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UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM

1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Sailfish Films

FOR AN EXEMPTION SEEKING RELIEF FROM 

THE REQUIREMENTS OF THE FAA REFORM ACT AND 

PART 11 OF THE FEDERAL AVIATION REGULATIONS FROM

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a); 

91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted	on	March	4,	2016

Sailfish	Films

4754	NW	Red	Maple	Dr

Jensen	Beach,	FL	34956

steve@sailfishfilms.com

SFF’s Consultant

Gowdy	Brothers	Aerospace,	LLC

8170	Old	Carriage	Court	N.	Suite	#200

Shakopee,	MN	55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com
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Table of Contents

GLOSSARY	OF	ABBREVIATIONS...........................................................................................3

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER..............................................4

Executive	Summary .................................................................................................................4

Expeditious	Summary	Grant	Approval	Request......................................................................4

Commercial	(Mission,	Operation)	Purpose:........................................................................................5

Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:.............................................6

Regulations	from	which	the	Exemption	Relief	is	requested:.......................................................7

The	name	and	address	of	the	Petitioner: .............................................................................................7

Background...........................................................................................................................................7

Commitment	to	Safety..................................................................................................................................8

Expertise	&	Experience................................................................................................................................8

The	Exemption	Request .........................................................................................................9

Operator	Requirements ................................................................................................................ 11

Aircraft	and	Equivalent	Level	of	Safety.................................................................................... 14

Specific	Uses	Public	Benefits ....................................................................................................... 18

Equivalent	Level	of	Safety............................................................................................................. 19

14	C.F.R.	§	91.7(a):	Civil	aircraft	airworthiness..............................................................................20

14	C.F.R.	§91.119:	Minimum	safe	altitudes ......................................................................................21

14	C.F.R.	§91.121	Altimeter	Settings...................................................................................................21

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions ..............................22

14	C.F.R. §91.405	(a);	91.407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance	

Inspections.....................................................................................................................................................22

Federal	Register	Publication............................................................................................. 23

Privacy	and	National	Security........................................................................................... 23

Summary................................................................................................................................... 24

APPENDIX	A	- EXEMPTION	PATTERN....................................................................................... 26

APPENDIX	B	- TECHNICAL	MANUALS	AND	SPECIFICATIONS............................................ 27

APPENDIX	C	- COMMERCIAL	(MISSION/OPERATION)	PURPOSE	- FAA	PREVIOUS	

APPROVED	EXEMPTION	NUMBERS........................................................................................... 28

APPENDIX	D	- EQUIPMENT	- FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS.... 29

APPENDIX	E	- EXEMPTION	14	C.F.R	- FAA	PREVIOUS	APPROVED	EXEMPTION	

NUMBERS............................................................................................................................................ 30

APPENDIX	F	- MONTHLY	MAINTENANCE	AND	REPAIR	LOG............................................. 31

APPENDIX	G	– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATIONS	MANUAL	

VERSION	1.0....................................................................................................................................... 32
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GLOSSARY OF ABBREVIATIONS

AGL Above	Ground	Level

AOI Area	of	Interest

ATC Air	Traffic	Control

ATO Air	Traffic	Organization

AV Aerial	Vehicle

CFR Code	of	Federal	Regulations

COA Certificate	of	Authorization

FAA Federal	Aviation	Administration

FAR Federal	Aviation	Regulation

GCS Ground	Control	Station

GPS Global	Positioning	System

LOL Loss	of	Link

NAS National	Airspace	System

NOTAM Notice	To	Airman

PIC Pilot	In	Command

Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333

SO Safety	Observer

SOP Standard	Operating	Procedures

sUAS Small	Unmanned	Aircraft	System

sUAV Small	Unmanned	Aircraft	Vehicle

UA Unmanned	Aircraft

UAS Unmanned	Aircraft	System

UAV Unmanned	Aircraft	Vehicle

VFR Visual	Flight	Rules

VLOS Visual	Line	of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Take-Off	and	Landing
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INTRODUCTION AND INTERESTS OF THE PETITIONER

Dear	Sir	or	Madam:

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

“Reform	 Act”)	 and	 14	 C.F.R.	 Part	 11,	 Sailfish	 Films,	 (“SFF”)	 Operator	 of	 Small	

Unmanned	 Aircraft	 Systems	(“sUAS’s”)	 equipped	 to	 offer	 on-demand	 commercial	

UAS	 operations	 for	 a	 host	 of	 industries	 and	 applications and	 to	 perform	 the	

purposes	 listed	 below, hereby	 applies	 for	 an	 exemption	 from	 the	 listed	 Federal	

Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	its	sUAVs/UAS,	so	

long	 as	 such	 operations	 are	 conducted	 within	 and	 under	 the	 conditions	 outlined	

herein	or	as	may	be	established	by	the	FAA	in	an	exemption	granted	under	either	

Section	333	or Section	49	U.S.C.	§44701(f)	

As	 described	 more	 fully	 below,	 the	 requested	 exemption	 would	 permit	 the	

operation	 of	 a	 UAS	 under	 controlled	 conditions	 in	 airspace	 that	 is	 1)	 limited;	 2)	

predetermined;	and	3)	would	provide	safety	enhancements	in	the	fields	in	which	it	

will	 operate,	 which	 now	 depend	 upon	 conventional	 aircraft	 or	 humans	 climbing	

high	 on	 dangerous	 structures,	 walking	 in	 insect	 laden	 swamps,	 and	 working	

adjacent	to	treacherous	infrastructure. Approval	 of	this	 exemption	would	thereby	

enhance	 safety	 and	 fulfill	 the	 Secretary	 of	 Transportation’s	 (the	 FAA	

Administrator’s)	responsibilities	to	“... establish	requirements	for	the	safe	operation	

of	 such	 aircraft	 systems	 in	 the	 national	 airspace	 system.”	 Section	 333(c)	 of	 the	

Reform	Act.1

Executive Summary

Expeditious Summary Grant Approval Request

The	 petitioner	 requests	 the	 agency	 issue	 a	 summary	 grant	 process	 for	 this	

application.	Petitioner	has	provided	in	a	confidential	document	attachment	labeled	

as	petitioner	proprietary	information,	specific	exemption	numbers	whereby	the	FAA	

has	 already	 granted	 a	 previous	 exemption	 similar	 or	 identical	 to	 each	 and	 every	

request,	herein.	

For	the	FAA’s	benefit,	Petitioner’s	Consultant,	Gowdy	Brothers	Aerospace,	LLC,	has	

researched,	categorized	and	arranged	all	3,711	previously exemptions	granted	as	of	

																																																							

1		The	Company	or	Petitioner	listed	above	relies	upon	the	following	exemptions	

where	specific	reference	to	an	exemption	is	not	provided:	Exemptions	11062	thru	

11067,	11080,	11109	through	11112,	11114,	11213,	11062	and	as	recent	as	11857.
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March	3,	3016	into	a	usable	searchable	database,	based	upon	the	following	criteria:	

date	 submitted,	 date	 grant	 issued,	 time	 to	 petition	 grant,	 petitioner,	 petitioner’s	

state,	 exemption	 number,	 sUAV	 equipment	 type,	 grant	 purpose	

(mission/operation),	along	with	other	supporting	data.		

Petitioner	has	identified	previous	approved	exemptions for	each	of	the	Petitioners	

FAA	submission	requests:

 Commercial	(mission/operation)	purposes;

 Type	of	sUAVs	(UAS);

 Title	14	Exemptions (exemption	pattern	referenced	in	appendix	A)2

Commercial (Mission, Operation) Purpose: 

This	exemption	request, once	granted	would	allow	the	petitioner	to	operate	a	small	

unmanned	aerial	vehicle	(sUAV),	unmanned	aircraft	system	(UAS)	to	conduct	aerial	

data	collection,	search	and	rescue	operations,	motion	picture	production3 and	

closed	set	filming,	training.

Aerial	 Data	 Collection to	 include	 the	 following:	(1)	 bridge	 Inspections,	(2)	 flare	

stack	inspection,	(3)	utility-power	generation	system	inspections	and	patrolling,	

(4)	aerial	inspection,	(5)	photography	and	(6)	videography	of	residential	and	(7)	

commercial	 real	 estate,	(8)	 weddings,	(9)	 aerial	 inspection,	(10)	 photography	

and	(11)	videography	of	(12)	utility	infrastructure	including	but	not	limited	to	

(13)	 electrical	 power	 lines,	 (14)	 wind	 turbines	 and	 (15)	 cell	 towers,	 (16)	

pipeline	 inspection	 and	 (17)	 patrolling,	 (18)	 precision	 agriculture	 with	 one	

board	 sensors,	(19)	 liquid	 and	 solid	 agriculture	 applications,	(20)	wildlife	 and	

forestry	 monitoring,	 (21)	 mosquito	 and	 insect	 control, (22)	 aerial	 surveying,	

(23)	construction	site	inspection	and	(24)	monitoring,	(25)	public	entity	support	

operations,	(26)	Aerial	imaging	for	safety	monitoring	and	(27)	comparing	work	

efforts	and	completion	percentages,	(28)	 security	of	controlled	environment	of	

various	 sites,	(29)	Aerial	 Photography	 and	 video	 photography	 over	water	 and	

marina	for	boats	and	Yachts, (30)	surface	mining,	(31)	special	events:	including	

(32)	high schools,	(33)	colleges	and	universities,	(34)	professional	 sports,	(35)	

open	 air	 events	 and	 (36)	 state	 and	 county	 fairs,	 (37)	 research,	 (38)	 forensic	

analysis	of	traffic	patterns	(39)	Fire	and	arson	inspection,	(40)	risk	management	

																																																							

2 Petitioner	 submits	the	Appendix	 and	 Manuals	 marked	“CONFIDENTIAL,”	 as	they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

3 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as	

Appendix	G.
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and	(41)	geographical	information	systems,	(42)	LIDAR	applications,	(43)	aerial	

assessment,	 (44)	 independent	 contracting	 and	 sub-contracting	 activities,	 (45)	

disaster	and	(46)	catastrophe	events.

Search	 and	 Rescue	 Operations (SRO)	 to	 include	 the	 following:	 (47)	 SRO	

independent	 contracting	 services,	(48)	SRO	 activities	 under	 the	 authority	 and	

support	of	local	authority	officials,	(49)	SRO	first	responders,	including	but	not	

limited	to	Fire,	Police,	Forestry,	County	Sheriffs	department,	private,	(50)	SRO	

with	aerial	video	and	live video	feed.

Motion	Picture,	Television	and	Closed	Set	Filming to	include	the	following:	(51)	

filmmaking,	(52)	 cinematography,	and	(53)	videography, (54)	aerial	 video	and	

live	 video	 feed,	(55)	 aerial	 video	 and	 photography	 for	 public	 and	 private	 use	

including	television,	public	 events,	 and	(56)	 cinematography	live	feed	 and	 live	

newsgathering, (57)	motion	picture,	(58)	television	and	(59)	closed	set	filming.

Training to	 include	 the	 following:	 (60)	 training	 to	 persons	 individually	 or	 (61)	

belonging	 to	 both	 private	 and	 public	 organizations,	 (62)	 training to	 increase	

awareness	 and	 (63)	 training	 to	 improve	 safety	 for	 current	 and	 future	 UAS	

operations	within	the	NAS,	(64)	educational	and	degree	granting	programs	for	

colleges	and	universities,	(65)	training	in	conjunction	with	FAA	pilots	and	other	

sUAV	training	certifications.

Description of Type, Make and Models of sUAV/UAS Requested:

The	 petitioner	 is	 seeking	 an	 exemption	to	 commercially	 operate	 sUAV’s	 and	 may	

chose	from	any	or	all	of	the	following	990	sUAV	makes	and	models as	follows:

APPENDIX B – SUAV LIST AND TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	confidential	cover.

Each	 separately	 weighs	 55	 lbs.	 or	 less,	 with imaging	 payload	 and	 applicable	

equipment.

Equipment	operation	manuals	for	each	sUAV	maybe included	for	your	reference	and	

are	considered	confidential	information	for each	respective	company’s UAS	and	are	

affixed	separately	in	these	documents labeled Appendix.
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Regulations from which the Exemption Relief is requested:

14	C.F.R.	§	61.113	(a)	&	(b)

14	C.F.R.	§	61.133(a)

14	C.F.R.	§	91.7(a)

14	C.F.	R.§	91.119

14	C.F.R.	§	91.121

14	C.F.R.	§	91.151	(a)

14	C.F.R.	§	91.405	(a)

14	C.F.R.	§	407	(a)	(1)

14	C.F.R.	§	409	(a)	(2)

14	C.F.R.	§	417	(a)	&	(b)

See	Appendix	E

The name and address of the Petitioner:

Sailfish	Films

Attn:	Steve	North

4754	NW	Red	Maple	Dr

Jensen	Beach,	FL	34956

Please	direct	any	question	or	comment	regarding	this	petition	to	Petitioners	

Consultant:	Gowdy	Brothers	Aerospace,	LLC.	

8170	Old	Carriage	Court	N.,	Suite	#200

Shakopee,	MN	55379

www.GowdyBrothersAerospace.com

Info@GowdyBrothers.com

Background

The	 Petitioner, SFF is under	 Steve	 North’s	 direction.	 Steve	 North is	 a highly	

accomplished,	capable,	experienced	and	trusted	professional.

Steve	 North	 is	 an	 Emmy	 Award	 winning	 film-maker	 with	 over	 30	 years	 of	

experience.	He	is	currently	President	of	SailFish	Films.	In	addition	to	working	as	an	

independent,	he	has	been	a	full-time	employee	at	The	Coca-Cola	Company	and	Starz	

Entertainment	 where he	 directed	 numerous	 broadcast	 commercials,	 special	 TV	

events	 and	 promotions.	In	January,	 2016	Steve	was	the	DP	for	the	 newest	 Carrie	

Underwood	 tour	 video	 which	 was	 shot	 with	 (6)	 Sony	 a7s	 cameras	 with	 Video	

Devices	PIX-E5	4k	recorders.	The	video	is	currently	shown	every	night	on	her	new	

world	tour.
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Steve	has	extensive	RC	experience,	having	been	introduced	to	the	modeling	world	

by	his	father	when	he	was	young.	He	has	built	and	piloted	countless	RC	models	both	

gas	and	battery	powered.	Several	years	ago,	he began	to	venture	into	UAV	building.	

He	has	built	several	quad	and	hexa-copters.	He	has	also	purchased	several	DJI	offthe-shelf	 UAVs.	 Steve	 is	 a	 meticulous	 model	 aviator,	 keeps	 a	 detailed	 flight	 log	

maintains	 his	 aircraft	 at	 the	 highest	 level	 and	 always	 flies	 with	 the	 aide	 of	 an	

assistant	 spotter.	He	has	never	has	a	 crash	of	lost	a	drone.	He	is	also	an	expert	at	

programming	digital	camera	gimbals.

Commitment to Safety

As	part	of	its	commitment	to	safety	and	innovation,	SFF is	asking	for	this exemption	

in part,	to	reduce	the	risk	of	injury	to	its	employees	and	contractors	who	participate	

in	 the proposed	 activities	 the	 petitioner	 requests,	 including	 but	 not	 limited	 to	

damage	 to	 agriculture,	 natural	 habitat,	 buildings	 and	 other	 structures	 within	 the	

United States.	

Expertise & Experience

SFF and	Steve	 North, has professional experience	 as	 a	 trusted	 sUAV	 pilot and is

extremely	 qualified	 and	 is	 considered	 an	 up	 and	 coming	 subject	 matter	 expert	 in	

their	local area	for	UAS	of	all	types,	models	and	makes.	
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The Exemption Request

SFF proposes the	use	of	the	sUAVs	will	be	for capture	of	high	resolution	imagery	and	

video	 of	 residential	 or	 commercial	 applications	 and	 purposes	to	 a	 level	 of	 quality	

that	allows	the	Petitioner	to	use	the	imagery	to	identify,	record,	memorialize	events	

and	objects	according	to	the	purposes	noted.	

The	 imagery	 and	 video	 will	 be	 used	 to	 identify	 the	 condition	 of	 landscapes,	

agriculture,	events,	disasters	and	infrastructure	to	conduct	bridge	inspections,	flare	

stack	inspection,	utility-power	generation	system	inspections	and	patrolling,	aerial	

inspection,	photography	and	videography	of	residential	and	commercial	real	estate,	

weddings,	aerial	inspection,	photography	and	videography	of	utility	infrastructure	

including	 but	 not	 limited	to	 electrical	 power	 lines,	wind	turbines	 and	 cell	towers,	

pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	 videography,	

precision	 agriculture	with	 on	 board	 sensors,	wildlife	 and	forestry	monitoring and	

mosquito	 and	 insect	 control, aerial	 surveying,	 construction	 site	 inspection	 and	

monitoring,	public	entity	 support	operations,	aerial	imaging	for	 safety,	monitoring	

and	comparing	work	efforts	and	completion	percentages,	and	security	of	controlled	

environment	of	various	sites,	aerial	video	and	live	video	feed	to	assist	with	search	

and	 rescue	operations	under	the	authority	and	 support	of	local	authority	officials,	

aerial	video	and	photography	for	public	and	private	use	including	television,	public	

events,	 and	 cinematography	 live	feed	 and	 live	 newsgathering,	training	to	 persons	

individually	 or	 belonging	 to	 both	 private	 and	 public	 organizations	 to	 increase	

awareness	 and	 improve	 safety	 for	 current	 and	 future	 UAS	 operations	 within	 the	

NAS,	 special	 events:	 including	 high	 schools,	 colleges,	 professional	 sports,	 open	 air	

events	 and	 fairs research,	 risk	 management	 and	 assessment,	 motion	 picture	

production,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events	and	

other	aerial	activities	as	opportunities	are	presented.

The	 UAS	 will	 be	 operated	 by SFF and	 or	 contracting	 operators on	 occasion	 to	

capture	 high-resolution	 imagery/video	 of	 large	 structures	(wide	 and	tall)	 such	 as	

warehouses,	 high	 rise buildings,	 bridges,	 and	 construction	 sites,	 as	well	 as	“bird’s	

eye”	 views	 of	 fire	 and	 explosion sites and	 various	 other	 purposes	 as	 mentioned	

above. Given	the	small	size	of	the sUAVs	involved,	no	more	than	55 lbs.,	majority	of	

the	speed	of	operation	be	between	5-45	mph and	the	restricted	environment	within	

which	they	will	operate,	the	Petitioner falls squarely	within	that	zone	of	safety	(an	

equivalent	 level	 of	 safety)	 in which	 Congress	 envisioned that	 the	 FAA	 must,	 by	

exemption,	allow	commercial	operations	of	UASs	to	commence immediately.

This	exemption	application	is	submitted	to	fulfill	Congress’	express	goal	in	passing

Sections	 333(a)	 through	(c)	 of	 the	 Reform	 Act.	 This	 law	 directs	 the	 Secretary	 of	

Transportation to	 consider	 whether	 certain	 unmanned	 aircraft	 systems	 may	

operate	 safely	 in	 the	 national airspace	 system	 (NAS)	 before	 completion	 of	 the	

rulemaking	 required	 under	 Section	 332	 of	 the Reform	 Act.	 In	 making	 this	
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determination,	the	Secretary	is	 required	to	determine	which	types	of UASs	do	not	

create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national security	

in	light	of	the	following:

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

 Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and

 Operation	of	the	UAS	within	visual	line	of	sight	of	the	Operator.

Reform	Act	 §	 333	(a).	 Lastly,	 if	the	Secretary	 determines	that	 such	 vehicles	“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)	(emphasis	added).4

The	 Federal	 Aviation	 Act	 expressly	 grants	 the	 FAA	 the	 authority	 to	 issue	

exemptions.	This statutory	authority,	by	its	terms,	includes	exempting	civil	aircraft,	

as	the	term	 is	 defined	 under §40101	 of	the	Act: The	Administrator	 may	 grant	 an	

exemption	from	a	 requirement	of	a	 regulation prescribed	under	 subsection	(a)	or	

(b)	of	this	section	or	any of	sections 44702-44716	of	this	title	if	the	Administrator	

finds	the	 exemption	is	in	the public	interest. 49	U.S.C.	 §44701(f).	See	 also	49	USC	

§44711(a);	 49	 USC	 §44704;	 14	 CFR	 §91.203(a)(1) This	 authority	 to	 grant	

exemptions	reaches	such	issues	as	authorization	of	commercial operation	of	aircraft	

without	an	FAA	issued	pilot’s	license.

SFF in	 filing	this	 application	 is	 requesting	that	the	 FAA	 combine	the	 grant	 of the	

Section	 333	 exemption	 with	 a	 standard	 Certificate	 of	 Operation	 (COA)	 that	 will	

allow commercial	operations	of	its	SFF’s sUAV without	the	necessity	of	filing	for	a	

COA	for	each flight,	unless	such	flight	is	to	be	conducted	in	an	area	not	approved	in	

the	 exemption. Compliance	with	the	 conditions	 agreed	to	 herein	 and	that	 may	 be	

imposed	 by	 the	 FAA,	 as	 set forth	 in	 prior	 Section	 333	 exemptions,	 provide	 the	

separation	needed	from	other	aircraft.

In	addition,	given	that	all	operations	will	be	conducted	below	400	AGL	feet	and	no	

closer than	5	nautical	miles	of	the	geographic	center	of	an	airport	as	denoted	on	a	

current	 FAA published aeronautical	 chart,	 unless	 a	 letter	 of	 agreement	 with	 that	

airport’s	management	is obtained,	SFF requests	that	operations	over	congested	or	

densely	populated	areas	be allowed.	The	vast	majority	of	commercially	built sUAV’s	

have	GPS	geo-fencing	and will	operate	at	a	very	low	altitude,	within confined	areas,	

at	low	speed	and	weighs	no	more	than 55 lbs. Such	operations	will	only	be undertaken	with	the	 approval	 of	the	 land	 or	 home	 owner,	 as	 set	forth	 herein,	 and	will	

comply with	 the	 requirements	 that	 operations	 be	 no	 closer	 than	 500	 feet	 to	 the	

																																																							

5 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administrator	to	not	only	

process	applications	for	exemptions	under	section	333,	but	for	the	Administrator to	

craft	conditions	for	the	safe	operation	of	the	UAS,	if	it	should	be	determined	that	the	

conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for	approval.
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adjacent	building	unless the	land	owner	has	provided	permission,	and	the	Operator	

has	made	a	safety	assessment	of the	risk	from	such	operations.	

Operator Requirements

Given	the	sUAV proposed	by	SFF,	Operators	/	Pilot-in-Command	(PIC)	as	long	as	the	

FAA	requires	hold	at	minimum	a	sport pilot	license with	a	valid	US	drivers	license.	

SFF believes	 that	 1)	 the	 operator,	 instead	 of	 understanding	 how to	 operate	 an	

aircraft,	should	have	knowledge	and	experience	that	enables the	safe	operation	of	a	

small,	 remotely	 piloted	 sUAV	 should	 understand	 airspace	 restrictions and know	

how	 to	 ensure	 separation	 from	 other	 aircraft	 as	 well	 as	 non-participants	 and	

property;	2)	the sUAV has	built-in	technical	capabilities	that	limit	the	potential	for	

unsafe	operation	and 3)	there	are	other	security	screening	mechanisms	already	in	

existence	that	SFF will utilize	to	ensure	the	operators	are	acting	 consistently	with	

national	security	interests.	

Given	 the	 sUAV safety	 features	 outlined	 below,	 SFF proposes	 that	 its operations	

under	 this	 Exemption	 request	 should	 not	 be	 required	 to	 hold a	 commercial	 or	

private pilot	 certification.	 Instead,	 Operators	 should	 be	 required	 to: have	

successfully	completed,	at	a	minimum,	FAA	pilot	ground	instruction	and passed	the	

FAA	Pilot	written	examination	or	FAA-recognized	equivalents;	have completed	SFF’s

training	program	for	operation	of	the	UAS.

SFF notes	 that	 1)	 the	 FAA	 has	 found	 that	 safety factors	 permitted	 operation	 of	

sUAVs	by Operators	with	these	qualifications	in	the	case	of	operations	pursuant	to	

public	 COAs when	 the	 mandatory	 operating	 conditions	 specified	 above	 were	

present; and	 2)	 that	 the	 Notice of	 Proposed	 Rulemaking	 entitled	 Operation	 and	

Certification	of	Small	Unmanned	Aircraft Systems,	80	F.R.	9544	(February	23,	2015)	

(“NPRM”),	 does	 not	 require	 the	 operator	 to	 hold	 a pilot	 license	 or	 a	 third	 class	

medical.

Advanced	sUAVs have a	navigation	and	control	system	and	auto-pilot	that	allows it	

to execute	very	accurate	pre-programed	flights.	Many	flights	are	pre-programmed	

with	 GPS	 waypoint	 to	 establish	 perimeters	 beyond	 which	 the	 aircraft	 will	 not	

operate.	 Flights	 under	 auto-pilot	 are not	 directed	 by	 positive	 manual	 input,	 but	

through	pre-programmed	flight	parameters that	are executed	by	the	auto-pilot.	In	

the	 case	 of	 unplanned	 events,	 the	 Operator	 inputs	 preprogrammed evasive	

maneuvers	from	the	control	unit,	and	the	autopilot	executes	those maneuvers.	Preprogrammed	 Operator	 interventions	 include:	 initiation	 of	 holding	 at	 present

position;	 suspension	 of	 mission;	 fly	 back	to	 launch	 point;	 abort	 mission	 and	 land	

immediately; and	 emergency	 power	 cut	 off	 and	 land	(flight	 termination	 system).

Additional	 automated	 safety	 functions	 and	 safety	 enhancing	 features	 of	 the	

advanced	sUAVs may	include	the	following:
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1)	 Auto-pilot	 detection	 of	 lost	 GPS	 or	 of	 insufficient	 satellites	 initiates	 an	

immediate landing,	

2)	 Low	power	on	the	aircraft	triggers	escalating	alarms	at	GCS	at	35%	and	10%	

levels. Low	power	below 10%	triggers	an	immediate	landing,	

3)	 If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	hold	

position at	its	current	location	for	5	seconds	and	if	the	signal	is	not	restored,	

execute	a	return to	home	and	land,	

4)	 Redundant	“kill	switches”	that	enable	completely	shutting	the	aircraft	down	

in	flight	in the	event	of	a	loss	of	control	or	un-commanded	deviation	from	the	

flight	path,	

5)	 The	aircraft,	weighs less	than	55	lbs.,	fully	loaded,	

6)	 The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals,	

7)	The	aircraft	will	more	than	likely	operate	for	the	Purposes	at	no	more	than	30

mph (while	 imaging)	 nor above	 200	 feet	 above	 the	 structure	 (imaging	

altitude)	or	a	maximum	of	400	feet AGL.

See	 Federal	 Aviation	 Administration,	 Notice	 N-8900.227,	 Unmanned	 Aircraft	

Systems	 (UAS) Operational	 Approval,	 at	 20-21	 (July	 30,	 2013);	 As	 the	 FAA	 has	

determined	in	Exemptions	11062	thru	11067,11080	and	11110	(the “Exemptions”),	

in	 comparing	 the	 requirements	 for	 private	 pilot	 knowledge	 and	 the	 knowledge	

required	 for	 a	 commercial	 pilot,	 that	 knowledge	 associated	 with	 a	 private	 pilot	

license,	and therefore	private	pilot	ground	 school,	was	 sufficient	to	allow pilots	to	

operate	sUAVs under	those	exemptions.	

Based	 upon	that	 analysis,	SFF believes	 successful completion	 of	 FAA pilot	 ground	

school	 is	 a	 suitable predicate	 to	 operating	 the	 sUAV	 under	 this	 exemption. SFF

proposes	that	the	Operator	accumulate	required	sUAV flight	training hours	through	

the	operation	of	sUAVs	rather	than	flight	hours	in	conventional	aircraft.	Those hours	

are	more	relevant	to	the	operations	proposed	herein	than	hours	gained	in	obtaining	

a pilot’s	 certificate	 in	 conventional	 or	 rotor	 aircraft.	 Those	 aircraft	 are	 orders	 of	

magnitude heavier	 than	 the	 sUAS	 and	 carry	 not	 only	 the	 pilot	 himself,	 but	 also	

passengers	 and	 fuel,	 none of	 which	 is	 carried	 in	 the	 sUAS.	 These	 conventional	

aircraft	fly	 over	 all	 sorts	 of	 airspace	without the	 permission	 or	 knowledge	 of	the	

landowner.	

A	handheld	radio	controller	controls	the sUAV and	the	vehicle	is	operated	within	the	

line	of	 sight.	The	 requirements	of	Part	61.127 (commercial	flight	proficiency)	and	

§61.107	 (private	 flight	 proficiency),	 to	 the	 extent	 they	 are relevant	 to	 UAS	

operations,	 can	 be	 taught	 in	 the	 training	 proposed	 herein.	 As	 a	 review	 of	 the	

requirements	 of	 part	 61.127	 and	 107	 demonstrate,	 the	 issues	 presented	 as	 they	

relate	to	a	55-pound aircraft,	more	than	likely	operating	at	less	than	30	mph during	

filming	 operations	 as taught	 in ground	 school	 and	 in	 flight	 training	 with	 the	

particular	 UAS	 and	 not	 gained	 from	 accumulating flight	 hours	 in	 a	 fixed	 wing	 or	

rotorcraft	 gas	 or	 jet	A	powered	 aircraft	 completing	 cross	 country flights	 and	take	

offs	and	landings	at	controlled	and	uncontrolled	airports.
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As	to	 national security	 review	 of	 pilots,	 each	of	SFF’s pilots/operators	will	 obtain	

internally	provided	certified	training	(Ground	and	Practical)	from	SFF to	operate the	

sUAV.	This	review and	certification could	reasonably vet	the	Operators	against	any	

known	terrorist	or	no	fly	listings	that	are	relevant and	publically	available.

SFF additionally	 asks	that	the	 exemption	be	issued	without	the	 requirement	for	 a	

visual	observer.	As	set	forth	herein,	an	equivalent	level	of	safety	is	provided	by	the	

size, speed	 and	 control	 capabilities	 of	 the	 aircraft,	 as	 well	 as	 the	 operational	

procedures	that	will	be applicable	to	all	flight	hereunder.	These	obviate	the	need	for	

the	visual	observer.	

The	Operator will	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will	

walk	and	follow	the aircraft	around	the	inspection	area	so	that	while	it	is	flying	its	

pre-programed	and	at	times,	manual	flight	path,	the	UAS will	always	be	directly	in	

his	or	her	line	of	sight.	The	Operator	will	not	be	distracted	by	viewing the	pictures	

taken	during	the	flight.	Rather,	once	the	sUAV is	launched,	the	Operator’s	only duty	

will	be	to	watch	the	flight	of	the	UAS	over	the	 structure	and	intervene	to	address	

flight	path deviations	or	other	issues	that	arise	during	the	flight.	The	functions	that	

an	observer	performs where	the	aircraft	is	flown	at	long	distances	from	the	launch	

area	will	not	be	necessary	as	the Operator	will	always	have	the	aircraft	in	his	or	her	

direct	 sight.	 The	 observer	 also	 will	 not	 be necessary	 because	 the	 Operator	 will	

conduct	a	pre-flight	inspection	of	the	area,	will	and	if	needed,	 cordon	off the	area	

and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating.

SFF again	notes	that	the	NPRM	does	not	require	the	use	of	a	visual	observer.	Given	

the	clear	direction	in	Section	333	of	the	Reform	Act;	the	authority	contained	in	the

Federal	Aviation	Act,	as	amended;	the	strong	equivalent	level	of	safety	surrounding	

the proposed	 operations,	 and	 the	 significant	 public	 benefit,	 including	 enhanced	

safety,	reduction in environmental	impacts,	including	reduced	emissions	associated	

with	allowing	battery	powered sUAVs	for	these	functions	instead	of	turbine	or	gas	

power	aircraft/rotorcraft	and	operations	with pilots	having	at	least	a	pilot	license,	

the	grant	of	the	requested	exemptions	is	in	the public	interest.	5

																																																							

5 Should	the	FAA	determine	that	it	cannot	grant	such	an	exemption	for	operations

without	a	FAA	licensed	pilot,	despite	the	showing	made	herein,	under	the	statutory	

authority	the	FAA	already	has,	the	Company	or	Petitioner	listed	above	will	operate	

its	aircraft	with	pilots	holding	at	least	a	sport	pilot	certificate	issued	by	the	FAA.	In

that	event,	the	Company	or	Petitioner	requests	that	the	exemption	be	granted	with	

conditions	similar	to	those	contained	in	numbered	paragraphs	14-15	in	Exemption	

11136
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Aircraft and Equivalent Level of Safety

The	Petitioner 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	even	higher	level	of	safety	to	

operations	under	the	current regulatory	structure	because	the	proposed	operations	

represent	 a	 safety	 enhancement	 to	 the operations	 conducted	 with	 conventional	

aircraft	 or	with	 humans	 climbing	 up	 and	 around structures.	These	 conditions	 are	

drawn	 from	 Exemptions	 11136,	 11138,	 11172,	 11174	 and 11177,	 11062,	 11109,	

11112,	and	11213 and	as	recent	as	11857.

These	limitations	and	conditions	to	which	SFF (referred	to	as	“Operator”)	agrees	to	

be	bound	when	conducting	commercial	operations	under	an	FAA	issued	exemption

include:

1) Operations	authorized	by	this	grant	of	exemption	are	limited	to	

the	over	990	aircraft	described	in	the	petition	herein,	which	is	a	

multi-rotor weighing	 up to	 55 pounds. Proposed	 operations	 of	

any	other	aircraft	note	listed	herein,	will require	a	new	petition	

or	a	petition	to	amend	this	grant.

2) The	UA	may	not	be	flown	at	an	indicated	airspeed	exceeding	100

mph (10-45 mph during	most	purposes).

3) The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	

above	 ground level	 (AGL),	 as	 indicated	 by	 the	 procedures	

specified	in	the	Operator’s	manual. All	altitudes	reported	to	ATC	

must	be	in	feet	AGL.

4) The	UA	must	be	operated	within	visual	line	of	sight (VLOS)	of	the	

Aircraft Operator	at	all	times.	This	requires	the	Aircraft	Operator	

to	be	able	to	use	human vision	unaided	by	any	device	other	than	

corrective	 lenses,	 unless	 the	 FAA	 authorized	 the	 use	 of	 First	

Person	Visual	(FPV)	devises

5) The	Exemption	Holder’s	Operation	Manuals	must	be	amended	to	

include	all	 conditions	and limitations	 required	by	the	FAA.	The	

Manuals	 must	 be	 maintained	 and	 made available	 to	 the	

Administrator	upon	request.	If	a	discrepancy	exists	between	the

conditions	and	limitations	in	the	exemption	and	the	procedures	

outlined	 in	 the Exemption	 Holder’s	 Operator’s	 manual,	 the	

conditions	and	limitations	in	the exemption	take	precedence	and	

must	be	followed.	Otherwise,	the	Aircraft Operator	must	follow	

the	 procedures	 as	 outlined	 in	 its	 Aircraft’s	 manual. The	

Exemption	 Holder	 may	 update	 or	 revise	 its	 Manuals.	 It	 is	 the	

Exemption Holder’s	 responsibility	 to	 track	 such	 revisions	 and	
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present	 updated	 and	 revised documents	 to	 the	 Administrator	

upon	request.	The	Exemption	Holder	must	also present	updated	

and	 revised	 documents	 if	 it	 petitions	 for	 an	 extension	 or

amendment	 of	 this	 exemption.	 If	 the	 Exemption	 Holder	

determines	 that	 any update	 or	 revision	 would	 affect	 the	 basis	

upon	which	the	FAA	granted	this exemption,	then	the	Exemption	

Holder	must	petition	for	amendment	to	its exemption.

6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the	UAS	to	

ensure	it	is	in	a condition	for	safe	flight.	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.	The	Ground	Control	Station	must	be	included	in	the	

preflight inspection.	 All	 maintenance	 and	 alterations	 must	 be	

properly	documented	in	the aircraft	records.

7) 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	in	accordance	with	the	Exemption	Holder’s

Manuals.	The	Aircraft	Operator	who	conducts	the	functional	test	

flight	 must	 make an	 entry	 in	 the	 UAS	 aircraft	 records	 of	 the	

flight.	 The	 requirements	 and procedures	 for	 a	 functional	 test	

flight	and	aircraft	record	entry	must	be	added	to the	Exemption	

Holder’s	Operator’s	manual.

8) The	 Exemption	 Holder	 must	 follow	 the	 manufacturer’s	 UAS	

aircraft/component, maintenance,	 overhaul,	 replacement,	

inspection,	and	life	limit	requirements,	with particular	attention	

to	 flight	 critical	 components	that	 may	 not	 be	 addressed	 in	the

manufacturer’s	manuals.

9) The	 Exemption	 Holder	 must	 carry	 out	 its	 maintenance,	

inspections,	 and	 record keeping	 requirements	 in	 accordance	

with	 the	 Operator’s	 Manuals.	 Maintenance, inspection,	 and	

alterations	must	be	noted	in	the	aircraft	logbook,	including	total

flight	hours,	description	of	work	accomplished,	and	the	signature	

of	the authorized	technician	returning	the	UAS	to	service.

10) The	authorized	technicians	must	receive	and	document	training	

referenced	in	the Exemption	Holder’s	Manuals.

11) Each	UAS	operated	under	this	exemption	must	 comply	with	all	

manufacturer System	and	Safety	Bulletins.
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12) The	 Exemption	 Holder’s	 maintenance	 personnel	 must	 make	 a	

record	entry	in	the UAS	logbook	or	equivalent	document	of	the	

corrective	 action	 taken	 against discrepancies	 discovered	

between	inspections.

13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have	

logged	at	least 25	hours	of	total	time	as	a	UA	rotorcraft	pilot	and	

at	least	ten	hours	logged	as	a UA	pilot	with	a	similar	UA	type	and	

5	hours	in	the	make	and	model.

14) 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 and	 land	 or	 be	 recovered	 in	

accordance	with	the	Exemption	Holder’s	Manuals.

15) The	 Aircraft	 Operator	 must	 abort	 the	 flight	 in	 the	 event	 of	

unpredicted	 obstacles or	 emergencies,	 including	 unauthorized	

people	 entering	 the	 flight	 area,	 in accordance	 with	 the	

Exemption	Holder’s	Manuals.

16) The	Aircraft	Operator	is	prohibited	from	beginning a	UAS	flight	

unless (considering	wind	and	forecast	weather	conditions)	there	

is	enough	power	to	fly to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed,	to	fly after	that	for	at	least	10	

minutes.

17) All	aircraft	operated	in	accordance	with	the	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.

18) Before	 conducting	 operations,	 the	 radio	 frequency	 spectrum	

used	for operation	and	control	of	the	UA	must	comply	with	the	

Federal Communications	 Commission	 (FCC)	 or	 other	

appropriate	government oversight	agency	requirements.

19) The	documents	required	under	14	CFR	91.9	and	91.203	must	be	

available	 to the	 Operator	 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.	

20) The	UA	must	remain	clear	and	yield	the	right	of	way	to	all	other	

manned operations	and	activities	at	all	times	(including,	but	not	

limited	 to,	 ultra-light vehicles,	 parachute	 activities,	 parasailing	

activities,	hang	gliders,	etc.).
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21) The	UA	may	not	be	operated	by	the	Aircraft	Operator	from	any	

moving	device	or vehicle.

22) UAS	operations	may	not	be	conducted	during	night,	as	defined	in	

14	CFR	1.1.

23) All	 operations	 must	 be	 conducted	 under	 visual	 meteorological	

conditions	(VMC). 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 Operator.

24) During	 operations	 the	 UA	 may	 not	 operate	 within	 5	 nautical	

miles	 of	 the geographic	 center	 of	 an	 airport	 as	 denoted	 on	 a	

current	 FAA-published aeronautical	 chart	 unless	 a	 letter	 of	

agreement	with	that	airport’s	management	is obtained,	and	the	

operation	 is	 conducted	 in	 accordance	 with	 a	 NOTAM,	 if	 as

required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the	

airport management	 must	 be	 made	 available	 to	 the	

Administrator	upon	request.

25) The	 UA	 may	 not	 be	 operated	 over	 congested	 or	 densely	

populated	areas	unless the	conditions	set	for	in	#26	are	satisfied.	

These	populated	areas	include	but are	not	limited	to	the	yellow	

areas	 depicted	 on	 World	 Aeronautical	 Charts (WAC),	Sectional	

Aeronautical	Charts	(Sectionals),	or	Terminal	Area	Charts (TAC).	

However,	 aeronautical	 charts	 may	 not	 reflect	 pertinent	 local	

information. Ultimately,	 it	 is	 the	 Operator’s	 responsibility	 to	

maintain	the	 minimum	 safe altitudes	 required	 by	 §	 91.119	(d)	

(1). Unless	the	UAV	 is	 operated	 for	 motion	 picture,	television	

and	closed	 set	filming	then	upon	 safety	precautions	outlined	in	

the	MPTFOM	flight	closer	than	500	feet	from	a	nonparticipating	

vessel,	structure	or	person	may	be	permitted.

26) 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	 debris	 in	 the	 event	 of	 an	

accident.	 The Aircraft	 Operator	 must	 ensure	 that	

nonparticipating	persons	remain under	such	protection.	If	a	

situation	arises	where	nonparticipating persons	leave	such	

protection	 and	 are	 within	 30	 feet	 of	 the	 UA,	 flight

operations	must	cease	immediately	and/or;

b. The	aircraft	is	operated	near	vessels,	vehicles	or	structures	

where the	 land	 owner/controller	 has	 granted	 permission	
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and/or	the	Aircraft	Operator	has	made	a	safety	assessment	

of	the	risk	of operating	closer	to	those	objects	and;

c. Operations	 near	 the	 Aircraft	 Operator	 do	 not	 present	 an	

undue	hazard to	the	Operator	per	§	91.119(a).

d. Unless	 the	 UAV	 is	 operated	 for	 motion	 picture,	 television	

and	 closed	 set	 filming	 then	 upon	 safety	 precautions	

outlined	in	the	MPTFOM	flight	closer	than	500	feet	from	a	

nonparticipating	 vessel, structure	 or	 person	 may	 be	

permitted.

27) All	 operations	 shall	 be	 conducted	 over	 private	 or	 controlledaccess	property with	permission	from	the	land	owner/controller	

or	 authorized	 representative. Permission	 from	 land	

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.

Specific Uses Public Benefits

SFF proposes	use	of	its	sUAV provided	equivalent	or	augmented	levels	of safety	for	

each	of	the	uses	proposed	herein:

The	 present	 systems	 of	 photography	 and	 videography	 and	 mapping	 of	 inspecting	

the	 roofs,	 agriculture	 land,	 buildings	 and	 large structures	 site	 surveys,	 wild	 life	

monitoring,	 mosquito	 and	 insect	 control	 are	 now	 conducted	 by	 either	 a	 person

wading	through	 swamps,	 climbing	on	the	 roofs and	 structures	that	are	 steep,	tall,	

slippery,	weakened	or	otherwise	hazardous	or	by	the	use	of conventional	aircraft.	

The	 current	 procedures	 can	 result	 in	 significant	 injuries	to	 the	 people	 who must	

climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude	greater	

in	 size than	 the	 sUAV.	 Either	 method,	 manual	 inspection	 or	 large	 conventional	

aircraft,	 results	 in increased	 risk	 of	 injury	 due	 to	 personnel	 falling	 off	 roofs	 or	

ladders,	carrying	heavy	ladders	and dealing	with	confined	and	dangerous	spaces,	or	

increased	 risk	 from	 low	 altitude	 flyovers	 with helicopters	 or	 fixed	 wing	 aircraft	

inspecting	 buildings	 after	 damage	 from	 storms	 or	 other disasters,	 such	 as	
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earthquakes	or	fires.	Such	flights	are,	of	 course,	 significantly	more expensive	than	

those	undertaken	with	a	sUAV.	

The	present	system	exposes	those	not	only	in the	immediate	area	of	inspection,	but	

those	who	are	along	the	path	of	flight	associated	with	the arrival	and	departure	of	

the	conventional	aircraft	at	the	inspection	site	because	the	aircraft	must be	flown	to	

and	from the	site.	By	contrast,	the	sUAV is	carried	to	the	site	and	transits no	other

property.	 Conventional	 aircraft	 carry	 flammable	 fuels	 that	 are	 not	 carried	 by	 the	

UAS	 and	 emit pollutants	 associated	with	 internal	 combustion	 engines.	 The	 sUAVs	

proposed	herein	are battery	powered	and	have	no	emissions.

Equivalent Level of Safety

14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and	Limitations;	Pilot	in	

Command;

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

conventional aircraft	that	 carries	 a	pilot,	passengers,	 and	 cargo,	the	SFF’s sUAV is	

remotely	 controlled	 with no	 passengers	 or	 property	 of	 others	 on	 board.	 Section	

61.133(a)	 requires	 an	 individual	 with	 a commercial	 pilot’s	 license	 to	 be	 pilot	 in	

command	of	an	aircraft	for	compensation	or	hire.	

SFF respectfully	proposes	that Operator	requirements	should	take	into	account	the

characteristics	 of	 the	 particular	 UAS.	 SFF’s sUAV has	 a	 high	 degree	 of	 preprogrammed control	and	various	built-in	technical	capabilities	that	strictly	limit	the	

potential	 for	 operation outside	 of	 the	 operating	 conditions	 set	 forth	 in	 the	

exemption	 application. The	 SFF’s sUAV has	 navigation	 and	 control	 system	

comprised	of	a	Ground	Control	Station (GCS)	and	auto-pilot	system	that	can	be	preprogrammed	to	set	operational	boundaries.	Many	flights	are	pre-programmed	with	

precision	GPS	 guidance.	In	the	 case	 of	 unplanned	 events,	the	Operator	 may	 input	

pre-programmed evasive	 maneuvers	 from	 the	 control	 unit,	 and	 the	 onboard	

autopilot	 executes	 those	 maneuvers. Pre-programmed	 Operator	 interventions	

include	initiation of	holding	at	present	position; suspension	of	mission;	fly	back	to	

launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and	

land	(Flight	Termination	System).

Additional	 automated	 safety	 functions	 and	 safety	 enhancing	 features	 of the	SFF’s

sUAVs may	include	the following:

1.1.	Auto-pilot	detection	of	lost	GPS	or	of	insufficient	 satellites	initiates	an	

immediate landing.

1.2.	Low	power	on	the	aircraft	triggers	escalating	alarms	at	GCS	at	35%	and	

10%	levels.	Low	power	below 10%	triggers	an	immediate	landing.
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1.3.	If	the	auto-pilot	detects	a	lost-link	to	the	ground	controller,	the	UAS	will	

hold	position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not	

restored, execute	a	return	to	home	and	land.

1.4.	Redundant	“kill	 switches”	that	 enable	 completely	 shutting	the	 aircraft	

down	 in	 flight	 in	 the	 event	 of	 a	 loss	 of	 control	 or	 un-commanded	

deviation	from	the	flight	path.

1.5.	The	aircraft,	weighs	less	than	55	lbs.,	fully	loaded.

1.6.	 The	 motors	 are	 driven	 by	 pulse	 width	 modulated	 signals,	 not	 analog	

signals.

1.7.	 The	 aircraft	 will	 operate	 for	 the	 Purposes at	 no	 more	 than	 30 mph

(while	 imaging) nor	 above	 200	 feet	 above	 the	 structure	 (imaging	

altitude)	or	a	maximum	of	400 AGL.

Given	these	safety	features,	SFF proposes	that	Operators	of	the	SFF’s sUAV should

not	be	required	to	hold	a	pilot	certification.	

Instead,	 Operators	 should	 be required	 to: have	 successfully	 completed,	 at	 a	

minimum,	 FAA	 pilot	 ground	 instruction	 and passed	 the	 FAA	 Pilot	 written	

examination	or	FAA-recognized	equivalents;	have	completed	the	manufacturer’s	or	

SFF’s training	program	for	operation	of the	UAS.

SFF notes	that	the	FAA	has	found	that	safety	factors permitted	operation	of	UASs	by	

Operators	 with	 these	 qualifications	 in	 the	 case	 of	 operations	 pursuant	 to	 public	

COAs	where	the mandatory	operating	conditions	specified	above	were	present.	See,	

Federal	 Aviation Administration,	 Notice	 N-8900.227,	 Unmanned	 Aircraft	 Systems	

(UAS)	Operational	Approval,	at 20-21	(July	30,	2013).	Likewise,	SFF notes	that	the

NPRM	does	not	require	that	the	Operator	hold	a pilot	license	issued	by	the	FAA.

Given	 these	 conditions	 and	 restrictions,	 an	 equivalent	 level	 of	 safety	 will	 be	

provided	by	allowing operation	of	the	SFF’s sUAV without	a	pilot’s	certificate,	under	

the	conditions	set	forth	herein.

The	 risks	 associated	 with	 the	 operation	 of	 the	SFF’s sUAV (given	 its	 size,	 speed,	

operational	 capabilities,	 and	 lack	 of	 combustible	fuel)	 are	 so	 diminished	from	the	

level	 of	 risk	 associated with	 pilot	 operations	 or	 commercial	 operations	

contemplated	by	Part	61	with conventional	aircraft	(fixed	wing	or	rotorcraft),	that	

allowing	operations	of	the	UAS	as	set	forth above	meets	or	exceeds	the	present	level	

of	safety	provided	under	14	C.F.R.	§	61.113(a)	&	(b) and	does	not	rise	to	the	level	of	

requiring	a	commercial	pilot	to	operate	the	aircraft	under §	61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This	 regulation	 requires	that	no	person	may	operate	 a	 civil	 aircraft	unless	it	is	in	

airworthy	 condition.	 Should	 the	 exemption	 be	 granted	 allowing	 commercial	
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operation	of	the	UAS	without an	airworthiness	certificate,	no	standard	will	exist	for	

airworthiness	of	the	UA.	Given	the	size	of the	aircraft	and	the	requirements	that	the	

Operator	has	agreed	to	as	it	relates to	airworthiness, as	contained	in	the	manual,	an	

equivalent	level	of	safety	will	be	achieved	by	insuring compliance	with	the	manuals	

prior	to	each	flight.	The	FAA	has	granted	exemptions	to	conduct similar	operations	

in	Exemptions	11062	through	11067,	11080	and	11110.

14 C.F.R. §91.119: Minimum safe altitudes

Section	 91.119	 establishes	 safe	 altitudes	 for	 operation	 of civil	 aircraft.	 Section	

91.119	(d)	allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	

provided	the	person operating	the helicopter	complies	with	any	route	or	altitudes	

prescribed	 for	 helicopters	 by	 the FAA.	 As	 this	 exemption	 is	 for	 a	 sUAS	 that	 is	 a	

helicopter	and	the	exemption	 requests	authority to	operate	at	altitudes	up	to	400	

AGL,	an	exemption	may	be	needed	to	allow	such	operations.	

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,	facility	owner,	and/or	local	officials.	Because	

of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals	

will	be	aware	of	the	planned	flight	operations	as	set	forth	in	the	Manuals.	Compared	

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

55	lbs.	and	the	lack	of	flammable	fuel,	any	risk	associated with	these	operations	is	

far	 less	 than	 those	 presently	 presented	 by	 conventional	 aircraft operating	 at	 or	

below	 500	 AGL	 in	 the	 aerial	 photography	 industry.	 In	 addition,	 the	 low-altitude

operations	of	the	sUAS	will	ensure	separation	between	these	small-UAS	operations	

and	the operations	of	conventional	aircraft	that	must	 comply	with	Section	91.119.	

The	 FAA	 has	 granted exemptions	 to	 conduct	 similar	 operations	 in	 Exemptions	

11062	through	11067,	11080	and 11110.

14 C.F.R. §91.121 Altimeter Settings

This	 regulation	 requires	 each	 person	 operating	 an	 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	SFF’s

sUAV,	in	manual	or	emergency mode,	will	not	have	a	barometric	altimeter	display,	

but	 instead	 a	 GPS	 altitude	 display,	 an exemption	 will	 be	 needed.	 The	 Operator,	

pursuant	to	the	procedures	set	forth	in	the	Manuals	as	indicated	before	flight,	will	

achieve	an	equivalent	level	of	 safety.	The	FAA	has granted	exemptions	to	 conduct	

similar	operations	in	Exemptions	11062	through	11067,	11080 and	11110.
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14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section	 91.151(a)	 prohibits	 an	 individual	 from	 beginning	 “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	– (1)	During	the day,	to	fly	after	that	for	at	least	30	minutes;	

or	(2)	At	night,	to	fly	after	that	for	at	least	45 minutes.”

The	 battery	 powering	 the	 sUAS	 provides	 approximately	 40	 minutes	 of	 powered	

flight.	To meet	the	30-minute	reserve	requirement	in	14	CFR	§91.151,	sUAS	flights	

would	be	limited	to approximately	10	minutes	in	length.	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	is	reasonable.

Petitioner believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	

of prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	

to	operate without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	

tightly	 controlled	 area where	 only	 people	 and	 property	 owners	 or	 official	

representatives	who	have	signed	waivers	will be	allowed,	with	less	than	30	minutes	

of	 reserve	 fuel,	 does	 not	 engender	 the	 type	 of	 risks	 that Section	 91.151(a)	 was	

intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.

Petitioner believes	 that	 an	 equivalent	 level	 of	 safety	 can	 be	 achieved	 by	 limiting	

flights	to 30	minutes	or	25%	of	remaining	battery	power	whichever	happens	first.	

This	 restriction	 would	 be	 more	 than	 adequate	 to	 return	 the	 sUAS	 to	 its	 planned	

landing	zone	from	anywhere	in	its	limited operating	area. Similar	exemptions	have	

been	granted	to	other	operations,	including	Exemptions	2689F, 5745,	10673,	10808	

and	Exemptions	11062,	through11067,	11080	and	11110.

14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance

Inspections

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	 the	 Petitioner.	 Maintenance	 will	 be	

accomplished	by the	Operator	or	manufacturer	pursuant	to	the	flight	manual	 and	

operating	handbook	as referenced	in	the	Manuals	attached	as	confidential	Exhibits	

an	 equivalent	 level	 of	 safety	 will	 be achieved	 because	 these	 small	 UASs	 are	 very	

limited	in	size	and	will	carry	a	small	payload	and operate	only	in	defined	areas	for	
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limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and	

will	 be	 operating	 from	 no	 higher	 than	 400	 feet	 AGL.	 As	 provided	 in the	 Aircraft	

Flight	Operations	Manual	the	Operator	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	 Operator	 and	 manufacturer	 are	 most	

familiar	with	the	 aircraft	 and best	 suited	to	 maintain	the	 aircraft	 in	 an	 airworthy	

condition	to	provide	the	equivalent	level	of safety.	The FAA	has	granted	exemptions	

for	similar	operations	in	Exemptions	11062	through 11067,	11080	and	11110.

*********

Federal Register Publication

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

the	Federal	Register,	should	it	be	determined	that	publication	is	needed:

Petitioner seeks	an	exemption	from	the	following	rules:

14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a);

91.407(a)(1);	 91.409(a)(2)	 and	 91.417	(a)	&	(b)	to	 operate	 commercially	 a	 small	

unmanned	 vehicle	(55	 lbs.	 or	 less)	 for	the	 following	 purposes:	to	 conduct bridge	

inspections,	flare	stack	inspection,	utility-power	generation	system	inspections	and	

patrolling,	aerial	inspection	and	photography	of	 residential	and	commercial	utility	

infrastructure	including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	

cell	 towers,	 pipeline	 inspection	 and	 patrolling,	 filmmaking,	 cinematography,	 and	

videography,	 precision	 agriculture	 with	 on	 board	 sensors,	 wildlife	 and	 forestry	

monitoring and	 mosquito	 and	 insect	 control,	 aerial	 surveying,	 construction	 site	

inspection	 and	 monitoring,	 public	 entity	 support	 operations,	 aerial	 video	 and	 live	

video	 feed	 to	 assist	 with	 search	 and	 rescue	 operations	 under	 the	 authority	 and	

support	 of	 local	 authority	 officials,	 aerial	 video	 and	 photography	 for	 public	 and	

private	 use	 including	 television,	 public	 events,	 and	 cinematography	 live	 feed	 and	

live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and	

public	 organizations	 to	 increase	 awareness	 and	 improve	 safety	 for	 current	 and	

future	 UAS	 operations	 within	 the	 NAS,	 special events:	 including	 high	 schools,

colleges,	professional	sports,	open	air	events	and	fairs,	research,	risk	management	

and	 assessment,	 motion	 picture	 production,	 surface	 mining,	 closed	 set	 filming,	

disaster	and	catastrophe	events.

Privacy and National Security

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

owner’s	prior	consent	and	knowledge.	Inspection	will	be	of	inanimate objects	in	

areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have	
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agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where	operations will	

take	place.	

The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	raise	national

security	issues.

Summary

Approval	of	exemptions	allowing	commercial	operations	of	sUAVs	for	petitioner	to	

operate	 an	 unmanned	 aircraft	 system	 (UAS)	 to	 conduct	 conduct	 aerial	 data	

collection,	search	and	rescue	operations,	motion	picture	production6 and	closed	set	

filming,	training.	

Conventional	 operations,	 using	 jet	 or	 piston	 powered	 aircraft,	 ladders	 or placing	

people	in	swamps,	on	roofs	or	tall,	hazardous	or	weakened	structures,	exposes	them	

to	 higher	 risks than those	 created	 by	 use	 of	 a	 sUAVs.	 Conventional	 aircraft	 that	

operate	at	extremely	low altitudes	just	feet	from	the	subject	being	inspected	and	in	

extreme	 proximity	 to	 people	 and structures	 present	 the	 risks	 associated	 with	

vehicles	that	weigh	in	excess	of	6,000	lbs.,	carrying large	amounts	of	jet	A	or	other	

fuel	(140	gallons	for	jet	helicopters).	Such	aircraft	must	fly	to	and from	the	project	

location.	In	contrast,	a	sUAV weighing	fewer	than	55 lbs.	and	powered	by batteries	

eliminates	virtually	all	of	that	risk	given	the	reduced	mass	and	lack	of	combustible	

fuel carried	 on	 board.	 The	 sUAV is	 carried	to	the	target	 area	 and	 not	 flown.	 The	

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

risks	associated	with	manned aircraft	flights.

The	operation	of	small	UASs,	weighing	less	than	55 lbs.,	conducted	under	the	strict

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	

grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow	

speeds,	close	to	the ground,	and	in	areas	that	are	under	the	control	of	the	customer	

for	 the	 operations and,	 as	 a result,	 are	 far	 safer	 than	 conventional	 operations	

conducted	with	turbine	helicopters	operating	in close	proximity	to	the	ground	and	

people	or	the	use	of	individuals	to	climb	the	structures	to conduct	the	operations.

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	 – provide	 more	 than	

adequate	 justification	 for	 the grant	 of	 the	 requested	 exemptions	 allowing	

commercial	operation	of	Petitioner’s	UAS	for	the Purposes	outlined	herein	and	are	

consistent	with	exemptions	already	granted,	including Exemptions number	11171	

																																																							

6 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as	

Appendix G.
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through	 11174,	11176,	11177,	11062,	11109,	11112,	 and	11213 and	 as	 recent	 as	

11857.

Sincerely,

Steve	North

Sailfish	Films

4754	NW	Red	Maple	Dr

Jensen	Beach,	FL	34956

and	

Stephen	Gowdy

Chief	Pilot,

Gowdy	Brothers	Aerospace,	LLC

Consulting	Agent	for	Sailfish	Films
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APPENDIX A - EXEMPTION PATTERN

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
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APPENDIX B – SUAV LIST AND TECHNICAL MANUALS AND SPECIFICATIONS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	 contain	

proprietary	 confidential	 business	 information	 that is	 not	 released	 to	 the	 public	 and	 is	

protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	 seq.	5	Reform	Act	Section	

333	(b).	

Submitted	under	separate	cover.
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APPENDIX C - COMMERCIAL (MISSION/OPERATION) PURPOSE - FAA 

PREVIOUS APPROVED EXEMPTION NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

www.GowdyBrothersAerospace.com		763-496-9551 Page	29

APPENDIX D - EQUIPMENT - FAA PREVIOUS APPROVED EXEMPTION 

NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

www.GowdyBrothersAerospace.com		763-496-9551 Page	30

APPENDIX E - EXEMPTION 14 C.F.R - FAA PREVIOUS APPROVED 

EXEMPTION NUMBERS

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

www.GowdyBrothersAerospace.com		763-496-9551 Page	31

APPENDIX F - MONTHLY MAINTENANCE AND REPAIR LOG

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.
Gowdy	Brothers	Aerospace,	LLC			8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379		

www.GowdyBrothersAerospace.com		763-496-9551 Page	32

APPENDIX G – MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS 

MANUAL VERSION 1.0

Petitioner	 submits	 the	 Appendix	 and	 Manuals	 marked	 “CONFIDENTIAL,”	 as	 they	

contain	 proprietary	 confidential	 business	 information	 that	 is	 not	 released	 to	 the	

public	and	is	protected	under	the	Freedom	of	Information	Act	5	USC	§552	et.	seq.	5	

Reform	Act	Section	333	(b).	

Submitted	under	separate	cover.