January 5, 2016

U.S. Department of Transportation

Docket Operations, M-30

1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor

Washington, DC 20590-0001

Re: Petition of Tim Trott dba Southern Helicam for an Modification to Exemption 

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

an Unmanned Aircraft System for Training purposes. ID: FAA-2015-0263-0001

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, Tim Trott, dba Southern Helicam, previously granted Exemption #11631 

under Section 333, hereby applies for an further exemption from the Federal Aviation 

Regulations identified below to allow for the commercial operation for operator safety and 

flight operation training and relief from Pilot Certification requirement.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

Petitioner requests additional exemption from one or more the following regulations:

• 14 C.F.R Part 21, Subpart H;

• 14 C.F.R Part 27;

• 14 C.F.R § 45.23(b);

• 14 C.F.R. § 45.27(a);

• 14 C.F.R § 61.113;

• 14 C.F.R § 91.7(a);

• 14 C.F.R § 91.9(b)(2);

• 14 C.F.R § 91.9(c);

• 14 C.F.R § 91.103;

• 14 C.F.R § 91.109(a);

• 14 C.F.R § 91.119;

• 14 C.F.R § 91.121;

• 14 C.F.R § 91.151(a) & (b)

• 14 C.F.R § 91.203 (a) & (b);

• 14 C.F.R § 91.405(a);

• 14 C.F.R § 91.407(a)(l);

• 14 C.F.R § 91.409(a)(2);

• 14 C.F.R § 91.417 (a) & (b).
II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. 

Congress has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems into the national airspace system.” Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to permit operation of an unmanned aircraft system where it does not create a 

hazard to users of the national airspace system (NAS) or the public or pose a threat to national 

security based on the following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant 

exemptions from the agency’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 

106(f), 44701-44716, et seq. A party requesting an exemption must explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or 

how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.

III. DESCRIPTION OF PETITIONERAND ITS SERVICES

Petitioner is a holder of an existing Section 333 Exemption who seeks further exemption such as 

to provide training for unmanned aerial vehicles for recreational or commercial users as well as 

public safety and emergency services entities, for the purpose of promoting greater safety in the 

national airspace, and to ensure safe use, while mitigating risk to persons and property.

A training curriculum has been developed (see section IV below) to encompass the 11 training 

areas outlined in the NPRM (§107) in addition to other basic aviation ground school subjects.

The aim is to make sure that operators receive training sufficient to maintain safety standards and 

to understand the FAA rules and safety standards. 

The Petitioner’s curriculum is based on a building block learning system. Operators in training 

would be urged to obtain membership in the Academy of Model Aeronautics (AMA) and to 

practice a specified number of hours at an AMA club facility. 

IV. DESCRIPTION OF PROPOSED OPERATIONS

Petitioner is requesting exemptions from applicable Federal Aviation Regulations (FARs) 

pursuant to Section 333 of the Reform Act to perform UAV training to persons or organizations 

which would be using small UAVs. Petitioner training sessions are designed to assure (i) public 

and worker safety; (ii) safe methods to effectively employ small UAVs; and (iii) ensure operators 
are aware of all pertinent FAA regulations. Granting of this further exemption will enhance 

safety by reducing risk to the operator, the general public and property owners from hazards 

associated with small UAVs.

Petitioner recognizes the enormous potential of sUAS but also recognizes the need for due 

diligence and responsibility on the part of the persons who will fly the sUAS to ensure the safety 

of the National Airspace (NAS) with respect to manned aircraft. Petitioner will assist with the 

integration of sUAS into the NAS by educating users on this new technology. Petitioner is 

seeking this exemption to ensure that recreational user and operators for public entities have a 

reasonable option for obtaining training on small UAVs. 

Petitioner’s mission is to help promote the protection of the NAS by providing education and 

training for sUAS operators.

Petitioner’s courses are to be taught in a step-by-step progression where the user has indoor 

training followed by outdoor flight training. The course of training is based on the Fundamentals 

of Instruction methods of classroom instruction, trainer demonstration and user hands-on 

performance. Understanding and proficiency is determined by knowledge (written) and 

proficiency (skills) testing.

In addition to flight training, the instruction includes the following:

(1) applicable regulations relating to small UAS rating privileges, limitations, and flight 

operation; 

(2) airspace classification and operating requirements, 

a) obstacle clearance requirements

b) flight restrictions affecting small UAS operation; 

(3) official sources of weather and effects of weather on small UAS performance; 

(4) small UAS loading and performance; 

(5) emergency procedures; 

(6) crew resource management; 

(7) radio communication procedures; 

(8) determining the performance of small UAS; 

(9) physiological effects of drugs and alcohol; 

(10) aeronautical decision-making and judgment; and 

(11) airport operations

The training sessions will take place in various locations. All flight training is to be conducted at 

200 AGL or below. 

The sUAS to be used in training are those which were included in the previously approved 

exemption (11636) or those owned by the student who will be required to obtain and hold

the requisite owner registration.

1. General Description of Proposed Flight Operations
The proposed operations do not create any hazard to users of the National Airspace System or 

pose a threat to national security. The sUAV’s ground speed has a maximum of 25 mph but it 

will be operated between 2 and 5 miles per hour, at or below 200 feet AGL. 

Petitioner training operations will be in areas at least 5 miles from any airport or two miles from 

restricted zones (hospital, etc.).

The FAA has determined that the risk of not having an electronic means to monitor and 

communicate with other aircraft, such as transponders or sense and avoid technology, is 

mitigated by placing limits on altitude, requiring distance from clouds, permitting daytime 

operations only, requiring that the aircraft be operated within visual line of sight and yield right 

of way to all other manned operations. However, where appropriate, the operator has the 

capacity to monitor aircraft frequencies with aircraft transceivers maintained for the purpose. 

The petitioner’s aircraft has the capability to operate safely after experiencing certain in-flight 

failures, as specified in the product manuals previously provided. The aircraft is also able to 

respond to a lost-link event with a pre-coordinated, predictable, automated flight maneuver

(Return To Home).

2. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted environment within which they will operate, the 

procedures listed below, and pilot certification requirements, Petitioner’s proposed operations 

using the sUAS would “not create a hazard to users of the national airspace system or the public 

or pose a threat to national security.” Reform Act Section 333(b)(1).

1. The aircraft is approximately 3 pounds.

2. The aircraft will be identified by serial number, are registered with the FAA, and 

have identification (N-Number) markings.

3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and 

confirmed for accuracy by PIC.

5. Maximum flight time for each operational flight will be 20 minutes.

6. The aircraft will be safely landed with no less than the greater of (a) 20% battery 

life remaining or (b) five minutes of flight time remaining.

7. The aircraft will be operated during daylight and in VFR conditions.

8. Flights will not exceed 200 feet AGL, so as to basic flight training.

9. Flights will be operated at a lateral distance of at least 50 feet from any persons or 

property not associated with the operation who have not given prior permission.

10. Flights will be limited to a groundspeed of 5 mph.

11. Minimum crew for each flight will consist of a PIC and an Observer.

12. The trainer will assure that civil UAS operations are conducted in accordance 

with Section 333. The Petitioner may also employ, at his option, a licensed pilot 

or certified flight instructor (CFI) 

13. Prior to the flight, a Mission Plan will be created setting forth the limitations for 

the flight.
14. The flight operations will yield the right of way to other manned aircraft 

operations.

15. All persons who are not involved with training class will be required to remain 

outside the marked training area.

16. All required permissions and permits will be obtained from territory, state, county 

or city jurisdictions prior to flight.

17. If an aircraft loses communications, it will have programmed to return to a predetermined launch location within the operational area and land.

18. If the aircraft loses its GPS signal it will have the capability of being flown 

manually to a predetermined location within the operational area and land.

19. The flight will be aborted in case of unpredicted obstacles or emergencies.

20. Each flight will be recorded in an Operations Log Book.

24. Maintenance on the aircraft will be recorded in a Maintenance Log Book.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are documented in the DJI 

manuals which were included in the prior approved petition. 

V. SPECIFIC FAR EXEMPTIONS REQUESTED

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61, 

and 91 for purposes of conducting the requested operations using the sUAS. Listed below are (1) 

the specific FAR sections for which exemption is sought, and (2) the operating procedures and 

safeguards that Petitioner has established which will ensure a level of safety better than or equal 

to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

Petitioner seeks exemption from 14 CFR § 61.113, which restricts private pilots from flying 

aircraft for compensation or hire and would also require a second class medical certificate. The 

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in 

which the PIC will be operating, as well as requiring certifications if the pilot is carrying 

passengers or cargo for hire.

While the sUAS will be operated as part of a commercial operation, it carries neither passengers 

nor cargo. In the Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined 

that the unique characteristics of UAS operation outside of controlled airspace did not warrant 

the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot 

certificate and a class II medical certificate. The FAA has also determined that the required 

knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The 

applicant has demonstrated equivalent knowledge relevant to UAS operation by passing the 

written test for Sport Aircraft (SPA).
Furthermore, the security screening conducted by the Transportation Security Administration of 

certificated airmen satisfies the statutory requirement of Section 333 for operations to not pose a 

threat to national security. The Petitioner has provided identification by way of initiating student 

pilot training at First Landings flight school in Apopka, Florida and Island Air Express in 

Panama City, Florida.

The restrictions Petitioner has placed on its sUAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial in FAA Docket No. FAA-2014-0352. The aircraft will be 

flown based on VLOS at or below 200 feet AGL. 

B. 14 C.F.R. § 91.103: Preflight Action

Equivalent Level of Safety: An equivalent level of safety will be provided by following the 

Manuals. The PIC will take all required preflight actions - including performing all required 

checklists and reviewing weather, flight requirements, battery charge, landing and takeoff 

distance, aircraft performance data, and contingency landing areas - before initiation of flight. 

The Manuals will be kept at the ground station with the operator at all times.

C. 14 C.F.R. § 91.109(a): Flight Instruction

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o 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.” UASs and remotely piloted aircraft, by 

their design, do not have functional dual controls. Instead, flight control is accomplished through 

the use of the A2 Flight Control System/Ground Control Station (GCS) that communicates with 

the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, the public and all participants

will be a safe distance from the aircraft, causing no safety hazard. Given the size and speed of the 

sUAS, an equivalent level of safe training can still be performed without dual controls because 

no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the 

event that the aircraft experiences any difficulties during flight instruction. In addition, Petitioner

will conduct flight training at a facility away from population centers. These training flights will 

be conducted on the sites and will otherwise comply with the provisions in the Manuals. 

Accordingly, Petitioner proposed method of operation provides superior levels of safety.

D. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. The Manuals provide for operations away from 

congested populations areas on the sites. The FAA has already determined that relief from 

Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight 

restrictions as those imposed by Petitioner. See Grant of Exemption No. 11062, p. 20-21.
Equivalent Level of Safety: Compared to flight operations with rotorcraft weighing far more 

than the maximum weights proposed herein, and given the lack of flammable fuel, any risk 

associated with these operations is far less than those that presently exist with conventional 

aircraft. An equivalent level of safety will be achieved given the size, weight, and speed of the 

sUAS, as well as the locations where it is operated – the sites. In order to avoid any risk to 

aircraft, flight operations will be restricted to 200 feet AGL or below. As set forth in the Manuals 

and previously provided, the sUAS will be operated at locations away from persons or structures 

not involved in the operation. All persons who are not involved with Petitioner operations will be 

required to be at least 25 feet from the training perimeter. 

VI. PUBLIC INTEREST

Granting Petitioner petition for exemption furthers the public interest. National policy set by 

Congress favors early integration of UAS into the NAS in controlled, safe working environments 

such as the sites proposed in this petition. By granting this petition, the FAA will fulfill 

Congress’s intent of allowing UAS to operate safely in the NAS before completion of the 

rulemaking required under Section 332 of the Reform Act.

Moreover, use of unmanned aircraft operations will improve awareness of FAA regulations and 

provide a standard level of training for all sUAS operators. The use of the sUAS will also 

decrease safety-related incidents involving new operators.

sUAS flight training will increase the effectiveness of new users, decrease their safety risks, and 

reduce the number of incidents between unmanned and manned aircraft.

Thus, the use proposed here will allow Petitioner to determine the efficacy of the sUAS for 

increasing public safety. The sUAS is approximately 2.75 pounds, carries no passengers or 

crew, and has no flammable fuel, as opposed to larger and more powerful helicopters and small 

airplanes. This program may prevent accidents and injuries, and there is a strong public interest 

in making these operations more safe and effective through the use of UASs.

VII. PRIVACY

All flights will occur over the identified sites. All flights will be conducted in accordance with 

any federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

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 one or more of the following rules for the commercial 

operation of a small unmanned aerial systems for operator training: 14 C.F.R Part 21, Subpart H; 

14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R § 61.113; 14 C.F.R § 

91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 
C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 

C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & 

(b).

The exemption will enhance safety by reducing risk to the operator, the general public and 

property owners from the hazards associated with new sUAS pilots.

IX. ATTACHMENTS

Attachment 1: Certificate of FOI exam

Attachment 2: Certificate of SPA exam

Attachment 3: Instructor Certification from Florida Department of Law Enforcement

Attachment 4: Private Pilot Ground School Certificate – Gold Seal

Attachment 5: Unmanned Experts Initial Qualification Training Course (IQT1)

Attachment 6: Air Safety Institute ADS-B for General Aviation

X. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of 

sight, and national security considerations - provides more than adequate justification for the 

grant of the requested extended exemptions to permit Petitioner to operate for training purposes.

Granting the requested exemption will benefit the public interest as a whole in many ways, 

including (1) significantly improving safety and reducing risk by alleviating human exposure to 

danger; (2) improving the quality of services Petitioner can provide to its customers; and (3) 

decreasing the risks of unmanned aircraft interfering with manned aircraft

Respectfully submitted,

 By: Tim Trott, Southern Helicam
Attachment 1: FOI 
Attachment 2: SPA
Attachment 3: Instructor Certification for Florida Department of Law Enforcement 
Attachment 4 Unmanned Experts Initial Qualification Training Course (IQT1)
Attachment 5
Attachment 6 Air Safety Institute ADS-B for General Aviation