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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590

March 9, 2016

RE:	Petition	for	Exemption	Pursuant	to Section	333	of	the	FAA	Modernization	and	

Reform	Act	of	2012 and	Part	11	of	the	Federal	Aviation	Regulations

Dear Sir or Madam:

Petitioner, 360 OnSite Security, LLC hereby petitions the Federal Aviation Administration 

(FAA) for an exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012.

Operator:

360 OnSite Security, LLC

P.O. Box 1531

Cypress, TX 77410-1531

Owner: James Hughes

Phone: 281-315-3660

Email: jim.hughes@360onsitesecurity.com

Specific	applicable	regulations	from	which	relief	is	required	(CFRs):

Petitioner, 360 OnSite Security, LLC is requesting relief from the following Federal Aviation 

Regulations (FARs) 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), 

91.417(a) and (b),
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to the extent necessary to allow 360 OnSite Security, LLC to commercially operate Unmanned 

Aerial Systems to perform aerial data collection and reporting with remote sensors and 

instrumentation aboard the UA for the proposed operations listed. 

You'll find that our request is similar to relief previously requested 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), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), 12645 

to Allied Drones (see Docket No. FAA-2014- 0804), 11433A to Cape Productions (see Docket 

No. FAA-2015-0223), and 15005 to Thomas R. Guilmette (see Docket No. FAA-2015-5829), 

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.

How	the	Operator	will	Maintain	an	Equivalent	Level	of	Safety or	NO	Adverse	Impact	

to	Safety:

360 OnSite Security, LLC will ensure that the exemption does not adversely affect safety and

will operate at a level of safety equal to existing regulations by operating with the following

limitations and conditions:

 All operations will strictly adhere to manufactures owners, operators and maintenance

manual.

 All maintenance will be conducted in accordance with manufacturers recommendations

and documented in the aircraft logbook

 Preflight operations will be conducted in accordance with the manufacturer's

recommendation and preflight checklist.

 All operations will be conducted during daylight hours.

 All operations will be conducted in uncontrolled airspace, unless specific permission is 

granted by the controlling agency

 All operations will occur below 400 feet AGL.

 All operations shall utilize a VO. The UA must be operated within the 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.

 Aircraft will remain within unaided visual line of sight (VLOS) of the PIC and visual 

observer (VO) to see and avoid other aircraft or objects aloft or on the ground.

 PICs will operate the UA not closer than 500 feet to any nonparticipating person without 

exception.

 All operation will be at speeds less than that recommended by the manufacturer, and at 

all times less than 87 knots.
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 All operations will be conducted in visual meteorological conditions (VMC) with 

visibility of at least three statute miles.

 All operations will be conducted with at least 500 feet below clouds and with a 

horizontal separation of at least 2000 feet.

 All PICs will be required to hold an Airline Transport Pilot, a Commercial Pilot, a 

Private Pilot, a Recreational Pilot, or a Sport Pilot certificate with a current FAA

Airman Medical Certificate or a valid U.S. driver’s license.

 Under all situations, the PIC is responsible for the safety of the operation. The PIC is 

also responsible for meeting all applicable conditions and limitations as prescribed in 

this exemption and ATO-issued COA, and operating in accordance with the operating 

documents.

 PICs will adhere to all flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 

 All operations will strictly adhere to FAA regulations with safety being the number one 

priority. 

 PIC qualifications: The PIC will be able to demonstrate the ability to safely operate the 

UAS in a manner consistent with how it will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles, and structures before operating non-training, proficiency, or 

experience-building flights under this exemption.

 PIC qualification flight hours and currency may be logged in a manner consistent with 

14 CFR § 61.51(b), however UAS pilots must not log this time in the same columns or 

categories as time accrued during manned flight. UAS flight time must not be recorded 

as part of total time.

 All training operations will be conducted during dedicated training sessions and may or 

may not be for compensation or hire.

 UAS that have 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. Functional test flights will 

only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people. The functional test flight will be conducted in such a manner so as to not pose an 

undue hazard to persons and property.

 For UAS operations where GPS signal is necessary to safely operate the UA, the PIC 

will immediately recover/land the UA upon loss of GPS signal. 

 If the PIC loses command or control link with the UA, the UA must follow a predetermined route to either reestablish link or immediately recover or land.

 The UAS, the UAS PIC, and the UAS operations will comply with all applicable parts 

of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

How	Granting	the	Exemption	would	be	in	the	Public	Interest:

The primary purpose of 360 OnSite Security, LLC is to use UAS to perform aerial data 

collection and reporting using the benefits of UAS which are safe and cost effective compared 

to using complex and expensive manned aircraft for the proposed operations listed. UAS allow

the completion of many tasks at a fraction of the cost of using traditional fixed and rotary wing 
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aircraft or other conventional manned aerial methods. Granting this exemption will enhance 

safety, lower costs, and improve the efficiency of operations. UAS greatly enhance efficiency

and achieve a high level of safety.

Proposed	Operations:

This request would permit 360 OnSite Security, LLC to research, develop, and commercially

operate UAS to conduct:

aerial data collection and reporting, 

aerial surveillance, 

aerial photography, 

aerial inspections, 

aerial surveys, 

aerial mapping, 

thermal imaging,

infrared imaging, 

training and education,

including inspection of utilities, transportation, and energy infrastructure, imaging for 

agriculture, real estate, events, search and rescue, and disaster response.

The owner/manager of 360 OnSite Security, LLC, James Hughes is an experienced airline pilot 

and airline pilot recruiter holding an Airline Transport Pilot Certificate and a current Flight 

Instructor Certificate. James Hughes, the Owner/Manager of 360 OnSite Security, LLC is also 

licensed by the Texas Department of Public Safety PSB as a video surveillance and video alarm 

company. James Hughes has a great amount of aviation knowledge and experience with FAA 

rules and regulations and with all aspects of flying and will serve the operations with the highest 

level of safety.

Make	and	Model	of	the	Aircraft	for	Proposed	Operations:

360 OnSite Security, LLC will conduct operations using UAS that have previously been 

approved by the Secretary of Transportation under Section 333 at regulatory docket FAA-2007-

3330 at www.regulations.gov. All operations will be conducted with aircraft weighing less than 

55 pounds including payload. Operations will not include foreign civil aircraft.

Make and model of aircraft for proposed operations include:

3D Robotics Iris

DJI Phantom 1

DJI Phantom 2

DJI Phantom 3

DJI Phantom 4

DJI Inspire 1
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DJI Inspire 2

Spreading Wings S900

Yuneec Typhoon H

Yuneec Tornado H920

Respectfully,

James Hughes

360 OnSite Security, LLC