place the 

sUASs N-numbers on the “arms” of the aircraft as large as practically possible. An equivalent 

level of safety to 14 C.F.R. 91.9(c) is met because the sUASs will be registered with the FAA 

and identifiable in the event of an incident. 

Thank you for taking the time to review our Exemption Request Section 333 of the FAA Reform 

Act of 2012 and Part 11 of the Federal Aviation Regulations. We believe we have surpassed the 

industry standard for flying sUASs, matched with one of the safest sites to fly a small UAS
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