August 27, 2015

Exemption No. 12637

Regulatory Docket No. FAA–2015-1459

Mr. William Kaunoa Ah Chan

Owner

UAS Maui

746 Hana Highway

Paia, HI 96779

Dear Mr. Ah Chan:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on May 6, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of UAS Maui (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct ground and flight instruction1, aerial photography, videography, surveying and site 

mapping.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

 

1 The petitioner requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS 

operations for training until a further assessment is completed. When the FAA completes its review, we will 

proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted 

to train its own pilot in commands and visual observers in accordance with condition no. 14 and the other 

conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom II, Cheerson CX20, and Yuneec 

Q500.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, UAS Maui is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, UAS Maui is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom II, 

Cheerson CX20, and Yuneec Q500 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

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

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 
4

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.
5

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol 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 request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
6

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 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 UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating 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 immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 
7

Permission from property owner/controller or authorized representative will be

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
United States Department of Transportation 

Docket Management System 

i 200 New Jersey Ave., SE 

West Building Ground Floor Room Wi 2-i 40 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform 

Act of 2012 

Aloha Sir or Madam: 

We are writing pursuant to the FAA Modernization and Reform Act of 

20i 2 (the "Reform Act") and the procedures contained in i 4 CFR i i, to 

request that UAS Maui, an owner and operator of small unmanned 

aircraft, be exempted from the Federal Aviation Regulations listed below 

so that UAS Maui may operate its small unmanned aircraft/lightweight 

unmanned aircraft systems commercially in airspace regulated by the 

FAA; as long as such operations are conducted within and under the 

conditions outlined heron or as may be established by the FAA as 

required by Section 333. 

As identified and described herein, Mr. William Kaunoa Ah Chan is the 

owner of UAS Maui, Mr. Ah Chan has been a lifelong resident of the 

State of Hawaii and since childhood has been flying with his father over all 

of the major Hawaiian Islands primarily fish spotting. He has accumulated 

over 5,000 flight hours in single engine airplanes and has operated model 

aircraft his entire life. Being a native Hawaiian he recognizes the value of 

unobtrusive lightweight unmanned aerial systems. He has a thorough 

understanding of the airspace system and is fully aware of the wind and 

weather associated with operating UAV's within the State of Hawaii. 

UAS Maui's has the experience, skill set and knowledge to safely operate 

UAV's and would like to provide the following Commercial 

services: Ground and Flight Instruction, Aerial PhotographyNideo and 

aerial survey and site mapping. We are a very compliant company and 

find it necessary to request a Certificate of Waiver or Authorization to 

meet the legal requirements of the FAR's. 
UAS Maui exemption request would permit its operation of lightweight, 

unmanned (remotely controlled in line of sight) aerial systems outside of 

B, C and D airspace at or below 400AGL. 

The Extent of Relief UAS Maui Seeks and the Reason it seeks such relief: 

UAS Maui submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent UAS Maui contemplated commercial operations 

within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public's interest to do so. UAS 

Maui's lightweight UAV/UAS meet the definition of "small unmanned 

aircraft" as defined in Section 331 and therefore the integration of UAS 

Maui's lightweight UAV/UAS are expressly contemplated by the Reform 

Act. UAS Maui would like to operate its lightweight UAV/UAS prior to the 

time period by which the Reform act requires the FAA to promulgate rules 

governing such craft. 

The Reform Act guides the Secretary in determining the types of UASs 

that may operate safely in our national airspace system. Considerations 

include: 

The weight, size, speed and overall capabilities of the UAS; Whether the 

UAS will be operated by line of sight. 

112 P .L. 95 § 333 (a). Each of these items militates in favor of an 

exemption for UAS Maui. 

UAS Maui utilizes four counter-rotating propellers for extreme balance, 

control and stability. They each weigh less than 55 pounds, including 

payload. Each of UAS Maui's small unmanned aircraft are designed to 

primarily hover in place and operate at less than 50 knots maximum 

speed. They are capable of vertical and horizontal operations but 

operate only within the line of sight of the remote control pilot. In addition 

to the remote control pilot, UAS Maui uses a visual observe/technician, 

so at a minimum two UAS Maui personnel govern the safe flight of the 

aircraft at all times. 
Utilizing battery power and not combustible fuels, flights generally last 

between five and twenty minutes. UAS Maui does not operate its aircraft 

with less than 30°/o battery power capacity. Safety systems in place 

include a GPS mode that allows UAS Maui's aircraft to hover in place if 

communication with the radio control pilot is lost and then slowly descend 

when the battery life gets to 25°/o. Further, UAS Maui's aircraft software 

will not allow operations within 5 miles of airports or within restricted 

areas. 

UAS Maui intends to operate in sparsely populated areas without hazard 

to persons or property on the surface. In the event non-participating 

public enters our operational area we will cease operations until all nonparticipating public is cleared of the area. 

Reasons why UAS Maui's exemption will not adversely affect safety or 

how the exemption will provide a level of safety at least equal to the 

existing rule. By granting the exemption and permitting UAS Maui to 

operate we can log more flight time in FAA controlled airspace which will 

allow us to innovate and implement new and as of yet undiscovered 

safety protocols. In addition, UAS Maui submits the following 

representations: 

UAS Maui UASs weigh less than 55 pounds 

UAS Maui only operates at or below 400 feet 

UAS Maui will only operate for 5-25 minutes per flight 

UAS Maui lands its UASs when they reach 30°/o battery life 

UAS Maui will only operate while maintaining line of sight to UASs 

UAS Maui will operate with a remote control pilot and a spotter/technician 

UAS Maui UASs have a GPS flight modes whereby they hover and then 

slowly land if communication with the remote control pilot is lost or battery 

life is below 25°/o 

UAS Maui will only operate in secured areas that are strictly controlled, 

are away from airports and populated areas 

UAS Maui conducts extensive briefings prior to flight, during which safety 

carries primary importance 

UAS Maui will log all flights 

UAS Maui always obtains all necessary permissions and permits prior to 
operation and will abort/suspend operations should a safety breach or 

potential danger develops 

The following are the regulations that UAS Maui are requesting an 

exemption: 

A. 14 CFR 21 and 14 CFR 91 Airworthiness Certificates, Manuals and 

the like. 

14 CFR 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in 

relation to FAR 91.203 (a) (1 ). The size, weight and enclosed operational 

area of UAS Maui UASs permits exemption from Part 21 because UAS 

Maui UASs meet an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 USC 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UASs from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. UAS 

Maui UASs meet or exceed each of the elements. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by the FARs, this regulation is inapplicable. 

14 CFR 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As 

there are no pilots or passengers, and given the size on the UASs, this 

Regulation is inapplicable. An equivalent level of safety will be achieved 

by maintaining a manual at the home base and having the manual in the 

pilots possession when operating. The FAA has previously issued 

exemptions to this regulation in Exemption# 8607, 8737, 8738,9299, 

9299A, 9565, 95658, 1 0167A, 10602, 10700 and 32827. 

14 CFR 91.121 regarding altimeter settings is inapplicable insofar as UAS 

Maui UASs will utilize electronic global positioning systems and internal 

gyroscopes to provide spatial coordination. 
i 4 CFR 9i. i Si (a) & (b) Fuel requirements for flight in VFR conditions, not 

applicable due to the fact that we will not be using fuel and only using 

battery power down to 30°/o. 

i 4 CFR 9i .203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same 

reasons described above. The equivalent level of safety will be achieved 

by maintaining such certifications and registrations at UAS Maui home 

base. 

B. i 4 CFR 45.23 Marking of the aircraft 

Applicable codes of Federal Regulation require aircraft to be marked 

according to certain specifications. UAS Maui UASs are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases .. Further, two-inch lettering is 

difficult to place on such small aircraft. Regardless, UAS Maui will mark 

its UASs in the largest possible lettering by placing the word 

"EXPERIMENTAL" on its fuselage as required by i 4 CFR 45.29 (f) so that 

the pilot, spotter/technician and others working with the UAV will see the 

markings. The FAA has previously issued exemptions to this regulation 

through Exemptions# 8738, i Oi 67,10167 A and 10700. 

C. 14 CFR 61.113 Private Pilot Privileges and Limitations, PIC 

Pursuant to i 4 CFR 61.113 (a) & (b), private pilots are limited to noncommercial operations. UAS Maui can achieve an equivalent level of 

safety as achieved by current regulations because UAS Maui UASs do not 

carry any pilots or passengers. Further, while helpful, a pilot license will 

not ensure remote control piloting skills, though UAS Maui pilot vetting 

and training programs will. Further, private pilot licensees will operate 

UAS Maui UASs with the same skill. Further, the risks attendant to the 

operation of UAS Maui UASs is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61, et seq. Thus, allowing UAS 

Maui to operate its UASs with a private as the pilot in control will exceed 

current safety levels in relation to 14 CFR 61.113 (a) & (b). 

D. 14 CFR 91.119 Minimum safe altitudes 
14 CFR 91.119 prescribes safe altitudes for the operation of civil aircraft. 

It allows helicopters to be operated at lower altitudes in certain conditions. 

UAS Maui UASs will never operate at an altitude greater than 400 AGL. 

UAS Maui will, however, operate its UASs in sparsely populated areas 

and never endanger the person or property of another, we will also cease 

operations if non-participating public enters our operational area, this will 

enable us to provide a level of safety at least equivalent to those in 

relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of UAS Maui UASs , an equivalent level of 

safety will be achieved. 

E. 14 CFR 91.405(a); 407(a)(1); 409(a)(1 )&(2); 417(a)&(b): 

Maintenance Inspections 

The above-cited regulations require, amongst other things, aircraft 

owners and operators to "have (the) aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as 

provided in paragraph© of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter." 

These regulations only apply to aircraft with an airworthiness certificate. 

They will not, therefore, apply to UAS Maui should its requested 

exemption be granted. UAS Maui conducts an extensive maintenance 

program that involves regular software updates and constant inspection 

for assessment of any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. 

F. Summary 

UAS Maui seeks an exemption from the following Regulations: 14 CFR 

21, subpart H, 14 CFR 45.23(b), 14 CFR 61.113 (a) & (b), 14 CFR 

91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.1 09(a), 14 CFR 91.119, 14 CFR 

91.121, 14 CFR 91.151 (a)&(b), 14 CFR 91.203(a)&(b), 14 CFR 

91.205(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1 ), 14 CFR 91.409(a) 

(1 )&(2), 14 CFR 91.417(a)&(b) to commercially operate its fleet of small 

unmanned vehicles and lightweight unmanned aircraft systems for flight 

instruction, aerial photography/video, aerial survey and site mapping. We 
would like to also conduct our own research and to develop economic 

platforms for law enforcement, search & rescue, and disaster relief 

operations. 

Granting UAS Maui request for exemption will reduce current risk levels 

and thereby enhance safety. Currently, the uses outlined above relies 

primarily on the use of larger aircraft running on combustible fuels. UAS 

Maui craft do not contain potentially explosive fuels, are smaller, lighter 

and more maneuverable than conventional manned aircraft. Further, 

UAS Maui provides a level of safety at least equal to existing rules and in 

nearly every instance, greater than existing rules. It is far safer to operate 

a battery powered lightweight UAS than a manned helicopter. The 

potential loss of life is diminished because UASs carry no people, we only 

operate in sparsely populated areas and the extreme maneuverability 

allow our remote control pilots to avoid hazards. UAS Maui have 

operated and will continue to operate at and above current safety 

standards. 

UAS Maui respectfully requests that the FAA grant its exemption request 

without delay. 

Sincerely, 

William Kaunoa AhChan