1

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

EAGLE EYE INTELLIGENCE, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF UNMANNED AIRCRAFT SYSTEM (UAS), SPECIFICALLY THE 

EAGLE EYE MERLIN, LOCKHEED MARTIN INDAGO LE, 3DR DIY QUAD, 

LATITUDE HQ40, PHOENIX 30 and LATITUDE MC 120 MICROCOPTER DRONE 

PURSUANT TO SECTION 333 OF

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

Submitted on December 29, 2015

Dean Attridge

Director of Fight Operations

Eagle Eye Intelligence, LLC

1001 Broken Sound Parkway NW

Suite C

Boca Raton, Florida 33487
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 5

BASIS FOR PETITION 11

NAME AND ADDRESS OF PETITIONER 13

THE SPECIFIC SECTIONS OF 14 C.F.R. FORM WHICH EAGLE EYE 14

INTELLIGENCE LLC SEEKS EXEMPTION

THE EXTENT OF RELIEF EAGLE EYE INTELLIGENCE, LLC SEEKS AND THE 17

REASON EAGLE EYE, INTELLIGENCE, LLC SEEKS RELIEF

THE REASONS WHY GRANTING EEI, LLC REQUEST WOULD 19

BE IN THE PUBLIC INTEREST

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 21

ADVERSELY AFFECT SAFETY

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 49

ANY ADDITIONAL INFORMATION, VIEWS OR ARGUMENTS AVAILABLE

TO SUPPORT REQUEST 49

CONCLUSION 49
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GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC 

ATO

AV 

C.F.R. 

COA 

FAA 

FAR

GCS

GPS

HUD

LOL 

NAS 

NOTAM 

PIC

Section 

SP

333 SOP

UA 

UAS 

VFR 

VLOS 

VMC 

VO

VTOL

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization 

Aerial Vehicle

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station

Global Positioning System

Heads Up Display

Loss of Link

National Airspace System 

Notice to Airman

Pilot in Command

FAA Modernization and Reform Act of 2012 (FMRA) Section 

Supplemental Pilot

333 Standard Operating Procedures

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions 

Visual Observer

Vertical Takeoff and Landing
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SUMMARY

Eagle Eye Intelligence, LLC seeks exemption from the requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate Unmanned Aircraft Systems pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Eagle Eye 

Intelligence, LLC to operate Unmanned Aircraft Systems (UAS) under strict protocols for the

purpose of conducting training, security, concept development and Personal Safety Device 

(PSD) support flights in the United States in compliance with conditions and limitations the 

FAA has included in standard exemptions under section 333. We accordingly seek summary 

processing of this petition and thus the FAA need not publish a summary of this petition in the 

Federal Register or seek public comment.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Eagle Eye Intelligence, LLC (hereinafter referred to as “EEI”) is a technology company 

that provides security and law enforcement agencies with advanced technology to, “Protect 

Property and Save Lives”. We intend to pursue federal, state, local, and commercial clients.

EEI is focused on providing solutions for utilizing unmanned aircraft to safely and efficiently

provide situational awareness and safety enhancements to its customers utilizing Unmanned 

Aircraft where appropriate.

As set forth in this Petition, EEI seeks to commercially operate its listed aircraft (Exhibit 

1) over certain areas of the United States for the purpose of conducting training, security, 

concept development and Personal Safety Device (PSD) support flights.
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BACKGROUND

Unmanned Aircraft System: EEI Merlin UAS

 EEI seeks an exemption to operate the EEI Merlin UAS (see Figure 1) for 

compensation or hire within the National Airspace System (NAS). The Merlin UAS is 

built by EEI from commercially available parts and is comprised of a Fixed Wing 

Unmanned Aircraft (UA) and a Ground Control Station (GCS). The Merlin UA has a 

maximum gross weight of 30 pounds, a wingspan of 102 inches, Nose to Tail is 77 

inches, and maximum speed of 100 mph. The Merlin UA is equipped with a single 

propeller, driven by a Lithium Polymer battery powered electric motor.

 The Merlin UA that will be operated by EEI will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, 

and marked in accordance with 14 C.F.R. Part 45, Identification and Registration

Marking. If processing is after 31 March 2016, EEI will comply with Part 48 electronic 

registration requirements.

 Figure 1: The Merlin UA.
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Unmanned Aircraft System: Lockheed Martin Indago LE

 EEI seeks an exemption to operate the Lockheed Martin Indago LE UAS

(see Figure 2) for compensation or hire within the NAS. The Lockheed Martin LE UAS 

is a Quadcopter Unmanned Aircraft and a Ground Control Station (GCS). The 

Lockheed Martin LE UA has a maximum gross weight of approximately 4.85 pounds

and a maximum speed of 30 mph. The Lockheed Martin Indago LE UA is driven by a

Lithium Polymer battery powering 4 electric motors.

 The Lockheed Martin Indago LE that will be operated by EEI will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification

and Registration Marking. If processing is after 31 March 2016, EEI will comply with 

Part 48 electronic registration requirements.

 Figure 2: The Lockheed Martin Indago LE
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Unmanned Aircraft System: 3DR DIY Quadcopter

 EEI seeks an exemption to operate the 3DR DIY Quad UAS (see Figure 3) for 

compensation or hire within the NAS. The 3DR DIY Quad is a Quadcopter UA and a

GCS. The 3DR DIY Quad UA has a maximum gross weight of approximately 5.5

pounds and a maximum speed of 30 mph. The 3DR DIY Quad UA is driven by a

Lithium Polymer battery powering 4 electric motors.

 The 3DR DIY Quad that will be operated by EEI will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and

Registration Marking. If processing is after 31 March 2016, EEI will comply with Part 48 

electronic registration requirements.

Figure 3: The 3DR DIY Quad
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Unmanned Aircraft System: Phoenix 30 Quadrotor

 EEI seeks an exemption to operate the Phoenix 30 Quadrotor UAS (see Figure 4) for 

compensation or hire within the NAS. The Phoenix 30 Quadrotor is a multi-rotor

Unmanned Aircraft and a GCS. The Phoenix 30 Quadrotor UA has a maximum gross 

weight of 12 pounds and a maximum speed of 30 mph. The Phoenix 30 Quadrotor UA

is driven by a Lithium Polymer battery powering 4 electric motors.

 The Phoenix 30 Quadrotor that will be operated by EEI will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification

and Registration Marking. If processing is after 31 March 2016, EEI will comply with 

Part 48 electronic registration requirements.

 Figure 4: Phoenix 30 Quadrotor
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Unmanned Aircraft System: Latitude HQ-40 Hybrid Quadrotor

 EEI seeks an exemption to operate the Latitude HQ-40 Hybrid Quadrotor UAS (see 

figure 5) for compensation or hire within the National Airspace System (NAS). The 

Latitude HQ-40 Hybrid Quadrotor is a multi-rotor / fixed wing Unmanned Aircraft (UA) 

and a Ground Control Station (GCS). The Latitude HQ-40 Hybrid Quadrotor UA has a 

maximum gross weight of 42 pounds and a maximum speed of 80 knots. The Latitude 

HQ-40 Hybrid Quadrotor UA is driven by a Lithium Polymer battery powering 4 electric

motors and a 4-cycle reciprocating engine for forward flight.

 The Latitude HQ-40 Hybrid Quadrotor that will be operated by EEI will be registered 

in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 

47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. If processing is after 31 March 2016, EEI will 

comply with Part 48 electronic registration requirements.

Figure 5: Latitude HQ-40 Hybrid Quadrotor
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Unmanned Aircraft System: Latitude MC 120 Microcopter

 EEI seeks an exemption to operate the Latitude MC 120 Microcopter UAS (see 

Figure 6) for compensation or hire within the National Airspace System (NAS). The 

Latitude Microcopter is a multi-rotor Unmanned Aircraft (UA) and a Ground Control 

Station (GCS). The Latitude Microcopter UA has a maximum gross weight of .26 

pounds and a maximum speed of 30 mph. The Latitude Microcopter UA is driven by a

Lithium Polymer battery powering 4 electric motors. The Latitude Microcopter is still 

under development and first flights are due in early 2016.

 The Latitude Microcopter that will be operated by EEI will be registered in

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47,

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification

and Registration Marking. If processing is after 31 March 2016, EEI will comply with 

Part 48 electronic registration requirements.

 Figure 6: Latitude MC 120 Microcopter (Prototype)
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BASIS FOR PETITION

Petitioner, EEI, LLC Inc., by and through undersigned counsel, pursuant to the 

provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization 

and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator to operate EEI listed aircraft in the NAS, and for an 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, EEI’s operation of UAS’s meets the conditions of 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H, with regard to Part 23 and 27 as appropriate. Accordingly, EEI

requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b), as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. EEI submits that the requested relief is proper since an equivalent 

level of safety will be ensured. EEI, will use at minimum FAA certified pilots to operate the 

aircraft. In addition, EEI will use FAA qualified technicians to perform supervision of 

maintenance, alterations, or preventive maintenance on EEI listed UAS’s using the methods,

techniques, and practices prescribed in EEI’s General Operations Manual Section 7

“Maintenance” (see attachment F) and following FAA maintenance procedures and principles 

whenever appropriate. Furthermore, EEI will document and maintain all maintenance records 

for each UAS it operates. Maintenance of the listed UAV’s will be accomplished by the 

owner/operator pursuant to the Training/Maintenance manuals, such as provided in the 

attachments. EEI will follow the Manufactures User guides as a reference document in 

conjunction with the Maintenance protocol established in the EEI General Operations Manual 

section 7 “Maintenance”. Relief from certain requirements of Section 61.113(a) and (b), 

entitled Private pilot privileges and limitations: Pilot in command, is requested by EEI to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot certificate and a

second-class airman medical certificate, and who has completed the UAS training and 

currency requirements, to conduct the proposed UAS operations. EEI submits that the 

conditions and limitations set forth herein will ensure the safety of the NAS, as well as the

safety of persons or property on the ground.

 

EEI seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, because

EEI’s listed UAS’s do not require an airworthiness certificate in accordance with 14 C.F.R.Part 

21, Subpart H, with regard to Part 23 and 27 as appropriate. As such, EEI submits that it will

ensure that the EEI listed UAS’s are in an airworthy condition, prior to every flight, by

determining that the UAS is in compliance with the UAS specific Operators Manual including 

the PIC’s pre-flight safety review, (see Attachment B) performance of all scheduled 

maintenance, and the restriction of all flights to VLOS and Visual Flight Rules (VFR) 

conditions.
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EEI also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as all EEI listed UAS’s are equipped with a barometer and Global 

Positioning System (GPS) equipment, which ensures that a ground level pressure setting will

be established prior to each flight. The UAS’s barometer and GPS equipment ensure safety by

providing the PIC with adequate information concerning altitude of the UAS, above ground

level (AGL), as shown on the heads-up display of the GCS.

Additionally, EEI seeks an exemption from the requirements of Section 91.151(b),

Fuel requirements for flight in VFR conditions. EEI request this exemption because it relies

mainly upon battery power rather than fuel. Depending upon the model used, the batteries 

necessary to power the UAS allow for the durations listed as follows: 

a. EEI submits that safety will not be affected by terminating flights of the battery

powered Merlin UA after approximately 90 minutes of continuous flight with at least 

20 percent of battery power remaining.

b. EEI submits that safety will not be affected by terminating flights of the battery

powered Lockheed Martin Indago LE after approximately 45 minutes continuous 

flight with at least 20 percent of battery power remaining. 

c. EEI submits that safety will not be affected by terminating flights of the battery 

powered 3DR DIY Quad after approximately 20 minutes of continuous flight with at

least 20 percent of battery power remaining.

d. EEI submits that safety will not be affected by terminating flights of the gasoline

powered Latitude Engineering HQ-40 Hybrid UAS after approximately 4 hours and 

30 minutes of continuous flight with at least 30 minutes of endurance remaining.

e. EEI submits that safety will not be affected by terminating flights of the battery 

powered Latitude Engineering MC 120 after approximately 10 minutes of continuous 

flight with at least 20 percent of battery power remaining.
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In accordance with 14 C.F.R. § 11.81, EEI provides the following information in

support of its petition for exemption:

A. Name and Address of the Petitioner.

The name and address of the Petitioner is:

Eagle Eye Intelligence, LLC

1001 Broken Sound Parkway NW, Ste C

Boca Raton, Florida 33487

The point of contact for this Petition and specific contact information is as follows:

Dean Attridge

Director of Flight Operations

Eagle Eye Intelligence, LLC

Boca Raton, Florida 33487

dattridge@eagleeyeintelligence.com

702.755.9825

EEI submits several attachments with this request:

Attachment A - EEI Training Manual

Attachment B - PIC Pre-flight Safety Review

Attachment C - Lockheed Martin Procerus Technologies Indago User Guide and Kestrel 

Autopilot System User Guide

Attachment D - EEI Merlin User Guide

Attachment E - EEI 3DR DIY User Guide

Attachment F - EEI General Operations Manual Section 7

Attachment G - UAV Solutions Phoenix 30 User Guide

Attachment H - Latitude MC 120 Microcopter User Guide 

Attachment I - Latitude HQ 40 User Guide

Because the manuals are proprietary information, EEI requests confidential treatment per 14 

CFR. §11.35(b) and protection from release under the Freedom of Information Act.
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B. The Specific Sections of 14 C.F.R. From Which EEI Seeks Exemption.

1. EEI Seeks Exemption From The Requirements Of Section

61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in part:

(a) No person who holds a private pilot certificate may act as a pilot 

in command (PIC) of an aircraft that is carrying passengers or

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

compensation or hire, act as PIC of an aircraft.

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

2. EEI Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. EEI Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

relevant part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the

route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an

appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the 

elevation of the departure airport or an appropriate altimeter

setting available before departure.
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4. EEI Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following:

(b) 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, to fly after 

that for at least 30 minutes.

5. EEI Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) 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[.]

6. EEI Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration 

unless--

(1) It has been approved for return to service by a person 

authorized under § 43.7 of this chapter.

7. EEI Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may

operate an aircraft unless, within the preceding 12 calendar months, it has 

had --

(1) An annual inspection in accordance with part 43 of this 

chapter and has been approved for return to service by a

person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter (with regard to Part 23 and 

27 as appropriate).
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8. EEI Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving

the aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time 

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) 

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date.

If the AD or safety directive involves recurring action, the time and 

date when the next action is required.
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(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for 

each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall 

be retained until the work is repeated or superseded by other work 

or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section 

shall be retained and transferred with the aircraft at the time 

the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator 

under § 43.11 of this chapter shall be retained until the defects 

are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief EEI Seeks And The Reason EEI Seeks The Relief.

1. Extent of Relief EEI Seeks And The Reason EEI Seeks Relief

From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b), entitled Private pilot privileges and limitations:

Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot

certificate and a second-class airman medical certificate, and who has completed the EEI 

training and currency requirements, to conduct the proposed UAS flight operations for

compensation.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state

that a private pilot may, for compensation or hire, act as PIC 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.

As set forth more fully below, EEI submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate EEI UAS’s unless that PIC has

demonstrated, through the Type specific UAS training and currency requirements, that the PIC 

is able to safely operate the EEI UAS in a manner consistent with the operations specifications 

as described in this exemption, including evasive and emergency maneuvers, as well as 

maintaining appropriate distances from people, vessels, vehicles and structures.

Further, EEI submits that all flights of EEI UAS’s are conducted by the PIC pursuant to 

the grant of this Petition (1) will be incidental to EEI’s business; and (2) will not carry

passengers or property for compensation or hire.
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2. Extent of Relief EEI Seeks And The Reason EEI Seeks Relief

From Section 91.7(a).

Relief from Section 91.7(a), entitled Civil aircraft airworthiness, is requested to the

extent required to allow EEI to determine that each UAS is in an airworthy condition prior to 

every flight by ensuring that each UAS is in compliance with their respective Operators

Manual/Users Guide, and that the UAS is in condition for safe flight. Copies of the manual,

which contain proprietary information, are attached here to as Attachments C, D, E, G, H and I

are to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) .

EEI seeks the requested relief because the listed UAS’s do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H with regard to Part 23 and 27 as 

appropriate. Therefore, EEI will ensure that the EEI UAS’s are in an airworthy condition based

upon its compliance with the operating documents prior to every flight, and as stated in the 

conditions and limitations below.

3. Extent of Relief EEI Seeks And The Reason EEI Seeks Relief From

Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight

operations of EEI UAS’s which utilizes a barometer and GPS equipment, to ensure that a 

ground level pressure setting will be established prior to each flight, in order to report altitude 

to the PIC. EEI seeks the requested relief because the EEI UAS’s do not utilize a typical 

barometric altimeter onboard that may be set as contemplated by Section 91.121. As more

fully set forth below, an equivalent level of safety will be maintained since EEI UAS’s are

equipped with a barometer and GPS equipment, which will ensure that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude information of

the UA, above ground level (AGL), on the heads-up display of the ground control station 

(GCS).

4. Extent Of Relief EEI Seeks And The Reason EEI Seeks Relief From

Section 91.151(b).

Relief from Section 91.151(b), entitled Fuel Requirements for flight in VFR conditions, 

is requested to the extent required to allow flights of EEI’s battery powered UAS’s during

daylight hours in visual meteorological conditions under visual flight rules (VFR), to continue

for the following duration:

Merlin UAS – approximately 60 minutes.

Lockheed Martin Indago LE – approximately 45 minutes.

3DR DIY Quad – 20 minutes.

Phoenix 30 Quadrotor – 25 minutes

Latitude Engineering MC 120 – 10 minutes.

Latitude Engineering HQ-40 – Able to comply with 91.151(b).
19

This will ensure that the UA will land with 20 percent of endurance remaining. EEI

seeks the requested relief, because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered UAS’s will severely constrain the practicality of conducting 

training, security, concept development and PSD support flights, which EEI proposes to 

conduct pursuant to this Petition. Significantly, as set forth in the supporting documentation 

attached, the technical specifications of each EEI UAS and their associated Operations

Manual / Users Guide, and EEI’s proposed operating limitations, ensure that EEI will safely

operate the battery powered UAs during daylight hours in VFR conditions for a total flight 

duration not to exceed 80% of the battery power with 20 percent of battery power remaining

after landing.

5. Extent Of Relief EEI Seeks And The Reason EEI Seeks Relief From

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &

(b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, EEI requests relief from these Sections

because EEI UAS’s do not have an airworthiness certificate. As set forth more fully below, EEI 

UAS’s meet the conditions of Section 333 of the FMRA for operation without an airworthiness 

certificate. Accordingly, EEI will use qualified technicians and certificated Private Pilots to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the EEI General Operation Manual section 7 

“Maintenance” (see Attachment F). EEI will follow the Manufacturers User guides as a 

reference document in conjunction with the Maintenance protocol established in the EEI 

General Operations Manual Section 7 “Maintenance”. Furthermore, EEI will document and 

maintain all maintenance records for each UAS it operates.

D. The Reasons Why Granting EEI’s Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing EEI to

safely, efficiently, and economically perform commercial training, security, concept 

development and PSD support over areas of the United States.

i. Training.

ii. Commercial Security Operations.

iii. Security Concept Development for US and International security requirements.

iv. Personal Safety Device (PSD) support.
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These operations will provide significant benefits to US public security and safety by 

providing enhanced situational awareness, improved risk and threat management, minimizing 

operating costs and reducing response times.

1. The Public Will Benefit From The Training, Concept Development, and 

Security Performed.

EEI submits this Petition to commercially operate the listed UAS’s to conduct 

commercial security, training and international security concept development flights throughout

areas of the United States. EEI UAS’s will provide safe, efficient, and economical training and 

security to further each of these fields, all of which are critical to the well-being of the general 

public.

In government training, the listed UAS will be used to provide government agency 

training to support their CoA applications and Public Use concept development studies, 

available to them outside of their jurisdiction. This will allow government entities increased 

access to training, shared training facilities, standards and operating procedures. This will 

allow efficiencies to be realized to these agencies, increasing safety and security to the public.

As Commercial Security Services UAS flights EEI will conduct flights to integrate UAS 

into commercial security operations, providing additional security options to commercial 

security companies.

In Security Concept Development, EEI will develop services and equipment to offer 

International Commercial Security Services (such as oil and gas industry) to enable use of UAS 

to increase security operations. Development of these concepts will increase stability and 

security to foreign countries’ infrastructure and citizens.

For Personal Safety Device (PSD) support, these commercial flights would benefit 

public safety by allowing rapid detection and location of persons equipped with personal safety 

location devices. These radio based devices can be detected from the elevated UAS (max 

400ft) over greater ranges than traditional detection means and with greater flexibility, allowing 

rapid location and thus saving lives. Typical examples would the location of those likely to 

wander (Alzheimer and Autism) or those persons likely to be missing over land or sea.

 

The specific operations that EEI will perform with the listed UAS, demonstrate how the 

requested exemption will directly benefit the above-referenced industries and the public.

2. The Public Will Benefit From The Safety And Efficiency Of EEI UAS’s.

Conducting training, security, concept development and PSD support with EEI UAS’s

instead of manned aircraft, will greatly benefit the public by reducing the levels of air and noise 

pollution generated during traditional manned aerial flight operations. By using battery power 

and electric motors, the smaller UAS have no air pollution, and are the most viable 

environmentally conscious alternative to helicopter or fixed wing manned aircraft. The listed 

UAS can all operate while reducing the carbon footprint of aerial support and reduced noise 

pollution. By using the UAS to perform training, security, concept development and PSD 

support flights, the substantial risk to life and property in the air and on the ground, which is

usually associated with traditional manned aircraft flight operations, will be substantially

reduced or completely eliminated. Notwithstanding from the lack of flight crew members 

located onboard the aircraft, the UAS’s (weighing less than 55 pounds), have less physical 
21

potential for collateral damage to life and property on the ground, and in the air, compared to 

the manned aircraft that typically conduct aerial security.

3. Performing The training, security, concept development and PSD support

Performed With EEI UAS’s Will Benefit The Economy.

In addition to being safe and efficient, EEI UAS’s are also an economical alternative to 

using manned aircraft to conduct similar aerial services. As such, operation of UAS’s will allow

United States based companies, like EEI, to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. The listed UAS operate such technologies that not only allow companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. By operating the listed UAS, companies such 

as EEI can remain competitive and profitable, and therefore, provide greater job stability to

employees and contractors, which will ultimately contribute to growth of the U.S. economy.

Improved financial performance of U.S. companies, through commercial use of the UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and 

federal tax revenues; and allows companies to invest in research and development in order to 

remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial flight operations that have been conducted for

decades, EEI’s proposed operation of UAS’s will not implicate any privacy issues. Specifically, 

the listed UAS will be operated primarily in private secure areas, and in accordance with all 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119. Most significantly, EEI’s UAS’s will not be operated closer than 500 feet to any

person, vessel, vehicle, or structure, which is not directly involved in the operation.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect

Safety, Or How The Exemption Would Provide A Level Of Safety At Least

Equal To That Provided By The Rule From Which EEI Seeks Exemption.

1. Reasons Why EEI’s UAS’s Meet The Conditions Of The FAA

Modernization And Reform Act Of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, EEI’s operation of the listed UAS, meets the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H, with regard to Part 23 and 27 as appropriate. Section 333

provides authority for a UAS to operate without airworthiness certification and sets forth 

requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states 

the following, in part:
22

(a) In General. --Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may operate

safely in the national airspace system before completion of the plan and

rulemaking required by section 332 of this Act or the guidance required by section

334 of this Act.

(b) Assessment of Unmanned Aircraft Systems. --In making the

determination under subsection (a), the Secretary shall determine, at a

minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create a

hazard to users of the national airspace system or the public or pose a

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United States

Code, is required for the operation of unmanned aircraft systems identified

under paragraph (1).

(c) Requirements for Safe Operation. --If the Secretary determines under this

section that certain unmanned aircraft systems may operate safely in the

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

operation of such aircraft systems in the national airspace system.

In seeking this exemption, EEI submits that the listed UAS, can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 

each UAS; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The Merlin UAS To Demonstrate Its

Safe Characteristics.

The Merlin UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications Of The Merlin UAS.

Unmanned 

Aircraft System

The Merlin is an Unmanned Aircraft System that is comprised 

of fixed wing unmanned aircraft and a transportable ground

control station.
23

Unmanned 

Aircraft 

Dimensions

Wing Span: 102 inches 

Nose to Tail: 77 inches

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

Manufacturer - Scorpion P/N:SII-4035-250(Electric) 

FAA Engine Type Cert: None

Propulsive Unit Type: 3.6 hp Peak Power Direct Drive

Weight – 15.87oz

Max RPM – 12,600

Motor, Electric Sub-Assembly:

Manufacturer: Castle Creations

Model: Castle Talon HV120

Part Number: CSE010013100

Type: Electronic Speed Controller 120amps

Weight – 6.56oz

Fuel Not Applicable.

NOTE: The Merlin UAS is powered by 4 Lithium Polymer

rechargeable batteries, P/N HC30C

Propeller and 

Propeller

Limits

FAA Propeller Type Certificate: None

Propeller Type: One 2-blade, Beechwood, fixed pitch, tractor

Manufacturer: Xoar

Model: 1506

Diameter (Nominal): 19 in.

Battery Command

& Control 4 Turnigy Multistar Batteries P/N HC30C power the motors, 

and command and control.

Capacity – 4S 14.8V 10,000 mAh

Temperature: -30° / +120° F

NOTE: The motor temperature is not displayed 

to the operator.

Weight – 804g

Dimensions – 160mm x 65mm x 36mm

Max Charge – 2C (22 Amps)

Max Discharge – 10C (110)

Airspeed Limits Vne (Never Exceed Speed) 100 knots 
24

Empty Weight 

C.G. Range

34.75”

Datum Nose of Aircraft

Maximum Weights Ramp 30 lbs. 

Takeoff 30 lbs. 

Landing 30 lbs.

Empty Weight 14.85 lbs.

NOTE: Empty weight excludes weight of batteries 

and payload modules.

Frequencies 902-928 MHz (ISM Band) 

1.3 GHz (ISM Band)

2.4 GHz (ISM Band)

5.8 GHz (ISM Band)

Computer Software Avionics embedded processor

Minimum Crew 1- EEI Merlin UAS can be operated by a single operator

accompanied by a visual observer.

Number of Seats 0- Not Applicable.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 400 ft. AGL

Rotor Blade and 

Control Movements

Fixed Rotor Control. Vehicle control is achieved through 

varying thrust of each motor individually.
25

Nominal Endurance 60 minutes with 200g payload

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: -30 °F (-34 °C)

Wind Limitation 25 mph

Maintenance This EEI Merlin UAS must be maintained in accordance with 

the manufacturer’s Users Guide, or later FAA accepted 

revision.

b. The Specifications Of The Lockheed Martin Indago LE

Demonstrate Its Safe Characteristics.

 The Lockheed Martin Indago LE does not create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications of the Lockheed Martin Indago LE.

Unmanned 

Aircraft System

The Lockheed Martin Indago LE is an Unmanned Aircraft 

System that is comprised of a vertical takeoff and landing

(VTOL) unmanned aircraft and a transportable ground control

station.

Unmanned 

Aircraft 

Dimensions

Diameter: 42 inches 

Rotor span: 16.25 inches

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

4 Electric Motors

Fuel Not Applicable.

NOTE: The Lockheed Martin Indago LE is powered by

1 Lithium-polymer rechargeable battery EEI S/N 0290, 0294.
26

 Battery

Capacity: 4s 11,000 mAh (162.8 Wh)

Maximum Operating Voltage: 16.8V

Minimum Operating Voltage: 13.8

Temperature: -30° / +120° F Dimensions – 7 x 2.5 x 1.875 in

Max Charge – 2C (22 Amps) Max Discharge – 5C (55

Amp mps)

Duration in Minutes display on Hand Controller

Propeller (4) EEI Inc. P/N 3590

FAA Propeller Type Certificate: None

Propeller Type: Four 2 blade (foldable), carbon fiber, fixed 

pitch, tractor

Propeller Assembly Manufacturer: 

Lockheed Martin Propeller 

Diameter (Nominal): 16.25 in.

Airspeed Limits Max Cruise Speed 30 mph

Empty Weight 

C.G. Range

Centroid of Vehicle / no adjustable limits

Datum Centroid of Vehicle

Maximum Weights Ramp 4.9 lbs. 

Takeoff 4.9lbs. 

Landing 4.9 lbs.

Empty Weight 2.57 lbs.

NOTE: Empty Weight Excludes weight of batteries and 

payload modules.

Frequencies 900 MHz (ISM Band)

1.3 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on the 900Mhz band. If 

video is utilized, uplink, downlink, and video are all on 1.3 

GHz.
27

Computer Software Avionics embedded processor

Handcontroller – Quad Core 1.2 GHz Processor

Minimum Crew (1) The Lockheed Martin Indago LE can be operated by a

single operator.

Number of Seats (0) Not Applicable.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 400 ft. AGL

Rotor Blade and 

Control Movements

Fixed Rotor Control. Vehicle control is achieved through 

varying thrust of each motor individually

Nominal Endurance 45 minutes with 200g payload

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: -30 °F (-34 °C)

Wind Limitation 25 mph

Maintenance This Lockheed Martin Indago LE must be maintained in 

accordance with the manufacturer’s Users Guide, or later FAA 

accepted revision.
28

c. The Specifications Of The EEI 3DR DIY Quad UAS 

Demonstrate Its Safe Characteristics.

The EEI 3 DR DIY Quad does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications of the 3DR DIY Quad UAS.

Unmanned 

Aircraft System

The 3DR is an Unmanned Aircraft System that is comprised 

of a Quadrotor unmanned aircraft and a transportable ground

control station.

Unmanned 

Aircraft 

Dimensions

13.7 in x 20.1 in x 11.8 in 

(35 cm x 51 cm x 20 cm)

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

Manufacturer – 3DR 880 KV AC2836-358 motors

FAA Engine Type Cert: None

Propulsive Unit Type: Peak Power Direct Drive

Weight – 72 gr

Max RPM//V – 880 KV

Motor, Electric Sub-Assembly:

Manufacturer: 3DR

Model: AC2836-358

Type: Electronic Speed Controller 20amps

Fuel Not Applicable.

NOTE: The 3DR DIY Quad is powered by a Lithium Polymer

rechargeable batteries, P/N 3S-8000 RMRC

Propeller and 

Propeller

Limits

FAA Propeller Type Certificate: None

Propeller Type: 4 – 2 blade fixed pitch propellers

Manufacturer: 3DR

Model: SF and SFP

APC: 10 x 4.7
29

Battery Command

& Control

1 ReadyMade RC Batteries (P/N 3S-8000 RMRC) 3S1P 

11.1V power the motors, and command and control.

Capacity – 3S 11.1V 8,000 mAh

Temperature: -30° / +120° F

NOTE: The motor temperature is not displayed 

to the operator.

Weight – 560g

Dimensions – 1900mm x 52mm x 25mm

Max Charge – 1C (8 Amps)

Max Discharge – 70C (560)

Airspeed Limits N/A

Empty Weight 

C.G. Range

Centroid of Vehicle

Datum Centroid of Vehicle

Maximum Weights Ramp 6 lbs. 

Takeoff 6 lbs. 

Landing 6 lbs.

Empty Weight 3 lbs. 1oz.

NOTE: Empty Weight Excludes weight of batteries 

and payload modules.

Frequencies 902-928 MHz (ISM Band) 

1.3 GHz (ISM Band)

2.4 GHz (ISM Band)

Computer Software Avionics embedded processor

Minimum Crew 1- EEI 3DR Quad UAS can be operated by a single operator 

accompanied by a visual observer.

Number of Seats 0 - Not Applicable.

Fuel Capacity Not Applicable.
30

Oil Capacity Not Applicable.

Max. Operating Altitude 400 ft. AGL

Nominal Endurance 20 minutes No payload

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 120 °F (49 °C)

Minimum OAT At Altitude: -30 °F (-34 °C)

Wind Limitation 25 mph

Maintenance This 3DR DIY Quad UAS must be maintained in accordance 

with the manufacturer’s Users Guide, or later FAA accepted 

revision.

d. The Specifications Of The Latitude HQ-40 UAS

Demonstrate Its Safe Characteristics.

 The Latitude HQ40 UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications Of The Latitude HQ40.

Unmanned 

Aircraft System

The Latitude HQ40 is a Hybrid Quadrotor / fixed wing 

Unmanned Aircraft System and a transportable ground control

station.

Unmanned 

Aircraft 

Dimensions

Wing Span: 99.25 inches

Nose to Tail: 35 inches
31

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

Manufacturer – Honda GX 4 stroke 35cc

1.6 hp engine / onboard Generator

FAA Engine Type Cert: None

Weight – 15.87oz

Electric: Manufacturer – Hacker A60 Brushless DC motors

1500 watt motor

Current Draw – 95 Amps Max

Fuel Unleaded Gas 

NOTE: The Latitude HQ40 Quadrotors are powered by 2

Lithium Polymer rechargeable batteries

Propeller and 

Propeller

Limits

FAA Propeller Type Certificate: None

Propeller Type: One 2-blade, fixed pitch, tractor

Manufacturer: Latitude

Model: N/A

Diameter (Nominal): 

Battery Command

& Control

4 Turnigy Multistar Batteries P/N HC30C power the motors, 

and command and control.

Capacity – 4S 14.8V 10,000 mAh

Temperature: -30° / +120° F

NOTE: The motor temperature is not displayed 

to the operator.

Weight – 804g

Dimensions – 160mm x 65mm x 36mm

Max Charge – 2C (22 Amps)

Max Discharge – 10C (110)
32

Airspeed Limits Cruise 38 kts / Max 80 kts 

Empty Weight 

C.G. Range

Datum

Maximum Weights Ramp 42 lbs. 

Takeoff 42 lbs. 

Landing 42 lbs.

Empty Weight 30 lbs.

NOTE: Empty Weight Excludes weight of batteries 

and payload modules.

Frequencies 902-928 MHz (ISM Band) 

1.3 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on the 900MHz

band. If video is utilized, uplink, downlink, and video are 

all on 1.3 GHz.

Computer Software Avionics embedded processor

Minimum Crew 1- Latitude HQ40 can be operated by a single operator.

Number of Seats 0- Not Applicable.

Fuel Capacity 100 ounces
33

Oil Capacity 3 ounces

Max. Operating Altitude 400 ft. AGL

Rotor Blade and 

Control Movements

Fixed Rotor Control. Vehicle control is achieved through 

varying thrust of each motor individually

Nominal Endurance 5 hours

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 104 °F

Minimum OAT At Altitude: 23 °F

Wind Limitation 30 kts

Maintenance This Latitude HQ40 must be maintained in accordance with 

the manufacturer’s Users Guide, or later FAA accepted 

revision.
34

e. The Specifications Of The Latitude MC-120 UAS

Demonstrate Its Safe Characteristics.

The Latitude MC-120 UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications of The Latitude MC-120.

Unmanned 

Aircraft System

The Latitude MC-120 is a Microcopter Unmanned Aircraft 

System and a transportable ground control station.

Unmanned 

Aircraft 

Dimensions

86mm x 141 x 59

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

Manufacturer – Latitude – 4 brushless electric 

motors with electronic speed controllers

FAA Engine Type Cert: None

Weight – TBD

Fuel NOTE: The Latitude MC-120 Quadrotors are powered by 1

Lithium Polymer rechargeable battery

Propeller and 

Propeller

Limits

FAA Propeller Type Certificate: None

Propeller Type: Four 2-blade, fixed pitch, tractor

Manufacturer: Latitude

Model: N/A

Diameter (Nominal): 
35

Battery Command

& Control

2 Cell 470 mAh LiPo Battery

NOTE: The motor temperature is not displayed 

to the operator.

Weight –

Dimensions -

Max Charge –

Max Discharge –

Airspeed Limits Max 33mph 

Empty Weight 

C.G. Range

Datum

Maximum Weights Ramp .26 lbs. 

Takeoff .26 lbs. 

Landing .26 lbs.

Empty Weight

Frequencies 902-928 MHz (ISM Band) 

2.4 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on the 900MHz

band. If video is utilized, uplink, downlink, and video are 

all on 2.4 GHz.

Computer Software Avionics embedded processor
36

Minimum Crew 1- Latitude MC120 can be operated by a single operator.

Number of Seats 0- not Applicable.

Fuel Capacity N/A

Oil Capacity N/A

Max. Operating Altitude 400 ft. AGL

Rotor Blade and 

Control Movements

Fixed Rotor Control. Vehicle control is achieved through 

varying thrust of each motor individually.

Nominal Endurance 10 minutes

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 104 °F

Minimum OAT At Altitude: 23 °F

Wind Limitation

Maintenance This Latitude MC120 must be maintained in accordance with 

the manufacturer’s Users Guide, or later FAA accepted 

revision.
37

f. The Specifications of the Phoenix 30 Quadrotor 

demonstrate its Safe Characteristics.

The Phoenix 30 Quadrotor does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability.

I. Technical Specifications of the Phoenix 30 Quadrotor.

Unmanned 

Aircraft System

The Phoenix 30 is an Unmanned Aircraft System that is 

comprised of a vertical takeoff and landing (VTOL) unmanned 

aircraft and a transportable ground control station.

Unmanned 

Aircraft 

Dimensions

Length and width 42 x 42 

inches

Engine 

(Propulsive 

Unit)

Engine (Propulsive Unit)

Manufacturer: T-Motor / Model MN4014-9

400KV

4 Electric Motors

Fuel Not Applicable.

NOTE: The Phoenix 30 is powered by

1 Lithium-polymer rechargeable battery

 Battery Capacity: Tattu 6s 22,000 mAh 

(355.2 Wh)

Maximum Operating Voltage: 25.2V

Nominal Operating Voltage: 22.2

Temperature: -30° / +120° F

Weight – 1932g (4.4lb)

Dimensions – 180 x 74 x 65 mm

Max Charge – 16C 

Max Discharge – 15C 

Duration in Minutes display on Hand Controller

Airspeed Limits Max Cruise Speed 30 mph
38

Empty Weight 

C.G. Range

Centroid of Vehicle / no adjustable limits

Datum Centroid of Vehicle

Maximum Weights Ramp 12 lbs. 

Takeoff 12lbs. 

Landing 12 lbs.

Empty Weight 5.1 lbs.

NOTE: Empty Weight Excludes weight of batteries and 

payload modules.

Frequencies 900MHz (ISM Band)

2.4 GHz (ISM Band) 

Computer Software Avionics embedded processor

Handcontroller – Shuttle DS81

Minimum Crew (1) The Phoenix 30 can be operated by a single operator 

accompanied by a visual observer.

Number of Seats (0) Not Applicable.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 400 ft. AGL

Rotor Blade and 

Control Movements

Fixed Rotor Control. Vehicle control is achieved through 

varying thrust of each motor individually
39

Nominal Endurance 25 minutes with 2lb payload

Ambient Outside 

Air Temperature 

(OAT)

Maximum OAT: 100 °F (38 °C)

Minimum OAT At Altitude: 32 °F (0 °C)

Wind Limitation 25 mph

Maintenance This Phoenix 30 must be maintained in accordance with the 

manufacturer’s Users Guide, or later FAA accepted revision.

II. The Listed UAS, Autonomous Flight And

Navigation Modes.

A complete description of the autonomous modes and methods of navigation for the

listed UAS, is provided in the UAS specific Operations Manual1. A copy of each of these 

manuals Section which contain proprietary information, is attached and is to be held in a

separate file pursuant to 14 C.F.R. §11.35(b).

III. The Listed UAS, Are Designed For Complete Autonomy

From Launch To Landing Even In The Unlikely Event Of

Loss Of The Control Link Or Navigation.

Although a degradation or loss of the control link, and/or degradation or loss of the

source of navigation is unlikely, it is a situation that is well planned for and therefore, is a 

benign event. EEI’s UAS’s are designed for complete autonomy from launch to landing with a

line of sight operator in the loop monitoring the aircraft. The listed UAS all use a two-stage

failsafe approach for all avionics failure conditions, including the event of a loss of

communications (“Lost Link”). Upon loss of the communication signal, the listed UAS will 

attempt to re-acquire the link while maintaining the current altitude and navigating to the home 

waypoint, which is likely the same location as the ground station. Once at the home waypoint, 

the Merlin UA, Latitude HQ40, will orbit the area while the Lockheed Martin Indago LE, 3DR 

DIY Quad, Phoenix 30 and Latitude MC 120 will hover. Once at the home waypoint, the 

UAS’s will continue their attempt to re-acquire the link for a configurable amount of time 

(usually 10-30 seconds) to allow for rebooting of the ground station, if needed. The UAS’s will 

then continue to attempt to re-acquire the link while they navigate through the landing 

procedure. The landing procedure for Lost Link is identical to a normal landing procedure.

The Merlin UAS, Lockheed Martin Indago LE, Latitude HQ40, Phoenix 30, 3DR DIY Quad 

and Latitude MC 120 will enter into an auto-land procedure; descending while reducing speed 

until contact with the ground. During this decent and touchdown, all will remain in controlled 

flight.

1

Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), 

are not to be included in the Federal Docket Management System (FDMS).
40

Loss of GPS signal will result in a two-tiered recovery approach. Upon loss of a GPS

signal, the Merlin UA, Lockheed Martin Indago LE, Latitude HQ40, Phoenix 30, Latitude MC 

120, and 3DR DIY Quad will immediately hold position in an attempt to re-acquire a signal. If

after 15 seconds, a GPS signal is not re-acquired, the UA’s will enter tier-two recovery. At

any time during either tier-one or tier-two recovery, the operator can take over with 

augmented control and utilize its onboard magnetometer to navigate back to the home 

waypoint through dead-reckoning. During this failure mode, the observer will call out the UA 

position and movement back to the operator. Once the UAS is close enough to resolve 

orientation, or if operating with a live video payload, the operator can engage manual control 

and perform a manual landing at the pre-decided landing site.

If a cascade of failures has occurred and Lost-Link has also occurred during tier-two

recovery, the Merlin UA, Lockheed Martin Indago LE, Latitude HQ40, Phoenix 30, Latitude 

MC 120 and 3DR DIY Quad will enter into an auto-land procedure; descending while reducing

speed until contacting the ground. Throughout this decent and touchdown, the Merlin UA, 

Lockheed Martin Indago LE, Phoenix 30, Latitude HQ40, Latitude MC 120 and 3DR DIY 

Quad will remain in controlled flight. EEI is submitting the following documents in support of 

this Section (III) The Merlin UAS User Guide “Safety and Failsafes”. Lockheed Martin Indago 

LE User Guide at Chapter 6.8 “Emergency Procedures”. The 3DR DIY Quad User Guide 

“Safety and Failsafes”, Latitude HQ Manual pg 20, Latitude Microcopter MC 120 pg 12, which 

fully describes the features of each model, and sets forth the UAS’s operation in the event of

a power loss, loss of communications, loss of GPS signal, loss of video link, or software 

crash. Each copy the Operators Manual / Users Guides contains proprietary information, and 

is attached hereto as Exhibit A, and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b)2.

iv. The Merlin Ground Control Station and its Operation.

The EEI Merlin UA, Lockheed Martin Indago LE, Latitude HQ40, Latitude MC 120, 

Phoenix 30 and 3DR DIY Quad Ground Control Stations are similar. A complete 

description of the operation and specifications of each ground control station (GCS) 

and flight control software for the EEI UAS’s is provided in the attached aircraft 

Operating Manuals.

___________________________________

 2Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), 

are not to be included in the Federal Docket Management System (FDMS).
41

v. Safe Operation of EEI UAS

The EEI UAS may be safely operated by a Pilot-in-Command (PIC) supported by a 

Supplemental Pilot (SP) and/or visual a Visual Observer (VO).

EEI intends to use an internal and external pilot for flight operations. The PIC may be located 

in a vehicle with a SP and/or a VO remaining outside the vehicle with a clear line of sight to 

the aircraft as directed in FAA FSIMS 8900.1 Vol 16, Ch 5, Sec 3, Para 7. The crew (PIC and 

SP/VO) must remain in verbal contact throughout the flight by use of Cell Phone, Radio or 

Voice. Flights must be terminated if direct communication is lost between the two flight crew. 

EEI General Operations Manual at page 6.1-6.2 (Attachment F) describes additional 

limitations and requirements that apply to operations of the EEI UAS’s, including the following:

The vehicle must be organized and clear of any unnecessary debris and or 

distractors prior to the operation, to maintain a “sterile cockpit.”

Equipment and personnel positioning within the vehicle must be predetermined

and agreed upon by the crew. Each crew member must use appropriate safety

restraint equipment, and such equipment should not interfere with safe flight.

A copy of the EEI General Operation Manual Section 7, which contains proprietary

information, is attached hereto as Attachment F, and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b).

b. Flight Operations Of EEI UAS’s Are Limited To The Line

Of Sight Of A Certificated Pilot in Command With

A Safety Observer.

EEI will only utilize FAA certificated pilots who possess a valid Class II airman medical

certificate to act as a pilot in command (PIC) of the UAS’s. Additionally, a safety Visual

Observer (VO) will assist all pilots. Both the PIC and VO must complete the EEI

UAS Operators Course specific to airframe and meet the experience requirements as set 

forth in the EEI General Operation Manual. A copy of the applicable sections of the General 

Operations Manual, which contains proprietary information, is attached hereto as Attachment

F, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

c. Flights of EEI UAS’s Must Be Conducted Pursuant To

Specific Operating Limitations.

In seeking this exemption, EEI proposes to commercially operate UAS’s for the special 

purpose of conducting training, security, concept development and PSD support over the 

United States, pursuant to the following specific operating limitations:

1) Operations authorized by the grant of exemption must be limited to the 

following aircraft listed in (Exhibit 1). Proposed operations of any other aircraft will
42

require a new petition or a petition to amend the grant.

2) EEI UAS’s must not be flown at an indicated airspeed exceeding 90 knots.

3) EEI UAS’s must be operated at an altitude of no more than 400 feet above 

ground level (AGL) in COA approved areas and 200ft AGL elsewhere, all

altitudes reported to ATC must be in feet.

4) EEI UAS’s must be operated within visual line of sight (VLOS) of the Pilot in 

Command (PIC) at all times. Using human vision unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA-issued airman medical

certificate.

5) All operations must utilize a Visual Observer (VO). The VO must be used to 

satisfy the VLOS requirement, as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times.

The PIC must be designated before and during the flight. The PIC must ensure 

that the VO can perform the functions prescribed in the operating documents.

6) Supplemental pilots could be used to operate the UAS. These pilots must

be assigned UAS flight duties to augment the PIC for relief, however, the PIC 

retains complete and overall responsibility of the flight, regardless of who may 

be piloting the UAS. It is common for operators to have both an internal and an 

external UAS pilot. The supplemental pilot can assume either of these

positions. The supplemental pilot may also assume duties of the PIC if the 

specified qualifications are met as designated in Order 8900.1 Vol 16.

7) The operating documents and the grant of exemption 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 operating documents, the conditions and limitations in the grant of 

exemption take precedence and must be followed. Otherwise, the operator must

follow the procedures as outlined in its operating documents. The operator may

update or revise its operating documents. It is the operator’s responsibility to 

track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the operator will

petition for amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

8) Prior to each flight, the PIC 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 UAS is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 
43

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.

9) Any UAS 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. The PIC who conducts the functional test flight must make

an entry in the UAS aircraft record of the flight.

10) In addition to the pre-flight inspection section in the operating documents, the 

preflight inspection must also account for all discrepancies, i.e. inoperable

components, items, or equipment, not already covered in the relevant sections of 

the operating documents.

11) The operator must follow the manufacturer’s UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.

12) The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, and alterations must be noted in the aircraft logbook, including total 

flight hours, battery cycles, description of work accomplished, and the signature 

of the authorized UAS maintenance personnel or PIC returning the UAS to 

service.

13) EEI authorized maintenance personnel or PIC must make a record entry in 

the UAS logbook or equivalent document of the corrective action taken against 

discrepancies discovered between inspections.

14) EEI authorized maintenance personnel, PIC, and VO must receive and 

document training referenced in the operating documents.

15) The UAS operated under the exemption must comply with all manufacturer 

System and Safety Bulletins.

16) The PIC must possess at least a FAA-issued private pilot certificate and a 

valid FAA-issued class II airman medical certificate. The PIC must also meet the 

flight review requirements specified in 14 C.F.R. 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate.

17) Prior to operating for hire, the PIC, and VO must have successfully

completed EEI’s training syllabus as outlined in the operating documents. In 

addition, the PIC and VO must also have successfully completed annual 

(recurrent) training in accordance with the operating documents. A record of

training must be documented and made available upon request by the 

Administrator. Training, proficiency, and experience-building flights for the 

purpose of training pilots and VOs to conduct flights authorized by the exemption 

are permitted under the terms of the exemption.
44

18) If the UAS loses communications or loses its GPS signal, it must return to a 

pre-determined location within the planned operating area and land, or be 

recovered in accordance with the operating documents.

19) The PIC must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

20) The operator must obtain familiarity with the issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of 

exemption. The COA may also require the operator to request a Notice to

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation.

21) All UAS operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (NNumber) markings in accordance with 14 C.F.R Part 45, Subpart C.

22) Before conducting flight operations, the radio frequency spectrum used for 

operation and control of the UAS must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency

requirements.

23) The documents required under 14 C.F.R §§ 91.9 and 91.203 must be available 

to the PIC 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.

24) The UAS must remain clear and yield the right of way to all other aircraft 

operations and activities at all times.

25) If the UAS is operated from a moving device or vehicle, the operation must be 

in accordance with the operating documents.

26) UAS operations may not be conducted during night, as defined in 14 C.F.R. 

§ 1.1.

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

The UAS 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 PIC.

28) During operations in the National Airspace System, the UAS 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 as required by the operator’s COA. The letter of agreement with the 

airport management must be made available to the Administrator upon request.
45

29) The UAS may not be operated over congested or densely populated areas. 

These 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 PIC’s responsibility to maintain the minimum safe 

altitudes required by 14 C.F.R. § 91.119.

30) Operation of the UAS must be conducted at least 500 feet from all 

persons, vessels, vehicles, and structures not directly involved in the 

operation.

31) Operations of the UAS may be conducted at distances less than 500 feet from 

participating persons, vessels, vehicles or structures that perform an essential 

function in connection with the special purpose operations. Operations closer than 

500 feet from the PIC, VO, operator trainees and essential persons, are permitted 

when operationally necessary; but never so close as to present an undue hazard, 

per 14 C.F.R. § 91.119(a).

32) Operations of the UAS may be conducted at distances less than 500 feet from 

unoccupied vessels, vehicles or structures owned by the land owner/controller 

when the land owner/controller grants such permission and the PIC makes a 

safety assessment of the risk from operations closer to these objects.

33) All operations shall be conducted with permission from the land 

owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative must be obtained for each flight to be 

conducted.

34) 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 meeting the requirements of 49 C.F.R. Part 830 must be reported to the

National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov.

2. Reasons Why an Exemption from the Requirements of Section

61.113(a) and (b) Would Not Adversely Affect Safety.

EEI submits that an equivalent level of safety established by Section 61.113(a) and (b)

will be maintained because no PIC will be allowed to operate the UAS unless that PIC has 

demonstrated, through the type specific UAS training and currency requirements, that the PIC 

is able to safely operate the UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Considering EEI’s proposed area of operations and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 
46

necessary to safely operate the EEI UAS, EEI submits that the additional manned airmanship

experience of a commercially certificated pilot would not correlate to the airmanship skills

necessary for EEI’s specific proposed flight operations.

Additionally, the FAA has previously granted relief from Section 61.113(a) and (b)

specific to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112,11136, 11138).

As in Exemption No. 11109, EEI will not allow any PIC to operate the EEI UAS unless 

that PIC has demonstrated through the type specific UAS training and currency requirements 

that the PIC is able to safely operate the EEI UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

A complete description of the EEI UAS Training and Qualification requirements is set 

forth at pages 3-5 through 3-6 of the EEI General Operations Manual, attached hereto as 

Attachment F. Attachment F contains proprietary information and is to be held in a separate

file pursuant to 14 C.F.R. § 11.35(b).

3. Reasons Why an Exemption From The Requirements Of Section

91.7(a) Would Not Adversely Affect Safety.

The level of safety established by Section 91.7(a) will be maintained because prior to

every flight, EEI will ensure that the EEI UAS is in an airworthy condition and safe for flight 

based upon the EEI UAS’s compliance with its operating documents (e.g., the Lockheed 

Martin User Guide,) and as stated in the conditions and limitations herein. Additionally, the 

FAA has previously granted relief from Section 91.7(a), specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).

4. Reasons Why an Exemption From The Requirements Of Section

91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the EEI UAS is equipped with a digitally encoded barometric altimeter and GPS

triangulation equipment, with a zero altitude initiation point being established prior to each

flight. As such, the PIC on the EEI UAS is provided the altitude of the UA above ground level 

(AGL) via a heads-up display of the ground control station (GCS). Specifically, the PIC of the

EEI UAS is provided three different types of altitude information:

(1) Desired Altitude, indicating the commanded altitude, located at the top right corner of HUD

as well as above the HUD; (2) Altitude Above Ground Level (AGL), indicating actual altitude

relative to height above launch level on the ground, located in the center of the right side of 

the HUD; and (3) Climb Rate, indicating the current rate of climb, located in the center of the 

right side of the HUD. Accordingly, the PIC of the EEI UAS will be provided with all of the

necessary altitude information necessary to maintain safe operation of the UAS in the NAS.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138).
47

5. Reasons Why an Exemption from the Requirements of

Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure the equivalent level of safety established by 14

C.F.R. Section 91.151(b) because of the technical specifications of EEI UAS’s. EEI’s 

proposed operating limitations will ensure that EEI may safely operate the battery powered 

UAS’s during daylight hours in VFR conditions for a total flight duration that does not exceed 

80% of the battery power provided. This will ensure a landing with 20 percent battery power 

remaining. Furthermore, previous exemptions granted by the FAA concerning Section

91.151(b) establish that safety is not adversely affected when the technical characteristics 

and operating limitations of a UAS are considered. EEI UAS’s are powered by Lithiumpolymer batteries, and are protected by two low battery failsafes. The ground control station 

(GCS) provides a battery indicator on the heads-up display, which indicates the UAS’s current 

remaining battery power measured in volts, and thus provides the PIC with constant 

awareness of the real- time battery voltage during a flight.

The two low battery failsafes that protect the UAS are a “Low AV battery”

failsafe and a “Critically low AV battery” failsafe. The “Low AV battery” failsafe flies the UAS

to the location of the ground control station (GCS), or identified Rally point, when the UAS 

batteries reach a certain threshold of time as configured by the operator, or 22.2V. The

“Critically low AV battery” failsafe lands the UAS at its current location. This failsafe is 

triggered if a battery drops below the critical battery voltage as configured by the operator, or 

21.2V.

Furthermore, an exemption from the requirements of Section 91.151(b) would not

adversely affect safety because EEI will only conduct flights during daylight hours in VMC,

with the duration of each flight not to exceed the early suggested endurance of 20 percent of

battery power remaining.

Likewise, as set forth above, EEI has proposed specific operating limitations in this

Petition that will maintain the equivalent level of safety established by Section 91.151(b),

including the following:

(1) EEI UAS’s only be operated during daylight hours (i.e. between the end of morning

civil twilight and the beginning of evening civil twilight, as published in the American Air 

Almanac, converted to local time).

(2) EEI UAS’s will only be operated pursuant to visual flight rules (VFR) in visual 

meteorological conditions (VMC).

(3) The duration of each flight shall not exceed 80% of battery power provided.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and operating

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate

at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 

5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151, 
48

specific to UAS in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos.8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b)

Would Not Adversely Affect Safety.

In seeking this exemption, EEI submits that an equivalent level of safety with regard

to the regulatory maintenance and alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because EEI, the

operator, will use its trained technicians to perform maintenance, alterations, or preventive

maintenance on the unmanned aircraft system using the methods, techniques, and practices 

prescribed in the manufacturer’s maintenance manual. Furthermore, EEI will document and 

maintain all maintenance records for all of its UAS.

Since EEI UAS will be inspected as prescribed by the Operators 

manual, EEI will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). The Manufacture`s Operator Manuals set

forth Scheduled Maintenance Inspection Procedures for each system and component.

Inspection intervals for the EEI UAS’s include preflight and post flight inspections, as well as

scheduled inspections every 25 hours, 50 hours, 75 hours, and 100 hours of operation.

Likewise, the exemption sought will not adversely affect safety because EEI will perform 

maintenance, alterations or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed by the manufacturer’s maintenance manuals. The 

Manufacturer`s Operator Manuals detail procedures for each component of the UAS, 

including the components of the propulsion system, legs/arms, avionics system, and payload 

system.

A copy of the Manufacturer`s Maintenance Manuals, which contain proprietary

information, is attached hereto as Attachment C, D, E, G, H, I and are to be held in a separate 

file pursuant to 14 C.F.R. § 11.35(b).

Furthermore, the exemption sought would maintain an equivalent level of safety

established by Sections 91.407, 91.417(a) and 91.417(b) because all maintenance of EEI

UAS’s will be supervised by EEI A&P certified technicians, who will document and maintain

maintenance records for each EEI UAS. EEI trained technicians are qualified to

conduct any and all maintenance to ensure the safe operation of each UAS,

conduct all service inspections, and authorize the use of each UAS based upon completion of 

appropriate inspections. The procedures for maintaining the maintenance logs for the UAS 

are fully set forth in the EEI General Operating Manual (Attachment F at Section 7)

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of a UAS are considered.

The FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).
49

F. A Summary That Can Be Published in the Federal Register, stating:

The Rules from Which EEI Seeks Exemption:

Eagle Eye Intelligence, LLC seeks exemption from the requirements of 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption EEI Seeks:

This exemption will permit Eagle Eye Intelligence LLC to commercially operate an Unmanned

Aircraft System (UAS) for the purpose of commercial training, security, concept development

and PSD support flights over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available to

Support EEI’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, EEI’s request for exemption may be granted

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, EEI will operate each UAS safely in the

NAS without creating a hazard to users of the NAS, or the public, or otherwise pose a threat 

to national security.

CONCLUSION

As set forth herein, EEI seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of each EEI UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting training, security, concept development and PSD support over

certain areas of the United States. By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while 

also advancing the interests of the public, by allowing EEI to safely, efficiently, and 

economically operate each EEI UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, EEI respectfully requests that the

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b), and permit EEI to operate UAS’s for the purpose of conducting training, 

security, concept development and PSD support over certain areas of the United States.
50

Dated: 1 2 / 2 9 / 1 5

Respectfully submitted,

Dean Attridge

Director of Flight Operations

EagleEye Intelligence, LLC 

Cell#: 702 755 9825

Email: dattridge@eagleeyeintelligence.com

www.eagleeyeintelligence.com