September 2, 2015

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein 

referred to as FMRA) and 14 CFR Part 11, Optum Computing Solutions, Inc. (doing 

business as Optum Unmanned Aircraft Systems and herein referred to as “Optum 

UAS”) hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of Unmanned Aircraft Systems (UAS) for the 

acquisition of aerial data, so long as such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA.

As detailed in this document and the attached Appendix A, “Previously Approved UAS,” 

the requested exemption would permit the operation of UAS platforms previously 

approved by the FAA for commercial operations in the United States. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of Transportation’s 

responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) Reform Act.

Contact Information:

Optum Computing Solutions, Inc.

Steven E. Davis

President

12001 Coldstream Drive

Potomac, MD 20854

Tel: 301-943-7500

Email: sdavis.optum@gmail.com

List of Specific Regulations from 14 CFR which the Exemption is Requested:

• 14 CFR 21, Subpart H – Airworthiness Certificates

• 14 CFR 45.23 (b) – Display of marks; general

• 14 CFR 61.113 (a) & (b) – Private pilot privileges and limitations: Pilot in command

• 14 CFR 91.7 (a) – Civil aircraft airworthiness

• 14 CFR 91.9(b)(2) -Civil aircraft flight manual, marking, and placard requirements.

• 14 CFR 91.103 (b) (2) - Preflight action

FAA 333 Exemption - Optum UAS Page 1 of 17
• 14 CFR 91.105 - Flight crew members at stations

• 14 CFR 91.109 - Flight instruction; Simulated instrument flight and certain flight 

tests

• 14 CFR 91.119 (c) - Minimum safe altitudes: General

• 14 CFR 91.121 - Altimeter settings

• 14 CFR 91.151 - Fuel requirements for flights in VFR conditions

• 14 CFR 91.203(a) & (b): Civil aircraft: Certifications required

• 14 CFR 91.405 (a) - Maintenance required

• 14 CFR 91.407 (a) (1) - Operation after maintenance, preventive maintenance, 

rebuilding, or alteration

• 14 CFR 91.409 (a) (2) - Inspections

• 14 CFR 91.417 (a) and (b) - Maintenance records

AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This 

statutory authority includes exempting civil aircraft, as the term is defined under §40101 

of the Act, including UAS, from the requirement that all civil aircraft must have a current 

airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections §44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR 91.203(a)(1).

Section 333(b) of the Reform Act assists the Secretary in determining whether UAS may 

operate in the national airspace system without creating a hazard to the user, the public, 

or a threat to national security. In making this determination, the Secretary must 

consider:

• The UAS’ size, weight, speed and operational capability;

• Whether the UAS operates within the visual line of sight of the operator;

• Whether the UAS operates outside of highly populated areas and away from close 

proximity to airports.

Reform Act 333(a). If the Secretary determines that a UAS “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. 333(c).

OPTUM UAS BACKGROUND

With safety being our primary goal, Optum UAS provides services utilizing UAS to 

deliver cost-effective aerial images and data to clients. Optum UAS was created 

specifically to help clients avoid the capital costs and operations overhead of building 

their own UAS programs and to purchase UAS services in a way which better fits their 

needs and budgets. Optum UAS believes in a risk-based and technology agnostic 

approach to operations in the National Airspace System (NAS). Approval for any 

FAA 333 Exemption - Optum UAS Page 2 of 17
operation should be based on an analysis of the specific risks associated with the fully 

integrated solution, rather than the individual components.

Optum UAS is led by Mr. Steven E. Davis who has a Master’s Degree in Electrical 

Engineering from the Johns Hopkins Whiting School of Engineering. Mr. Davis currently 

holds a Private Pilot Certificate (since 1992) and has logged over 300 hours of flight 

time as Pilot in Command in single engine aircraft. He has been an aircraft owner and 

has scratch built and flown radio controlled models for many years. Flying and 

maintaining UAS’ has been a natural progression of his knowledge and skill-set.

UAS AND OPERATIONAL DESCRIPTION

Optum UAS seeks to commercially operate a variety of UAS weighing less than 55 

pounds including payload in the United States for the purpose of aerial imaging 

(photography and video), inspections, data collection, and UAS flight training. Appendix 

A, attached to this exemption petition, lists the aircraft that Optum UAS contemplates 

operating. In prior, similar exemptions, the Secretary has approved every UAS platform 

included in the Appendix A.

As the operator of these aircraft, Optum UAS is committed to the following conditions 

and limitations on its operations. Optum UAS understands that failure to comply will be 

grounds for the immediate suspension or rescission any exemption granted.

1. Operations are limited to the UAS listed in the Appendix A when weighing less 

than 55 pounds including payload.

2. Operations for the purpose of closed-set motion picture and television filming are 

not contemplated.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per 

hour). In no case will the aircraft be operated at airspeeds greater than the 

maximum aircraft operating airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above 

ground level (AGL). Altitude must be measured and reported in feet AGL.

5. The aircraft will be operated within visual line of sight (VLOS) of the Pilot in 

Command (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 U.S. driver’s license.

6. All operations will utilize a visual observer (VO). The aircraft will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times.

7. All operating documents needed to operate the UAS and will be accessible 

during UAS operations and made available to the Administrator upon request. 

FAA 333 Exemption - Optum UAS Page 3 of 17
The operator will also present updated and revised documents if it petitions for 

extension or amendment.

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) 

will undergo a functional test flight prior to conducting further operations.

9. Optum UAS 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 will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight.

11. Optum UAS will 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 will comply with all manufacturer 

safety bulletins.

13. The PIC will hold a UAS flight training certificate, in some cases training directly 

from the aircraft manufacturer, and 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.

14. Optum UAS will 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 to acquire aerial data, including evasive and emergency maneuvers, 

and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner 

consistent with 14 CFR § 61.51(b). Optum UAS will operate flights for the 

purposes of training Optum UAS PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC’s ability to safely operate the UAS.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. 

All operations will be conducted under visual meteorological conditions (VMC).

16. The aircraft will 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.

17. The aircraft will 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.

FAA 333 Exemption - Optum UAS Page 4 of 17
18. If the UAS loses communications or loses its GPS signal, the aircraft will return 

to a pre-determined location.

19. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power or fuel for the 

aircraft to conduct the intended operation and to operate after that for at least 

five minutes or with the reserve power or fuel recommended by the manufacturer 

if greater.

21. All operations shall be conducted in accordance with an ATO-issued COA if the 

blanket COA does not cover the intended operation.

22. All aircraft operated will 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 will be as large as 

practicable.

23. Documents used by Optum UAS to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating.

24. The aircraft will remain clear and give way to all manned aviation operations and 

activities at all times.

25. The UAS may be operated by the PIC from a moving device or vehicle; however, 

specific requests will be made via subsequent COA.

26. All flight operations will 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 aircraft or debris in the event of an accident; or 

b. The owner/controller/operator of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has 

made an assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard.

27. The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption.

28. All operations conducted over private or controlled-access property will be 

conducted with the permission from the property owner/controller or authorized 

FAA 333 Exemption - Optum UAS Page 5 of 17
representative. Permission from property owner/controller or authorized 

representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will 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.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness Certificates 

Subpart H, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203(a)(1). Given the size and limited operating area 

associated with the aircraft to be utilized by Optum UAS, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701(f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, 

speed, operational capability and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment and under 

the conditions proposed, will be at least as safe, or safer, than a conventional aircraft 

operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

14 CFR 45.23(b): Display of marks; general 

This regulation requires that certain experimental, provisionally certified aircraft, or lightsport category aircraft to be marked with letters between 2 inches and 6 inches high 

“limited”, “restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to 

a cabin, cockpit or pilot station. Even though the UAS will have no airworthiness 

certificate, an exemption may be needed as the UAS will have no entrance to the cabin, 

cockpit or pilot station on which the word “Experimental” can be placed. Given the size 

of the UAS, 2 inch lettering may or may not be impossible. Optum UAS will mark the 

UAS as practicable.

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

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

the UAS 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 have completed a UAS flight-training course. Unlike a conventional aircraft 

that carries the pilot and passengers, the UAS is remotely controlled. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in 

advance. The risks associated with the operation of the UAS are so diminished from the 

FAA 333 Exemption - Optum UAS Page 6 of 17
level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the UAS as requested exceeds the present level of 

safety achieved by 14 CFR 61.113(a) and (b).

14 CFR 91.7(a): Civil aircraft airworthiness

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 

Optum UAS contemplates operating, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft 

and the operational restrictions put on the aircraft, an equivalent level of safety will be 

provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 

The UAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is 

no room or capacity to carry such an item on the aircraft. The equivalent level of safety 

will be maintained by keeping the Operating Manuals at the ground control point where 

the pilot flying the UAS will have immediate access to it.

14 CFR 91.103 (b): Preflight action

This regulation requires each pilot in command take certain actions before flight to 

ensure the safety of flight. An exemption is needed from this requirement, as the pilot 

will take separate preflight actions, including checking for weather conditions, checking 

flight battery or fuel requirements, checking takeoff and landing distances, and all other 

actions in the Operating Manual and safety checklists. These actions will provide an 

equivalent level of safety.

14 CFR 91.105: Flight crew members at stations

This regulation requires certain actions by onboard crew members. Since all UAS are 

unmanned by definition, an exemption from this rule is requested.

14 CFR 91.109: Flight instruction; Simulated instrument flight and certain flight tests

Section 91.109 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. By design, UAS do not have fully functional dual controls. 

Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The equivalent level of safety is provided by the 

fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control 

the UAS via radio signals from the controller and by the size and speed of the aircraft.

FAA 333 Exemption - Optum UAS Page 7 of 17
14 CFR 91.119 (c): Minimum safe altitudes: General

Section 91.119 establishes safe altitudes for operation of civil aircraft. The UAS will 

never operate at altitude higher than 400 AGL and all operations will occur during 

daylight hours under Visual Meteorological Conditions (VMC) only. The equivalent level 

of safety will be achieved given the size, weight and speed of the UAS as well as the 

location where it is operated. No flight will be taken without the permission of the 

property owner. Because advance notice to the property owner and any onsite 

personnel, as well as the precautions outlined below, all affected individuals will be 

aware of the planned flight operations.

Flight operations will be conducted at least 500 feet from all non-participating persons 

(persons other than the pilot in command (PIC) or visual observer (VO)), vessels, 

vehicles and structures, unless operations do not present an undue hazard. The UAS 

will remain within visual line of sight of the PIC or VO. Flight operations will be 

conducted at least 5 miles from an airport. The PIC or VO will provide notification to the 

local Flight Standards District Office and airport controller of all operations within 5 miles 

of an airport. The FAA will have advance notice of all operations through the filing of 

notices-to-airmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the UAS 

proposed herein, any risk associated with our operations is far less than those presently 

presented with helicopters and other conventional aircraft operating at or below 500 feet 

AGL. In addition, the low-altitude operations of the UAS will ensure separation between 

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

Section 91.119.

14 CFR 91.121: Altimeter settings

This regulation requires each person operating the aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the PIC confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. 

Relief from this section is requested to the extent required to allow flights of a variety of 

UAS during daylight hours in visual flight rules (VFR) conditions to begin only if there is 

enough battery power to safely land with a 25% reserve power. Typical, flight operations 

will begin with fully charged batteries. The PIC will be required terminate the flight with a 

safe landing and at least a 25% energy reserve.

FAA 333 Exemption - Optum UAS Page 8 of 17
Furthermore, the FAA has stated that an equivalent level of safety is provided if the UAS 

flight is terminated with at least 25% reserve battery power still available. See Grant of 

Exemption to Astraeus Aerial, Docket No. FAA-2014-0352. 

14 CFR 91.203(a) & (b): Civil aircraft: Certifications required

The UAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. 

Therefore, there is no ability or place to carry certification and registration documents or 

to display them on the UAS. An equivalent level of safety will be achieved by keeping 

these documents at the ground control point where the pilot flying the UAS will have 

immediate access to them, to the extent they are applicable to the UAS. 

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance, Preventive 

Maintenance, and Alterations

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to Optum UAS. Maintenance will be 

accomplished pursuant to the manufacturers User Guide or Operating Manual. An 

equivalent level of safety will be achieved because these UASs are limited in size and 

will carry a small payload and operate only in restricted areas for limited periods of time. 

If mechanical issues arise, the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. The PIC will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance and keep a log of any maintenance 

performed. Moreover, the PIC is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of 

data enhances safety while reducing risk and saving energy. Manned aircraft in certain 

application such as pipeline monitoring create a greater risk because the aircraft are 

much larger and carry an onboard human pilot. In contrast, a UAS weighing 55 pounds 

or less will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. In addition, aerial data will allow commercial 

entities to make decisions about how to best deploy ground resources and ensure the 

safety and cost-effectiveness of their operations.

FAA 333 Exemption - Optum UAS Page 9 of 17
EQUIVALENT LEVEL OF SAFETY

Optum UAS proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current and proposed regulatory structure.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Images or video taken of individuals will have consented 

to being filmed or otherwise they will be made anonymous.

NATIONAL SECURITY

Given the small size of the UAS involved and the restricted environment within which 

they will operate, our petition presents no national security issue.

FEDERAL REGISTER SUMMARY

Petition for exemption

Docket No.: FAA-2015-_________________

Petitioner: Optum Computing Solutions, Inc. (doing business as, Optum UAS)

Seeking exemption from the following regulations: Part 21 and §§ 45.23(b), 61.113(a) 

and (b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and 

(b), 91.405(a), 407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal 

Regulations (14 CFR).

Description of Relief Sought: Optum UAS is seeking an exemption to conduct 

commercial acquisition of aerial data using unmanned aircraft systems. Based upon the 

foregoing, Optum UAS requests that the FAA grant it the necessary exemptions under 

Section 333 of the FAA Reform Act as requested herein to allow for commercial 

operations of UAS within the United States.

Sincerely,

// signed //

Steven E. Davis

President, 

Optum Computing Solutions, Inc.

FAA 333 Exemption - Optum UAS Page 10 of 17
Appendix A - Previously Approved UAS

This list represents UAS platforms previously approved by the FAA for commercial 

operations in the United States. Every UAS model listed has been throughly reviewed 

by Optum UAS.

Ref. # Manufacturer Model Reviewed

1 3D Robotics Aero-M YES

2 3D Robotics IRIS+ YES

3 3D Robotics X8+ YES

4 3D Robotics X8-M YES

5 3D Robotics Solo YES

6 3D Robotics Spektre YES

7 3D Robotics Y6 YES

8 Aerial Mob Heavy Lifter YES

9 Aerial Mob Light Lifter YES

10 Aerialtronics Altura Zenith ATX8 YES

11 AeroLogix GIS GeoStar UAV YES

12 Aeromao Aeromapper Talon YES

13 Aeromao Aeromapper 300 YES

14 Aeromao Aeromapper EV2 YES

15 AeroVironment Puma AE YES

16 AeroVironment Qube YES

17 AeroVironment Shrike YES

18 Aeronavics Limited Sky Jib X4 YES

19 Aeronavics Limited SkyJib 8 YES

20 Aeryon Labs, Inc. Aeryon SkyRanger YES

21 Aeryon Labs, Inc. Aeryon Scout YES

22 AgEagle, LLC AgEagle YES

23 AgPixel RoboFlight RF70 YES

24 AgriImage AgScout YES

25 AgriImage AgScout Mini YES

Ref. #

FAA 333 Exemption - Optum UAS Page 11 of 17
26 Agribotix Hornet YES

27 Agribotix Enduro YES

28 Aibotix Aibot X6 YES

29 AirCover Integrated Solutions QR425 YES

30 AirRobot GmbH & Co. KG AR100 YES

31 AirRobot GmbH & Co. KG AR180 YES

32 AirRobot GmbH & Co. KG AR200 YES

33 Align Corp. LTD M690L YES

34 Align Corp. LTD T-REX 700E YES

35 Align Corp. LTD T-REX 800E YES

36 Altavian Nova F6500 YES

37 Altavian Nova R8400 YES

38 Altus UAS Ltd. Altus X4 YES

39 Altus UAS Ltd. Delta X8 YES

40 American Drones, LLC Eagle YES

41 Arch Aerial OCTO YES

42 Arris M680 Hexa-coper YES

43 Analytical Methods, Stark 

Aerospace, Inc.

ArrowLite YES

44 Ascending Technologies AscTec Falcon 8 YES

45 Atlantic RC Aircraft Land Cruiser YES

46 BirdsEyeView Aerobotics FireFLY6 YES

47 Bormatec Maja UAV YES

48 C-Astral Aerospace, Ltd. Bramor gEO YES

49 CarbonCore Cortex ARTF YES

50 Cybertechnology CyberQuad YES

51 DJI Flame Wheel F450 YES

52 DJI Flame Wheel F550 YES

53 DJI Inspire 1 YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 12 of 17
54 DJI Inspire 2 (when available) YES

55 DJI Phantom 1 YES

56 DJI Phantom 2 YES

57 DJI Phantom 2 Vision YES

58 DJI Phantom 2 Vision+ YES

59 DJI Phantom 3 YES

60 DJI Phantom 3 Professional YES

61 DJI Phantom 3 Advanced YES

62 DJI Phantom FC40 YES

63 DJI Spreading Wings S900 YES

64 DJI Spreading Wings S1000 YES

65 DJI Spreading Wings S1000+ YES

66 DJI Spreading Wings S800 YES

67 DJI Spreading Wings S800 EVO YES

68 Draganflyer Guardian YES

69 Draganflyer X4-ES YES

70 Draganflyer X4-P YES

71 Draganflyer X6 YES

72 Drone America DAx8 YES

73 DYS (Dong Yang Model Technology 

Co., Ltd.

D800-X8 YES

74 DYS (Dong Yang Model Technology 

Co., Ltd.

F450 YES

75 E-Flite Apprentice YES

76 Event 38 E384 YES

77 TOP Engineering Group Co., Ltd. Falcon-V VTOL YES

78 Foxtech Kraken K130 V2 YES

79 FreeFly Systems ALTA RTF YES

80 FreeFly Systems CineStar 6 YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 13 of 17
81 FreeFly Systems CineStar 8 YES

82 FreeFly Systems CineStar X8 YES

83 FreeFly Systems CineStar 8 HL YES

84 GerMAP G180 YES

85 Gryphon Dynamics X8 YES

86 Haris H18 Octocopter YES

87 HexaCrafter Ltd. HC-1100 YES

88 HexaCrafter Ltd. HO-1250 YES

89 HobbyKing Bixler v1.1 YES

90 HobbyKing Bixler 2 YES

91 HoneyComb Corp. AgDrone YES

92 Horizon Hobby Blade 350 QX3 YES

93 Hoverfly Technologies, Inc. LiveSky YES

94 Hoverfly Technologies, Inc. BigSky YES

95 Hubsan X4 micro drone YES

96 Industrial Aerobotics SD02 YES

97 InovalDrone Inova One YES

98 Intuitive Aerial Aerigon YES

99 Kopterworx Hammer X12 YES

100 Latitude Engineering HQ-40 Hybrid Quadrotor YES

101 Leptron Avenger (unmanned 

helicopter)

YES

102 Leptron RDASS 1000 Quadcopter YES

103 Lockheed Martin Desert Hawk III YES

104 Lockheed Martin Indago YES

105 MicroDrones GmbH MD4-200 YES

106 MicroDrones GmbH MD4-1000 YES

107 Mikrokopter (HiSystems GmbH) ARF-OktoXL 6S12 YES

108 Martin UAV Super Bat YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 14 of 17
109 Parkzone Radian RTF YES

110 Parrot Bebop Drone YES

111 Finwing Penguin V2 YES

112 Precision Drone Pacesetter YES

113 PrecisionHawk Lancaster YES

114 Prioria Robotics Hex YES

115 Prioria Robotics Maveric UAS YES

116 Pulse Aerospace PA-01Vapor YES

117 Pulse Aerospace Pulse Vapor 35 YES

118 RCTimer Power Model Co., Ltd Hexacopter YES

119 Riegl RiCopter YES

120 RITEWING Z3 Spade 47” YES

121 RITEWING Spade 70” ARF YES

122 RITEWING Z4 Spade 52” YES

123 Rotomotion, LLC SR15 (SR20) YES

124 RangeVideo RV Jet YES

125 Readymade RC Universeye Penguin YES

126 SelectTech Geospacial EH-4 VTOL sUAS YES

127 SenseFly eBee YES

128 SenseFly eBee RTK YES

129 SenseFly eXom YES

130 Sensurion Magpie MP-1 YES

131 Service-Drone Multirotor G4 YES

132 SkyCatch, Inc. SkyCatch YES

133 Skywalker Technology Co., Ltd. X-8 Flying Wing YES

134 SteadiDrone Vader YES

135 SteadiDrone Mavrik YES

136 SteadiDrone Flare YES

137 Swift Radioplanes Lynx UAS YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 15 of 17
138 Tactical Robotics, Physical 

Sciences, Inc.

InstantEye Mk-2 YES

139 Tactical Robotics, Physical 

Sciences, Inc.

InstantEye Mk-2 Gen2 YES

140 Tarot 680PRO YES

141 Tarot T690 YES

142 Tarot T960 YES

143 Tarot T15 YES

144 Tarot T18 YES

145 Tarot T810 YES

146 Tayzu Robotics Titan X8 YES

147 Team Black Sheep TBS Discovery Pro YES

148 Topcon Sirius Pro YES

149 Trimble UX5 YES

150 Trimble UX5 hp YES

151 Trimble ZX5 YES

152 Turbo Ace Cinewing 6 YES

153 Turbo Ace Matrix-E YES

154 Turbo Ace Matrix-G YES

155 Turbo Ace Matrix-I YES

156 UAV Solutions Phoenix 30 YES

157 UAV Solutions Phoenix 60 YES

158 UAV Solutions Talon 120LE YES

159 Vangard Defence Industries ShadowHawk YES

160 Viking UAS X6 Model 800 S.A.R YES

161 Viking UAS Patriot X4 S.A.R YES

162 Viking UAS Ranger EX YES

163 Volt Aerial Robotics Octane YES

164 Vulcan UAV Mantis YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 16 of 17
165 Vulcan UAV Octo YES

166 Vulcan UAV Raven YES

167 Walkera TALI H500 YES

168 Walkera Scout X4 YES

169 X-CAM KongCopter X8 YES

170 XAircraft X650 and SuperX YES

171 xFold Cinema YES

172 Yamaha RMAX YES

Ref. # Manufacturer Model Reviewed

FAA 333 Exemption - Optum UAS Page 17 of 17