## Drone Assist,	Inc

. 333	Exemption	Request

1 December 10, 2015

To Whom It May

Concern: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 C.F.R. Part 11, Drone Assist, I nc. , hereb y applies for an exemption from the Federal Aviation Regulations (FARs) identified below, to operate small unmanned aerial vehicles (i.e., small unmanned aircraft s ys tems or UAS) for aerial data collection , aerial photography and cinematograph y

. Drone Assist, I nc. r espectfully submits that this Petition for Exemption qualifi es for approval, as the Federal Aviation Administration (FAA) has previously issued grants of exemption in circumstances similar in all material respects to those presented herein. In addition to this Petition for Exemption, Drone Assist, I nc. also subm its a confidential Motion Picture and Television Operations Manual (MPTOM).

Respectfully , //signed// William Douglas Harwell I V, President/Chief Pilot Drone Assist, Inc

. 11989 Music Street Gulfport, MS 39503 228 265

- 0174

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. 333	Exemption	Request

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**The specific applicable regulations from which relief is required (CFRs):**  Drone Assist, Inc

. is requesting relief from Federal Aviation Regulations: Exemption from of Title 14, Code of Federal Regulations (14 CFR) : **Part 21 Part 45**  **61.56 (a)**  **61.57 61.101(e)(1)(ii)(iv),**  **(2), (4), (5), and (7) 61.113(a) and (b)**  **61.315( a**  **) 91.9 (b)(1) and (2)**  **91.103(b) 91.105 (a)(2), (b)(1) and (2)**  **91.107 91.109 (b)(1) and (2), (c)(1), (2) and (3)(i)(ii)**  **91.119 91.121**  **91.144 91.151**  **91.203 91.205**  **91.313(e)(1) and (3) 91.403(b)**  **91.405(a) and (b)**  **91.407(a)(1) 91.409(a)(1) and (2)**  **91.417(a) and (b) Part 21: Request relief from this rule.** 

**Part 45: Request relief from this rule as the UAS is too small to accommodate the size of**  **markings dictated in §45.29. Drone Assist, Inc. will place m arkings on the aircraft in a**  **location that allows for the most visibility.**
**61.56 (a)**  **...Request flight review minimum flight time be reduced from 1 hour to 1 UAS flight, during which the PIC will demonstrate competence while operating the UAS.**  **Subpart A** 

**— General**  **§61.56 Flight review.**  (a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. **61.57...Request 3 takeoffs and3 landings while operating t he UAS in the preceding 90 days**  **meet the intent of this rule. §61.57**  **Recent flight experience: Pilot in command.** (a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoff s and three landings within the preceding 90 days, and

— (i) The person acted as the sole manipulator of the flight controls; and

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(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a t ype rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel. (2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act as a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are carried on board the aircraft, other than those necessary for the conduct of the flight. (3) The takeoffs and landings r equired by paragraph (a)(1) of this section may be accomplished in a flight simulator or flight training device that is

— (i) Approved by the Administrator for landings; and (ii) Used in accordance with an approved course conducted by a training center certificated under part 142 of this chapter.
**61.101 (e)(1** 

**) (ii)(iv), (2), (4),**  **(5) , and (7)...The UAS is a multiengine aircraft with retractable**  **landing gear being used for compen sation or hire in the furtherance of a business**  **with possible operations in Class B, C and D airspace; request a waiver to allow recreational pilots**  **to act as PIC of the UAS**

**. Subpart D** 

**— Recreational Pilots**  **§61.101 Recreational pilot privileges and**  **limitations.** (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— (1) That is certificated

— (ii) With more than one powerplant; (iv) With retractable landing gear (2) That is classified as a multiengine airplane, powered

- lift, glider, airship, balloon, powered parachute, or weight

- shift

- control aircraft; (4) For compensation or hire; (5) In furtherance of a business; (7) In Class A, B, C, and D airspace, at an airport located in Class B, C, or D airspace, or to, from, through, or at an airport having an operational control tower; **61.113(a) and (b)**

**... Request permission to allow a Private Pilot be PIC of the UAS for**  **compensation or hire. Subpart E** 

**— Private Pil**  **ots §61.113**  **Private pilot privileges and limitations: Pilot in command.** (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 comp ensation 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.

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**61.315( a**  **) ... Request permission to allow a Sport Pilot**  **to act as PIC of the UAS for**  **compensation or hire and for the purposes of a demonstration flight of the UAS to a**  **prospective buyer. Subpart J** 

**— Sport Pilots**  **§61.315 What are the privileges and limits of my sport pilot certificate?**  (a) If you hold a sport pilot certificate you may act as pilot in command of a light

- sport aircraft, except as specified in paragraph (c) of this section (c) You may not act as pilot in command of a light

- sport aircraft: (2) For compensation or hire. (3) In furtherance of a business. (9) To demonstrate the aircraft in flight to a prospective buyer if you are an aircraft s alesperson **14 CFR: 91.9 (b)(1) and (2)..**

**. The**  **UAS does not have the ability to**  **carry manu als or**  **registration onboard** 

**. R equest exemption from carrying**  **these documents onboard; they will readily available to the UAS pilot during operations and made availabl**  **e to the administrator**  **when requested.**  **Subpart A**

**— General**  **§91.9 Civil aircraft flight manual, marking, and placard requirements**  (b) No person may operate a U.S.

- registered civil aircraft

— (1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in §121.141(b); and (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 thereo f. **91.103(b)... Request exemption from this rule as t**  **he UAS does not have manufacturers**  **performance information in relation to takeoff and landing information. §91.103**  **Preflight action.** (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and la nding distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircr aft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature. **91.105 (a)(2), (b)(1) and (2)... The**  **unmanned aircraft lacks onboard**  **crew members and**  **therefore do**  **es not**  **have seat belts** 

**. Requesti**  **ng exemption from this rule**  **for registered UAS**  **s .**  **Subpart B**

**— Flight Rules**  **§91.105 Flight crewmembers at stations.**  (a) During takeoff and landing, and while en route, each required flight crewmember shall

— (2) Keep the safety belt fastened while at the crewmember station. (b) Each required flight crewmember of a U.S.

- registered civil aircraft shall, during takeoff and landing, keep his or her shoulder harness fastened while at his or her assigned duty sta tion. This paragraph does not apply if

— (1) The seat at the crewmember's station is not equipped with a shoulder harness; or

## Drone Assist,	Inc

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(2) The crewmember would be unable to perform required duties with the shoulder harness fastened.
**91.107... The unmanned aircraft lacks occupants and therefore does not**  **have seat belts.**  **Drone Assist, Inc. is r equesting exemption from this rule**  **in order to legally operate the U.S. registered UAS.**  **§91.107 Use of safety belts, shoulder harnesses, and child**  **restraint systems.** (a) Unless otherwise authorized by the Administrator

— (1) No pilot may take off a U.S.

- registered civil aircraft (except a free balloon that incorporates a basket or gondola, or an airship type certificated before November 2, 1987) unl ess the pilot in command of that aircraft ensures that each person on board is briefed on how to fasten and unfasten that person's safety belt and, if installed, shoulder harness. (2) No pilot may cause to be moved on the surface, take off, or land a U. S.

- registered civil aircraft (except a free balloon that incorporates a basket or gondola, or an airship type certificated before November 2, 1987) unless the pilot in command of that aircraft ensures that each person on board has been notified to fasten h is or her safety belt and, if installed, his or her shoulder harness. **91.109 (b)(1) and (2), (c)(1), (2) and (3)(i)(ii)... The**  **UAS does not have dual yokes nor does it**  **have rudder pedals t**

**hereby requiring exemption from this rule for the purposes of flight instruction. It**  **may or may not be operated with**  **dual controllers with “trainer” mode during instruction.**  **If the f**

**light instructor does not have a “buddy box,” which connects two**  **transmit ters for “trainer” mode, he/she**  **will remain next to the student controlling the UAS ready to take over control**  **when needed. §91.109**  **Flight instruction; Simulated instrument flight and certain flight tests.** (b) An airplane equipped with a single, functio ning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57 when

— (1) The airplane is equipped with operable rudder pedals at both pilot stations; (2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight (3) Exce pt in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

— (i) The safety pilot has determined that the flight can be conducted safely; and (ii) The person manipulating the controls has at least a private pilot certificate with appropr iate category and class ratings.
**91.119 ...Current UAS rules preclude the ability to comply with 500 feet above the surface.**  **Request relief to the extent necessary to operate in accordance with sUAS rules and Drone Assist, Inc.’s**  **Motion Picture and Televisio n Operations Manual (**  **MPTOM )** 

**. §91.119**  **Minimum safe altitudes: General.** Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

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(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an a ltitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.
**91.121...The sUAS does not have an adjustable altimeter**  **; rather it use s**  **the GPS altitude calculation function** 

**. Before taking off the PIC will either reset the GPS altitude to 0’ AGL if**  **able or note the GPS altitude and subtract it from the airborne GPS altitude to determine height AGL.**  **Therefore, Drone Assist, Inc**

**. requests exemption from this rule.**  **§91.121 Altimeter settings.**  (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 cur rent 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 ap propriate 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; or (2) At or above 18,000 feet MSL, to 29.92 ʺ Hg. ( b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table: Current altimeter setting Lowest usable flight level 29.92 (or higher) 180 29.91 through 29.42 185 29.41 through 28.92 190 28.91 through 28.42 195 28.41 through 27.92 200 27.91 through 27.42 205 27.41 through 26.92 210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

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Current altimeter setting Adjustment factor 29.92 (or higher) None 29.91 through 29.42 500
29.41 through 28.92 1,000 28.91 through 28.42 1,500 28.41 through 27.92 2,000 27.91 through 27.42 2,500 27.41 through 26.92 3,000

**91.144...Sinc e the UAS is operated in accordance**  **with the sUAS rules and does not solely rely on a barometric altimeter**  **to determine altitude**  **, Drone Assist, Inc.**  **request s**  **exemption from**  **this rule. §91.144**  **Temporary restriction on flight operations during abnormally high barometric pressure conditions.**  (a) Special flight restrictions. When any information indicates that barometric pressure on the route of flight currently exceeds or will exceed 31 inches of mercury, no person may operate an aircraft or initiate a flight contrary to the requirements established by the Administrator and published in a Notice to Airmen issued under this section. (b) Waivers. The Administrator is authorized to waive any restriction issued under paragraph (a) of this section to permit emergency supply, transport, or medical services to be delivered to isolat ed communities, where the operation can be conducted with an acceptable level of safety.
**91.151...The UAS is**  **electric with a total flight time of 20**

**- 30 minutes. The minimum battery**  **voltage established by the**  **battery manufacturer should be used to determine minimum “fuel”**  **requirements**

**, however if a minimum voltage is not established then Drone Assist, Inc. will use 25% voltage remaining to establish**  **minimum fuel for the LiPo battery.**  **§91.151 Fuel requirements for flight in VFR conditions.**  (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 fo r at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft 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 20 minutes.

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**91.203... Request exemption from this rule as p**  **ertinent documents cannot be carried on board**  **the UAS**  **. Drone Assist, Inc. will**  **have the documents**  **available to the UAS pilot as part of the**  **UAS equipment and readily a ccessible**  **to the pilot during operations** 

**. Subpart C** 

**— Equipment, Instrument, and Certificate Requirements**  **§91.203 Civil aircraft: Certifications required.**  (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. Each U.S. airworthiness certificate used to comply with this subparagraph (except a special flight permit, a co py of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 and 135 of this chapter containing that portion of the operations specifications issued under §21.1 97(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworthiness certificate need not have on it an assigned special identification number before 10 days af ter that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been affixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district of fice. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign country. (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 tha t it is legible to passengers or crew. (c) No person may operate an aircraft with a fuel tank installed within the passenger compartment or a baggage compartment unless the installation was accomplished pursuant to part 43 of this chapter, and a copy of F AA Form 337 authorizing that installation is on board the aircraft. (d) No person may operate a civil airplane (domestic or foreign) into or out of an airport in the United States unless it complies with the fuel venting and exhaust emissions requirements of part 34 of this chapter.
**91.205... Request exemption from this rule. The**  **UAS lacks most of the required instruments necessary to be considered airworthy.**  **§91.205 Powered civil aircraft with standard category U.S. airworthiness certificates:**  **Instrument and equipment requirements.**  (a) General. Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a powered civil aircraft with a standard category U.S. airworthiness certificate in any operation described in paragraphs (b) t hrough (f) of this section unless that aircraft contains the instruments and equipment specified in those paragraphs (or FAA

- approved equivalents) for that type of operation, and those instruments and items of equipment are in operable condition. (b) Visu al

- flight rules (day). For VFR flight during the day, the following instruments and equipment are required: (1) Airspeed indicator. (2) Altimeter. (3) Magnetic direction indicator. (4) Tachometer for each engine. (5) Oil pressure gauge for e ach engine using pressure system. (6) Temperature gauge for each liquid

- cooled engine.

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(7) Oil temperature gauge for each air

- cooled engine. (8) Manifold pressure gauge for each altitude engine. (9) Fuel gauge indicating the quantity of fuel in each tank. (10) Landing gear position indicator, if the aircraft has a retractable landing gear. (11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made. (12) If the aircraft is operated for hire over water and b eyond power

- off gliding distance from shore, approved flotation gear readily available to each occupant and, unless the aircraft is operating under part 121 of this subchapter, at least one pyrotechnic signaling device. As used in this section, “shore”
mea ns that area of the land adjacent to the water which is above the high water mark and excludes land areas which are intermittently under water. (13) An approved safety belt with an approved metal

- to

- metal latching device for each occupant 2 years of age or older. (14) For small civil airplanes manufactured after July 18, 1978, an approved shoulder harness for each front seat. The shoulder harness must be designed to protect the occupant from serious head injury when the occupant experiences the ultimate inertia f orces specified in §23.561(b)(2) of this chapter. Each shoulder harness installed at a flight crewmember station must permit the crewmember, when seated and with the safety belt and shoulder harness fastened, to perform all functions necessary for flight o perations. For purposes of this paragraph

— (i) The date of manufacture of an airplane is the date the inspection acceptance records reflect that the airplane is complete and meets the FAA

- approved type design data; and (ii) A front seat is a se at located at a flight crewmember station or any seat located alongside such a seat. (15) An emergency locator transmitter, if required by §91.207. (16) For normal, utility, and acrobatic category airplanes with a seating configuration, excluding pil ot seats, of 9 or less, manufactured after December 12, 1986, a shoulder harness for

— (i) Each front seat that meets the requirements of §23.785 (g) and (h) of this chapter in effect on December 12, 1985; (ii) Each additional seat that meets th e requirements of §23.785(g) of this chapter in effect on December 12, 1985. (17) For rotorcraft manufactured after September 16, 1992, a shoulder harness for each seat that meets the requirements of §27.2 or §29.2 of this chapter in effect on September 16, 1991. **91.313(e) (1) and (3)**  **...Request permission to operate in accordance**  **with the sUAS rules**  **, Motion Picture and Television Operation Manual**  **and as necessary to accomplish the mission in a safe manner.**  **Subpart D**

**— Special Flight Operations**  **§91.313 Restricted category civil aircraft: Operating limitations.**  (e) Except when operating in accordance with the terms and conditions of a certificate of waiver or special operating limitations issued by the Administrator, no person may operate a rest ricted category civil aircraft within the United States

— (1) Over a densely populated area; (3) Near a busy airport where passenger transport operations are conducted

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**91.403(b)...Request permission to perform maintenance, preventive maintenance or**  **alt erations as needed to properly configure the aircraft to perform the mission as long as it**  **remains within manufacturer’s performance limitations and does not adversely affect the safe flight characteristics and performance.**  **Subpart E**

**— Maintenance, Preventiv**  **e Maintenance, and Alterations §91.403**  **General.** (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter. **91.405(a) and (b)** 
**... Request**  **a deviation from this rule that allows pre and post flight**  **inspections to**  **meet the int ent of the required inspections, and gives the PIC or appointed**  **Drone Assist, Inc. personnel the ability to determine if/when the UAS has been approved for**  **return to service. §91.405**  **Maintenance required.** 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 (b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to servi ce; **91.407(a)(1)**

**... Request a deviation from this r**  **ule to allow the**  **PIC be**  **the authorized person to determine the aircraft is airworthy after maintenance, preventive maintenance, rebuilding or**  **alteration work is conducted. §91.407**  **Operation after maintenance, preventive maintenance, rebuilding, or alteration.**  (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 a uthorized under §43.7 of this chapter **91.409(a)(1) and (2)**

**... Request**  **a deviation that allows a thorough pre and post flight**  **inspections meet the intent in lieu of the required inspections. If a discrepancy is found then**  **the PIC will be required to “down” the aircraft until all di screpancies have been corrected and**  **a functional test flight has been completed with the PIC returning the UAS to service. §91.409**  **Inspections.** (a) Except as pro vided 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 p erson 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.

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**91.417(a) and (b) ...Request a deviation in order to create a maintenance record program**  **suitable for unmanned aircraft. The 100 hour and annual inspections will most likely be superseded by the UAS manufacturer’s recommendations** 

**. §91.417**  **Maintenance records.** (a) Except for work performed in accordance with §§91.411 and 91.413, each regi stered 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 requ ired 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 Administrato r) 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 i tems 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 direc tive involves recurring action, the time and date when the next action is required. (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 appl iances. (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 re tained 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 r eturn to service. **How the operator will maintain an equivalent level of safety or no adverse impact to safety:** Drone Assist, Inc

. is petitioning to operate a DJI Spreading Wings S1000+ , eight engine , electric unmanned aircraft with a maximum aircraft weight of 24.25lbs . The aircraft is 41 inches in diameter and operates on the 2.4GHz frequency. The aircraft is equipped with a n autopilot , specificall y designed and programmed to maintain the aircraft’s stability during motor failure , allowing the pilot to recover the aircraft back to the intended landing point and terminate the mission without loss of directional control. T he a utopilot also has lost link programmable command that will guide it back to a pre

- established location for landing sho uld it lose link with the 2.4GHz controller . During a loss of GPS signal the pilot has the option to select “attitude mode” on the controller which then allows the pilot to operate the aircraft in the same manner as a radio controlled aircraft.
The UAS is configured with a 5.8GHz high definition video downlink that will transmit video to the ground station where both the pilot and camera operator will have “first pilot view.” The

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downlink will also transmit telemetry information from the UA S such as power voltage, flight velocity , height, distance from the home point, horizontal attitude and GPS satellite status, etc. Additionally , the onboard instrumentation can record the flight telemetry , record the input and output information of every c hannel, GPS signal, power voltage, home distance and height, etc., which are all pertinent information needed to investigate the cause of a crash should an aircraft mishap occur. Drone Assist, Inc.’s President and Chief Pilot is an Air Force aviator with a combined 22 ye ars of civilian and military aviation experience . H e also has over 24 ye ars’ experience fly ing radio controlled airplanes . FAA airman certificates held are: Airline Transport Pilot (ATP) airplane multi

- engine land, Commercial Privil eges airplane single

- engine land, expired Certified Flight Instructor (CFI) airplane single and multi

- engine and instrument airplane and Ground Instructor Instrument . Training and qualifications include Chief of Safety , Flight Safety Officer, Aircraft Mish ap Investigator’s Course, Risk Management, Flight Safet y’s Crew Resource Management Course and oversight of special use airspace for air to air and air to ground training. Additionally , he is an experienced FAR Part 141 Flight and Ground Instructor in ass ociation with Delta State University ’s B achelors of C ommercial A viation program. Drone Assist, Inc.’s Pilot in Command (PI C) will ensure all operations are in accordance with FAR 91, the attached Motion Picture and Television Operations Manual (MPTOM) and the rules and exemptions set forth by the FAA’s sUAS rulemaking. Additionall y, the PI C will conduct mission planning before each flight to determine potential hazards, safe takeoff and landing locations including emergency landing areas, areas where nonparticipants might encroach on the operation and ensuring necessary public notifications are announced in a timely manner.
T he following outline s the FAA’s guidelines to operate a s UAS for commercial operations and as such will be followed by all Drone Assist, Inc.’s employ ees when operating a UAS:

 Not o perated at a speed exceeding 87 knots (100 miles per hour)

 O perated at an altitude of no more than 400 feet above ground level (AGL).

 O perated within visual line of sight (VLOS) of the PI C at all times

 This exemption and all documents needed to operate the UAS and conduct its operations must be accessible during UAS operations and made available to t he Administrator upon request

 Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics will undergo a functional test flight

 The operator is responsible for maintaining and inspecting the UAS to ensure that it is in
a condition for safe operation

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 Drone Assist, Inc. will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the air craft and aircraft components and compl y with all manufac turer safety bulletins

 The PI C will hold either an airline transport, commercial , private, recreational, or sport pilot certificate. The PI C must also hold a current FAA airman medical certificate or a valid U.S. driver’s license

 No PI C may operate the UAS, other than for training unless the PIC demonstrates the ability to safel y o perate the UAS in a manner consistent with how the UAS will be operated

 UAS operations will be day time visual meteorological conditions (VMC)

 The UA will not operate within 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published instrument flight pr ocedure of an airport reference point (ARP) as denoted in the current FAA Airport/Facilit y Directory (AFD) or for airports not denoted with an ARP, the center of the airport sy mbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon re quest.

 The PI C must abort the flight in the event of unpred icted obstacles or emergencies

 The UA S must remain clear and give way to all manned aviation operations and activities at all times

 All Flight operations must be conducted at least 500 feet fr om all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently

protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonpar ticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediatel y in a manner ensuring the safety

of nonparticipating per sons; and b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PI C has made a safet y assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

 The PI C, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption. Drone Assist, I nc.’s MPTOM Appendix 3 contains a document to notify

personnel on and around a motion picture or television set that a UAS

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will be used. Additionally , the MPTOM Appendix 5 outlines a sample checklist to be used in planning and briefing before the UAS begins an operation.

 All operations shall be conducted over private or controlled

- access propert y with permission from the property owner/controller or authorized representative. Permission from propert y owner/controller or authorized representative will be obtained for each flight to be conducted. Drone Assist, Inc.’s MPTOM Appendix 4 conta ins a document to obtain necessary

permissions from propert y owner/controller and/or governmental agencies.

 Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined b y t he app licable COA must be reported to the FAA's UAS Integration Office (AFS −80) within 24 hours. Accidents must be reported to the National Transportation Safet y Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.
Finall y, all un manned aircraft operations will be conducted within the limitations set forth by the aircraft and aircraft components’ manufacturer and if no limitation is established by the manufacture , Drone Assist, I nc

. will establish limits . Drone Assist, I nc

. believes that the LiPo battery used to power the UAS is a safet y concern and therefore will charge, discharge and use the battery

according to manufacturer’s specifications and will immediately cease using and will fully discharge to 0 volts and discard a ny battery that shows signs or s ym ptoms of damaged cells such as battery

swelling or cell imbalance that cannot be corrected via a balancing charger. Additionally , the LiPo batteries will be charged, discharged and stored in LiPo specific safety bags that are designed to contain a battery fire. **How granting the exemption would be in the public’s interest:** Granting Drone Assist, I nc.’s exemption furthers the spirit of the Congressional mandate by allowing a small business whose owner has years of prof essional aviation experience to contribute to the safe integration of unmanned technology into industries that are constantly seeking way s to leverage technology to improve safe working conditions, increase profitabilit y, reduce expenses and increasing ret urns for both shareholders and stakeholders by reducing their overall environmental impact. Furthermore, we seek to safel y further the use of unmanned aircraft as a replacement and/or substitution for the current hazardous means of aerial photograph y/ cine matography and aerial data collection. Additionally , we believe unmanned technology

will provide an overall benefit to the United States as well as the world economies as small unmanned aircraft businesses safel y integrate into industries that normally di d not use and/or could not afford to use aviation assets as part of their processes. • UAS provide safer work conditions for company emplo ye es because the employ ees will not have to go into a dangerous environment • A UAS is safer than a helicopter or small plane because it is lighter and less combustible • A UAS is more environmentally friendl y than a helicopter or small plane because it
re duces noise and air pollution

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• UAS use contributes to reduced airport congestion by reducing th e commercial use of small p lanes and helicopters • There is less risk to li fe and propert y on the ground • UAS use is more economical for companies and contributes to the U.S. economy by al lowing them to stay

competitive **The proposed operations:** Drone Assist, Inc

. is an aerial data collection and storage compan y created to provide the customer with detailed aerial data used to mak e intelligent operational and fiduciary decisions. We will focus on capturing videos and/or photos of real estate, aerial survey ing, utility infrastructure and power generation s ys tems , above and below ground pipeline inspection, communication tower s , precision agriculture, wildlife and forestry monitoring, construction site survey s and monitoring , archaeology and geol ogy exploration, and mo tion picture and television production and training to individuals belonging to both private and public organizations to increase awareness and improve safet y for current and future UAS operations. Additionally , Drone Assist, Inc seeks to offer its UAS for use in conjunction with state and federal agencies for aerial video and pictures assisting with search and rescue and state and federal emergency management operations. Lastl y, we seek the ability to operate in all 50 states and its territories and possessions. **The make and model of the aircraft for proposed operations (aircraft manuals are not necessary):**  Drone Assist, Inc currently owns and seeks to operate the DJ I Spreading Wings S1000+ for commercial purposes

. Aircraft and component manuals available upon request.

**FEDERAL REGISTER SUMMARY** The following summary

is provided pursuant to 14 C.F.R. Part 11: Drone Assist, Inc. seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: Part 21; Part 45; 61.56 (a) ; 61.57; 61.101(e)(1)(ii)(iv), (2), (4), (5), and (7); 61.113(a) and (b); 61.315(a); 91.9 (b)(1) and (2); 91.103(b); 91.105 (a)(2), (b)(1) and (2); 91.107; 91.109 (b)(1) and (2), (c)(1), (2) an d (3)(i)(ii); 91.119; 91.121; 91.144; 91.151; 91.203; 91.205; 91.313(e)(1) and (3); 91.403(b); 91.405(a) and (b); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b)

. The exemption will enhance safety by reducing risk to the general public and propert y owners from the substantial hazards associated with using conventional fixed

- wing aircraft or, rotorcraft for aerial data collection and aerial photography and cinematograph y.