14812 N. 60th St | Scottsdale, AZ 85254 | (301)266-2011 | Doug@RevolutionUAS.com

May 27, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Petition of Revolution UAS, LLC for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

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

Act") and 14 C.F.R. Part 11, Revolution UAS, LLC, hereby applies for an exemption from the 

Federal Aviation Regulations ("FARs") identified below, to allow commercial operations of 

small unmanned aerial vehicles (i.e., "small unmanned aircraft" or "UAS").

This exemption is made based on the information in this petition, as well as the 

accompanying Revolution UAS Operations, Maintenance and Safety Manual ("Operations 

Manual") Petitioner submits this supporting material as confidential documents under 14 C.F.R. 

§ 11.35(b), as they contain confidential commercial and proprietary information that the 

Petitioner has not and will not share with others. Similarly, these documents contain operating 

conditions and procedures that are not available to the public and are protected from release 

under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements 

established by the FAA pursuant to Section 333 of the FAA Reform Act.

This exemption request will permit Revolution UAS LLC, to operator commercially for 

the purpose of collecting aerial photography and videography used to support a broad variety of 

inspection and ground truth operations. 

We request a summary grant, as we have designed our petition, operations, and chosen 

UAV to not set precedent over previously approved exemptions. 

For your convenience, the petition is organized as follows:

I. Description of Petitioner

II. Public Interest

III. Relevant Statutory Authority

IV. Revolution UAS Proposed UAS Operations Meet The Requirements Of Section 333 

Of The Reform Act

V. Regulations from which exemption is requested and equivalent level of safety 
a. 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203

b. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

c. 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

d. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 

e. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration.

f. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

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

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

i. 14 C.F.R. § 91.119: Minimum Safe Altitudes

j. 14 C.F.R. § 91.121: Altimeter Settings

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

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

Inspections

m. 14 CFR § 61.113 Private Pilot Privileges and Limitations

VI. Drug and Alcohol Policy

VII. Privacy

VIII. Federal Register Summary

IX. Conclusion

I. Description of Petitioner

Revolution UAS LLC. “Revolution UAS”, is headquartered in Scottsdale, AZ and was 

founded by two military veterans with significant military and civilian aviation experience. 

Revolution UAS seeks the requested exemptions in order to provide optical and thermal sensor 

data acquired from UAS platforms to perform light industrial inspection, survey and ground truth 

photography and videography.

Revolution UAS employs a DJI s900 with 3D Robotics Pixhawk flight controller. A 

complete description of the system is included in the attached operations manual. The S900 has 

received approval for use in Exemption 11326 (PPL Electric Utilities Corp), and Exemption 

11400 (McKenna Long & Aldridge LLP). Our proposed use is similar in all material respects as 

those being used in Exemption Nos. 11062, 11109, 11112, and 11213.

II. Public Interest

Revolution UAS has performed significant market research, partnering with local 

companies to understand and leverage the utility of unmanned systems to reduce risk, cost and 

improve efficiency. As described below, the requested exemption would authorize Revolution 

UAS to perform commercial UAS operations within the NAS that will provide the following 

benefits: 

a. Commercial use of UAS to perform aerial data gathering in support of the 

following industries: Construction site photography and mapping, precision 
agriculture, pipeline/power line transmission/distribution towers, tower 

inspection, manmade/natural disaster damage assessment, support to first 

responders, security, construction, research, wildlife and wildfire monitoring, real 

estate, local infrastructure such as bridges, surveying, scientific studies, insurance 

functions, training, mining and UAS research and development. All of these 

activities are critical to the well-being of the general public. 

b. The use of an UAS provides much improved data for decision making. The 

technical combination of platform, sensor and software, allows us to rapidly 

acquire and organize data that previously had to be obtained by manned 

inspection, such as roof or tower inspection. 

c. The use of UAS will decrease congestion in the NAS along with reducing the 

noise/air pollution generated during traditional manned aircraft flight operations. 

Many of the operations proposed in this petition for exemption are currently 

achieved by aircraft or rotorcraft flying at low altitudes. 

d. Operation of UAS may substantially reduce the risk to life and property by 

performing missions that are currently being performed by manned aircraft that 

are considered dangerous (i.e., transmission tower inspections or operating in 

extreme terrain or weather conditions). In the absence of a UAS, many of 

these inspections would have to be carried out by a helicopter or by sending

someone up to perform the inspection manually. Utility inspections by 

helicopter are carried out at speed up to 70 knots, and the consequences of a

wire strike or other collision is much greater than with the UAS. Moreover,

conducting helicopter inspections at certain locations, such as substations 

where several transmission lines converge, carry additional risks to

helicopters. 

Petitioner’s Address:

Doug Andriuk

14812 N. 60th St

Scottsdale, AZ 85254

doug@revolutionuas.com

II. Relevant Statutory Authority

This petition for exemption is submitted in accordance with the Section 333(a) through (c) 

of the FAA Modernization and Reform Act of 2012. 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 unmanned 

aircraft systems to operate in the National Airspace System ("NAS") where it is safe to do so 

based on the following considerations:

 The UAS's size, weight, speed, and operational capability;
 Operation of the UAS in close proximity to airports and populated areas; and

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

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), (b) and§§ 

44702-44716, 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). See 14 C.F.R. § 11.81 

(petitions for exemption).

III. Revolution UAS’ Proposed UAS Operations Meet the Requirements of 

Section 333 of the Reform Act.

The proposed operations in this petition for exemption qualify for expedited

approval under Section 333 of the Reform Act. Each of the statutory criteria and other

relevant factors are satisfied.

a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and 

Operational Capability

Revolution UAS will employ the DJI S-900 for its infrastructure inspection 

operations. This UAS has a maximum take-off weight of 24 pounds. The UAS's flight

speed will not exceed 30 miles per hour, and it will not be flown in controlled airspace

or at an altitude that exceeds 400 feet AGL. All flights will be flown in such a way that

they can be safely terminated with a reserve battery power of 25% maximum charge. 

The DJI S-900 do not carry any flammable propellant or fuel.

The DJI S-900 also has redundant motor capabilities, and the vehicle is still

capable of flight in the event a motor fails unexpectedly. The vehicle is capable of

compensating for an engine loss automatically and action is not required by the PIC.

The DJI S-900 also has features that can alert the PIC to the possibility of a lost

link before it occurs. Because the video link is at a shorter wavelength than the control

links, it is more susceptible to loss than the control link. Loss of the video signal warns

the PIC that action should be taken to ensure continued control. In the event the control

link is lost, the UAS is also equipped with a failsafe setting that permits the vehicle to

return to a preselected home point.

Given the small size of the selected UAS and the restricted environment within

which they will operate, this petition for exemption falls within the zone of safety, i.e.,

an equivalent level of safety, in which Congress directed the FAA to permit commercial 

UAS operations by exemption pending completion of formal rulemaking.
b. Approval is Warranted Based on the Operational Restrictions Set Forth

in the Operations Manual

The Revolution UAS Operations Manual and manufacturer's maintenance and flight

manuals contain all of the procedures and limitations necessary to successfully perform the 

proposed operation. To assist the FAA in its safety assessment of Revolution UAS’s 

operations, below is a summary of operational limitations and conditions which will ensure

an equivalent or higher level of safety for operations conducted under current regulatory 

guidelines:

1. The UAS will adhere to it published maximum takeoff weight as outlined in in 

the operations manual.

2. The radio frequencies used for operations and control of the UAS will comply 

with the Federal Communications Commission ("FCC") or other appropriate 

government oversight agency requirements.

3. Minimum crew for each operation will consist of a pilot, who will be Pilot-in 

Command ("PIC") of the UAS, and one or more Visual Observers ("VO") 

necessary to safely conduct the mission.

4. The UAS shall be operated within Visual Line of Sight ("VLOS") of the PIC and 

VO at all times. The PIC will use human vision unaided by any device other 

than corrective lenses.

5. The VO designated for any operation will be in constant voice contact with the 

PIC.

6. The additional requirements identified in the exemption grant shall be added to 

the Revolution UAS' Operations Manuals. The Operations Manual will be 

maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in the granted 

exemptions and the Revolution UAS Operations Manuals, the conditions and 

limitations in the granted exemptions shall take precedence and must be 

followed. Otherwise, Revolution UAS must follow the procedures outlined in 

their Operations Manuals.

7. Maximum total flight time for each operational flight will be limited to the 

amount of time the UAS can be flown and still maintain a reserve battery power 

of no less than 25%.

8. Flights will be operated at an altitude of no more than 400 feet AGL and will not 

be conducted within navigable airspace.
9. Flights will be operated at a lateral distance of at least 500 feet from any

inhabited structures, buildings, vehicles or vessels, or from people not associated

with the operation who have not given permission in advance of the operation.

10. The Pilot will have a private pilot's license, will be trained in accordance with 

the Operations Manual and will pass a company imposed flight evaluation. 

11. The Visual Observer designated for any operation will be required to complete

the training course as set forth in the Operations Manual before performing his

duties on any flight.

12. The UAS will operate in accordance with the safety and operational

requirements of the Operations Manual and manufacturer’s flight manual.

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

for the flight as well as contact and hazard information provided by the utility.

14. A NOTAM will be issued not more than 72 hours in advance of flight, but not 

less than 48 hours before flight.

15. The PIC and Visual Observer will at all times be able to communicate by voice.

16. A Certificate of Authorization will be obtained prior to flight.

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

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

appropriate governmental agencies.

18. The operator will coordinate all flights with the appropriate Flight Standards

District Office.

19. If the UAS loses communications or loses its GPS signal, the UAS will have

the capability to return to a pre-determined location within the operational

area and land.

20. Contingency plans will be in place to safely terminate flight if there is a loss

of communication between the pilot and the observer.

21. The UAS will have the capability to safely abort flight in the case of unpredicted 

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

unpredicted obstacles or emergencies in accordance with the Revolution UAS’ 

Operations Manuals.
IV. Regulations from which exemption is requested and equivalent level of safety 

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 

91.203(a)(1)

The regulation requires:

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the

size and limited operating area associated with the aircraft to be utilized by the Applicant, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

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

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

without an airworthiness certificate, in the rural sparsely populated environment and under 

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

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed.

Equivalent Level of Safety:

The UAS to be operated is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials, and operates exclusively within a

secured area as set out in the Manual. Unlike other civil aircraft, the proposed 

operations in this petition for exemption will be controlled and monitored by the

operator, pursuant to the Manual's requirements. Moreover, the FAA will have

advance notice of all operations conducted under this exemption. 

These safety enhancements, which already apply to civil aircraft operated in connection 

with existing inspection operations, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, 

location of operation, lack of explosive materials, and inability to carry a substantial external 

load.

b. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft.

14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness

certification of normal category rotorcraft. To the extent the Petitioner's UASs would

otherwise require certification under Part 27, as a rotorcraft, Petitioner requests an

exemption from Part 27’s airworthiness standards for the same reasons identified in the

exemption request from 14 C.F.R. Part 21, Subpart H.
c. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements

The regulation requires:

14 C.F.R.§ 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides 

that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable.

14 C.F.R. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the 

cabin, fuselage, boom, or tail the marks required by§ 45.23. In its previous Grant of Exemption, 

the FAA determined that exemption from these requirements was warranted provided that the 

aircraft "have identification (N-Number) markings in accordance with 14 CFR part 45, Subpart 

C if the markings are as large as practicable." FAA Docket No. FAA-2014-0352.

Note:

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the

word “Experimental” can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the vehicle frame in compliance with

§45.29 (f).

Equivalent level of safety:

The equivalent level of safety will be provided by marking the sUAV’s appropriate 

identification with lettering as large as practicable. The FAA has issued the following exemptions 

to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

d. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

14 C.F.R. § 91.9(b)(2), which states:

(b) No person may operate a U.S.-registered civil aircraft
(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft 

Flight

Manual, approved manual material, markings, and placards, or any combination thereof.

Given its size, configuration, and load capacity, the UAS has no ability to carry such a 

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

simply no room or capacity to carry such an item on the aircraft.

Equivalent Level of Safety

The safety related purpose of this manual requirement can be equally satisfied by 

maintaining the UAS flight manual at the ground control point where the pilot flying the UAS

will have immediate access to it. Accordingly, Petitioner requests an exemption from 

§91.9(b)(2)'s flight manual requirements, on the condition that the UAS flight manual be 

available at the control point during each operation.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

e. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and 

Registration.

The regulation provides:

14 C.F.R. § 91.203 (a) and (b).

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has

within it the following:

(1) An appropriate and current airworthiness certificate

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

In addition to the fact that Petitioner is seeking an exemption from the airworthiness

certificate requirements, an exemption to this regulation is necessary because (a) the UAS’s load

capacity and size does not allow it to carry certification and registration documents; (2) the UAS

does not have a cabin or cockpit entrance at which the documents could be displayed; and (3) 

there are no passengers or crew for whom the certificates need be displayed.

Equivalent Level of Safety:

To the extent these regulations are applicable to the proposed UAS operations, an 

equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the pilot flying the UAS will have immediate access to them.
The FAA has issued numerous exemptions to this regulation. A representative sample of 

other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and

10700.

f. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

The regulation provides:

14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be

operated.

Equivalent Level of Safety:

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

be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size 

of the aircraft and the requirements contained in the DJI S900 & S1000 User’s Manual for

maintenance and use of safety check lists prior to each flight.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

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

The regulation provides:

14 C.F.R. §91.103, which requires a PIC to become familiar with specific information 

before each flight, including information contained in the FAA-approved Flight Manual 

on board the aircraft. While the PIC will be familiar with all information necessary to 

safely conduct the flight, an exemption is requested to the extent that an FAA-approved 

Flight manual is required.

Equivalent Level of Safety:

An equivalent level of safety will be provided by following the Aircraft Operations 

Manual and flight manual provided by the manufacturer. The PIC will take all required preflight 

actions- including performing all required checklists and reviewing weather, flight battery 

requirements, landing and takeoff distance, aircraft performance data, and contingency landing 

areas - before initiation of flight. The Aircraft Operations Manual and manufacturer's flight 

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

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

The regulation provides:
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 a device that 

communicates with the aircraft via radio communications.

Equivalent Level of Safety[DA1]:

Given the size and speed of the UAS, an equivalent level of safe training can still be 

performed without dual controls because no pilot or passengers are aboard the UAS, and all 

persons will be a safe distance away in the event that the UAS experiences any difficulties during 

flight instruction.

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See

Exemption Nos. 5778K & 9862A.

i. 14 C.F.R. § 91.119: Minimum Safe Altitudes

The regulation provides:

14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which 

aircraft may not operate, including 500 feet above the surface and away from any person, vessel, 

vehicle, or structure in non-congested areas. See 14 C.F .R. § 91.119( c). Section 91.119( d) 

allows for a helicopter to operate at less than those minimum altitudes when it can be operated 

"without hazard to persons or property on the surface," provided that "each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA."

Equivalent Level of Safety:

Risk is significantly reduced compared to flight operations with rotorcraft weighing far 

more than the maximum UAS weight 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 

UAS, as well as the location where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to 400' AGL or below. As set forth in the Manual, the UAS will be 

operated in a restricted area, away from persons or structures not involved in the operation.

j. 14 C.F.R. § 91.121: Altimeter Settings

The regulation provides:

14 C.F.R.§ 91.121: which requires a person operating an aircraft to maintain cruising 

altitude or flight level by reference to an altimeter that is set to the elevation of the departure 

airport or barometric pressure. An exemption is required to the extent that the UAS does not 

have a barometric altimeter, but rather a GPS altitude read out.
Equivalent Level of Safety:

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be 

operated at 400' or below and within visual line-of-sight in addition to GPS based altitude 

information relayed in real time to the operator. See Grant of Exemption to Astraeus Aerial, 

Docket No. FAA-2014-0352. As the attached Operations Manual indicates, the chosen UAS 

meets these requirements, and a zero altitude initiation point will be obtained prior to flight.

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

The regulation provides:

14 C.F.R.§ 91.151(a) fuel requirements for flight in VFR conditions. Section 91.151 states:

(a) No person may begin 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.

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30 minute reserve. Revolution UAS

proposes that all flights comply with this requirement by mandating that the aircraft be safely 

landed with no less than 25% of battery life remaining.

Equivalent Level of Safety:

The FAA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352. The Operations Manual conforms to this limit, 

providing an equivalent level of safety.

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

(b):Maintenance Inspections.

The regulation provides:

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

These regulations specify maintenance and inspection standards in reference to 14 C.F.R. 

Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall 

have that aircraft inspected as prescribed in subpart E of this part and shall between required

inspections . . . have discrepancies repaired as prescribed in part 43 of this chapter”). An
exemption to these regulations is needed because Part 43 and these sections apply only to aircraft

with an airworthiness certificate, which the UAS will not have.

Equivalent Level of Safety:

An equivalent level of safety will be achieved because maintenance and inspections will 

be performed in accordance with the Aircraft Operations Manual as referenced in the available

Manual. As provided in the 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. The operator is the person most familiar with the aircraft and best suited to maintain

the aircraft in an airworthy condition to provide the equivalent level of safety.

If mechanical issues arise, the UAS can land immediately and will be operating from 

no higher than 400 feet AGL. Moreover, the UAS's small size, carrying capacity, and the fact

that flight operations will only take place in restricted areas for limited periods of time, create

less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft 

performing the same operation.

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

Command.

The regulation provides:

§§ 61.113 (a) and (b), which states:

(a) Except as provided in paragraphs (b) through (h) of this section, no

person who holds a private pilot certificate may act as pilot in 

command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, 

act as pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for 

compensation or hire.

Equivalent Level of Safety:

As required by the Manual, Petitioner's UAS operators acting as PIC will hold either an 

airline transport, commercial, private, recreational, or sport pilot certificate. Because the UAS
will not carry a pilot or passengers, the proposed operations can achieve the equivalent level

of safety to 14 C.F.R. §§ 61.113 (a) and (b).

Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely 

controlled with no passengers on board. Moreover, the area of operation is controlled and 

restricted, and allflights are planned, coordinated, and briefed to the appropriate official in advance 

as set forth in the Manual.

Revolution UAS can achieve an equivalent level of safety as achieved by current

Regulations because the UAS do not carry any pilots or passengers. Further, while helpful, a

pilot license will not ensure remote control piloting skills, though Revolution UAS’s training

program will ensure the PIC has substantial experience on the airframe. The risks inherent to

the operation UAS are far less than the risk levels in the commercial activities outlined in 14

C.F.R. § 61, et seq. Thus, allowing Revolution UAS to operate its UASs as proposed will exceed

current safety levels in relation to 14 C.F.R. §§ 61.113 (a) and (b).

VI. DRUG AND ALCOHOL POLICY

Revolution UAS will have policies in place to ensure that no person may participate in 

UAS flight operations if they are under the influence of alcohol or any drug.

VII. PRIVACY

All Revolution UAS operations will be conducted in accordance with applicable federal, 

state, or local laws regarding privacy. All operations conducted over private or controlled-access 

property with permission from the land owner/controller or authorized representative.

VIII. SUMMARY OF SECTION 333 EXEMPTION REQUEST

Revolution UAS hereby provides pursuant to Part 11 a summary of its exemption 

application to allow commercial operation of the Inspire unmanned aircraft in precision aerial 

survey work. An exemption is requested from the following regulations:

• 14 C.F.R. Part 21, Subpart H- Airworthiness Certificates and 14 C.F.R. § 91.203

• 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

• 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification 

Requirements

• 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft 

• 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration.

• 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

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

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

• 14 C.F.R. § 91.119: Minimum Safe Altitudes

• 14 C.F.R. § 91.121: Altimeter Settings

• 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions
• 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections

• 14 CFR § 61.113 Private Pilot Privileges and Limitations

IX. CONCLUSION

Revolution UAS petition for exemption satisfies the criteria articulated in Section 333 of 

the Reform Act of 2012. The proposed UAS operations set forth in this petition not set 

precedent with previously approved exemptions. Approving this exemption, will benefit 

the public as a whole by improving safety, efficiency, cost and reducing the overall risk 

across a wide number of activities.

Thank for your consideration. If you have any questions or need additional information 

to support the requested exemptions, please do not hesitate to contact me at:

Doug Andriuk

Phone: 301-266-2011

Email: Doug@RevolutionUAS.com