August 26, 2015

Exemption No. 12603 Regulatory Docket No. FAA

– 2015

– 1087

Mr. Travis J. Brown Chief Operating Officer SkyVue Technologies, LLC dba Travis Jay Brown Photography

912 South Alfred Street Alexandria, VA 22314

Dear Mr. Brown :

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 s dated April 13, 2015 , and July 15, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of SkyVue Technologies, LLC dba Travis Jay Brown Photography ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to
operate an unmanned ai rcraft system (UAS) to conduct aerial photography and survey, fine art and real estate photography, agricultural and construction monitoring, and UAS operator training 1

.

See Appendix A for the petition submitted to the FAA des cribing 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 th is petition would be detrimental to the petitioner

.

1 The petitioner also 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 furth er 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 2 Vision + , DJI Phantom 3, and DJI Inspire 1

.

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic 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

, C ertification pr ocedures 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 collection 2

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , 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 peti tioner 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 i nterest.

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 (part iculate 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, SkyVue Technologies, LLC dba Travis Jay Brown Photography 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 necessa ry 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, SkyVue Technologies, LLC dba Travis Jay Brown Photography 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 autho rized by this grant of exemption are limited to the DJI Phantom 2

Vision + , DJI Phantom 3, and DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend t his 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 altitud e 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 ot her 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 VLOS4

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

e lectronic messaging or texting is not permitted during flight operation s. The PIC 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.

Other wise, 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 a ffect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the oper ating 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 pro perty.

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 th e 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew 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

1 4 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, 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

traini ng, proficiency, and experience

- building flights, all persons not essential for flight ope rations 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 b e 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/Facili ty Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l 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

hori zontally 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 sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must ab ort 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 t o 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 cond ucted 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

num ber, 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 enforcem ent 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

tha t 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 nonparticipa ting 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.7

27. All operations shall be conducted over private or control led

- access property with permission from the prop erty owner/controller or authorized representative. 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 vert ical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

containe d 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 a rea 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 f

or 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 th e person responsible for the on

- scene operation of the UAS;

d. Make, model, and serial or N− Number of UAS to b e 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 August 31, 2017 , unles s sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

EnclosuresApril 13 , 2015

U.	S.	Department	of	Transportation Docket	Management	System 1200	New	Jersey	Ave.	SE Washington,	DC	20590

RE:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Modernization	and

Reform	Act	of	2012

Dear	Sir	or	Madam:

The	subject	pet ition	is	be ing	submitted without	consulting	or	legal	services	as SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography	is	a	start

- up	small

business. I	also	hold	a	Private	Pilot	Certificate	and	Instrument	Rating.

Pursuant	to	Section	333	of	the	FAA Modernization	and	Reform	Act	of	2012	(the Reform	Act),	and	14	C.F.R.	Part	11,	SkyVue	Technologies,	LLC	d/b/a	Travis	Jay

Brown Photography	wishes	to	operate small Unmanned	Aircraft	System	(UAS) equipped	to	conduct	aerial	photography	and	survey	for	various industries and hereby	applies	for	an	exemption	from	the	Federal	Aviation Regulations	(FARs)

listed	below to	allow	operation	of	our	UAS	commercially	in	the	National	Airspace System	(NAS)	so	long	as	such	operations	are	conducted	with	and	under	the

conditions outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by

Section	333.

The	requested	exemption	would	permit	SkyVue	Technologies,	LLC	d/b/a	Travis	Jay Brown	Photography	to	pursue	its	commercial	interests	in	providing	services	to

consumers	interes ted	in	aerial	photograph	using	a	small,	commercial

- off

- the

- shelf (COTS)	UAS	in	the	following	areas:

• Motion Picture F ilming

• Fine Art and Real Estate Photography

• Agricultural and Construction Monitoring

• UAS Operator Training

• Promoting the Safe and Effective Use of S mall UAS T echnology

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography	UAS	operations	will only	occur	in	areas	approved	for	use	with	prior	verbal	or	written	consent. Flight operations	will	not	be	conducted	under	any	circumstances	within the	Washington,DC	Special	Flight	Rules	Area	(SFRA)	or	the	Washington,	DC	Flight	Restricted	Zone (FRZ).

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography ’s UAS	flights	will	be piloted	by	indi viduals	who	hold

, at	a	minimum

, Private	Pilot Certific ates and	if observers	are	not	qualified	pilots,	they	will	be	trained	by	to	understand	t he	proper roles	of	an	observer, communication	procedures,	proper	visual	scan	techniques, operations	at	non

- towered	airports,	and	appropriate	sections	of	the	Aeronautical Information	Manual	(AIM).		Proper	training	and	safety	is	of	upmost	importance.

Regulations from which the exemption is requested:

14	C.F.R.	Part	21 14	C.F.R.	45.23	(b) 14	C.F.R.	61.113(a)	and	(b) 14	C.F.R.	91.7	(a) 14	C.F.R.	91.9	(b)	(2)

14	C.F.R.	91.1 09

14	C.F.R	.	91.119

14	C.F.R.	91.121 14	C.F.R.	91.151(a) 14	C.F.R.	91.203	(a)	&	(b) 14	C.F.R.	91.205	(b)

14	C.F.R.	91.215 14	C.F.R.	(91.401

- 91.417)

Unmanned Aircraft System

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography requests to operate
DJI Phantom 2 Vision Plus , Phantom 3, and Inspire 1 multi

- rotor UAS ’ equipped with a

three

- axis gimbaled camera

. The UAS weigh s less than 25 lbs, have a built

- in c apability to limit the height the UAS flies above the ground, to limit the radius of the di stance it flies from the operator and to exclude it from Class A, B, C and D airspace including a no fly zones . Each system also has the failsafe function of the autopilot system, which means

when the communication between the main controller and the trans mitter is lost, the system will automatically “return to home” and will land safely. These UAS are considered COTS products and will not be altered or modified in any way.

The petitioner will only operate its UAS in line

- of

- sight of a pilot and/or obser ver and will operate at sites that are a safe distance from populated areas. UAS operators will insure that the UAS will create a nuisance or hazard for users of the NAS, the general public, livestock, pets, or wildlife.

When conducting UAS flights with in 3 miles of an airport, airport operators will be

notified and the UAS operator will give the right

- of

- way to avoid flying in the proximity

of full

- scale aircraft.The m aximum flight time for each operational flight will not exceed 60 minutes.

Flights will be terminated at 25% battery power reserve should that occur prior to the 60

minute limit.

The UAS will be programmed so that it will not be operated at an altitude of no more

than 600 feet AGL

.

The UAS operator will be a n FAA licensed airman holdin g, at a minimum an FAA

Private Pilot Certificate

.

The UAS proposed by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal).

The UAS will op erate at speeds not to exceed 55 knots.

G iven the small size of the UA S and the restricted environment within which they operate, the proposed UAS operations ad here to the Reform Act's safety requirements.

All UAS operators will be appropriately trained in small UAS operations including

familiarization with all applicable r egulations an d guidance documents; local area charts,

current NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human

Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather factors; Airmanship and Decision

- making and Safe Operating Procedures.

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography request s exemption under Section 333 to enable to operate safe, low

- risk commercial small UAV operations

for the activities summarized in this request

.

Sincerely,

Travi s J. Brown Chief Operating Officer SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography Alexandria, VA 22314 travis@travisjaybrown.com (571) 344

- 3554

Attachments:

A. Exemption Requests and Equivalent Level of Safety

B. Maintenance Log

C. Flight LogATTAC HMENT A

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

SkyVue	Technologies,	LLC	d/b/a	Travis	Jay	Brown	Photography requests an exemption from the following regulations as well as any additional regulations that may apply to the operation of the UAS :

14 CFR Part 21, Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While

the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental ce rtificate be issued for the DJI Phantom 2 Vision

Plus , Phantom 3, and Inspire 1 UAS.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number in l etters at least 3 inches high. Additionally, the aircraft must display

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The s mall UAS does not have an entrance in which the

word "EXPERIMEN TAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the pl acard on the top of the UAS.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and

61.133 Commercial pilot privileges and limitations.

The regulation provides that no person that holds a Privat e Pilot certificate may act as

P ilot in Command of an aircraft for compensation or hire. Subparagraph (b) allo ws a private pilot to act as Pilot in C ommand 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. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this a pplication is to conduct

a business.

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 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We

request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew durin g flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we

pr opose that a current, approved UAS Flight Manual must be available to the crew at the ground station at all times.

14 CFR 91.109 Flight Instruction; Simulated i nstrument flight and certain flight

tests

The regulation states "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully f unctioning dual controls." The UAS System ground

- based control station consis ts of a small hand

- held radio transmitter and while it

does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. W ith both student and instructor having

"hands

- on" the contr ols during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the aircraft cannot be operated

clo ser than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission

of the UAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Opera tions will only be flown over property or persons where permission has been obtained either verbally or in writing . The aircraft will be operated at a low altitude allowing, if there is a loss of propulsion , an emergency landing without undue hazard to per sons or property on
the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altime ter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an

altimeter setting available within 100 NM of the aircraft. The UAS will always fly below

600 feet AGL and will not need to maintain cruising altitudes in order to prevent confli ct
with other aircraft. An AGL altimeter measurement above the takeoff point is transmitted

via radio from the UAS on

- board computer to the display screen held by the UAS
operator , providing a constantly updated AGL readout.1 4 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

- VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buf fer for delays to landing. The UAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on

w hich UAS ) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We also request exemptio n from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides tha t an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockp it entrance so that it is l egible to passengers or crew." A small UAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA

will be collocated with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information found on

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, P reventive Maintenance,

Alterations

The regulation provides that the operator is primarily responsible for maintaining the

aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs

91.407 and 91.409 require that the aircraft be "approved for return to service by a person

authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the

aircraft for return to service." T he UAS operator will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections after every two hours of flight. Maintenance performed by the UAS operator is limited to repairing small cracks, replacing a propel ler, checking electrical and updating software

and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The UAS operator will document work performed in accor dance with 91.417 in the attached Maintenance Log

.ATTACHMENT B

MAINTENANCE LOG

MODEL: ______________________ _ SERIAL NUMBER: __________________

DATE SUMMARY OF MAINTENANCE SIGNATURE RETURN

TO SERVICEATTACHMENT B

FLIGHT LOG

DATE LOCATIO

N OPERATOR &

OBSERVER

NAME CUSTOMER MISSION DO VFR

CONDITIONS

EXIST AIRSAPCE

STATUS NOTES