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Midwest	Drone	Services/Aerial	Photography

Bill	Douglass,	member

4331	Panorama	Dr

Panora,	Iowa	50216

Cell	Phone: (901) 484-3055

Email:	billontheboard@netins.net

December	11,	2015

U.S.	Department	of	Transportation	(DOT)	

Subject:	Request	for	Issuance	of	Exemption	under	Title	14	CFR,	Seciton	333

To	whom	it	may concern,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	

CFR	Part	11,	Midwest	Drone	Services/Aerial	Photography,	and	Bill	Douglass,	

member,	hereby	applies	for	exemption	from	certain	Federal	Aviation	Regulations	

to	allow	for	the	commercial	operation	of	small	Unmanned	Aircraft	Systems	(sUAS)	

so	long	as	the	proposed	operations	are	conducted	within	and	under	the	conditions	

outlined	herein	or	as	may	be	established	by	the	FAA	as	required	in	accordance	

with	Section 333.

If	 granted,	 it	 is	 my	 intention	 to	 engage	 in	 the	 commercial	 operation	 of	 sUAS	 in	 order	 to	 offer	

services	to	multiple	industries	including	but	not	limited	to:

• Aerial	surveying	and	mapping

• Cell	tower	inspections

• Energy	Systems	inspections

• Pipeline	inspections

• Aerial	data	collection

• Residential	Real Estate	sales presentations

• Public safety support operations

• Development	Site	Planning

• Industrial	Site	Video

• Swimming	Pool	Construction/Advertising

• Construction	Review	and	Progress	Reports

• RV	Campground	or	Sales	Lot	Photography

• Golf	Course	and	Resort	Promotional	Photos	and	Video

• Planning	for	Horse,	Bike,	ATV	and	Walking	Trails

• Search	and	rescue	(lost	child,	etc.)

• Searching	for	dangerous	animals	(bear,	wolf,	etc.)

• Limited	Access/Disaster	Area	Surveying	

(sink	hole,	land	slide,	tornado	or	

hurricane,	flooding)
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The	requested	exemption	would	permit	the	operations	of	sUAS	by	the	applicant	under	controlled	

conditions	in	airspace	 that	is	1)	limited,	2)	predetermined,	3)	controlled	as	 to	access,	4)	would	

provide	safety	and	environmental	enhancements	not	possible	with	larger,	manned	aircraft,	and	

5)	mitigate	the	inherent	risk	associated	with	the	deployment	of	men and women	in	climbing	and	

/or	rappelling	operations	as	may	often	times	be required.

The	applicant	holds	an Air	Transport	Pilot	(ATP)	certificate,	a	current	1st class medical certificate,	

and	has	more	than	6000	hours	of	PIC	time	in	both	jet and	piston	aircraft,	thereby	demonstrating	an	

intimate	understanding	of	how	manned	aircraft	safely	navigate	the	National	Airspace	System.

Due	to	the	small	size	of	the	UA	and	the	restricted	areas	in	which	the	sUAS	will	operate,	the	

petitioner	asserts	approval	of	the	application	presents	no	national	security	issue.	Additionally,	

the	ability	to	conduct	the	types	of	missions	outlined	in	this petition	by	a	craft	significantly	

smaller	that	a	manned	aircraft	and	carrying	no	passengers,	crew	or	flammable	fuel	significantly	

enhances	safety	to	the	general	public	as	well	as	those	involved	with	the	mission.

Granting	the	requested	exemptions	is	in	the	public	interest	because	of	(1)	the	clear	direction	in	

section	333	of	Public	Law	112–95,	(2)	the	strong	equivalent	level	of safety	surrounding	the	

proposed	operations,	and	(3)	the	significant	public	benefit,	including	enhanced	safety	and	

reduction	in	environmental	impacts	(such	as	reduced	emissions	associated	with	allowing	sUAS	

for	photography	and	inspection operations).

Additional	consideration:

The	FAA	has	set	precedence	in	granting	petitions	to	other	entities	that	propose	to	engage	in	the	

same	or	similar	types	of	activities	under	essentially	the	same	operating	parameters.	Below	is	a	

list	of	exemptions	granted	which	we	believe	engage	in	similar	operations:

---11062	Astraeus	Aerial

---11109 Clayco	Inc.

---11112 VDOS	Global

---11213	Aeryon	Labs,	Inc.

---11969 HighGround	Images,	LLC

---11941 Soaring	Sky,	LLC

---11940	Aerial	Associates	Photography,	Inc.

---11947 Daniel	C.	Augspurger

Finally,	the	applicant	will	ensure	that	all	flights	will	be	operated	in	class	G	airspace	within	visual	

line	of	sight	(VLOS)	of	the	pilot	and/or	a	visual	observer	(VO)	under	daytime	VFR	flight	

conditions	as	defined	in	FAR	91.155.	For	flights	in	other	than	class	G	airspace,	the	controlling	

agency	will	be	notified	at	least	24	hours	in	advance,	and,	if	required,	any	necessary	permission	

will	be	obtained.	The	sUAS	will	be	limited	to	a	maximum	altitude	of	400	feet	AGL	or	100	feet	

above	an	elevated	launch	site.	The	applicant	will	keep	the	sUAS	clear	of	and	yield	the	right	of	

way	to	all	manned	operations	and	activities	at	all	times	(including	but	not	limited	to	ultra-light	

crafts,	skydiving	activities,	parasailing	activities,	hang	gliders,	and	hot	air	balloons.
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Name	and	address	of	the	applicant:

Bill	Douglass,	member

4331	Panorama	Dr

Panora,	Iowa	50216

Cell	Phone: (901) 484-3055

Email:	billontheboard@netins.net

Regulations	from	which	this	exemption	is	requested:

---14	CFR Part	21	Subpart	H

---14	CFR	Section	45.23(b)

---14	CFR	Section	61.113(a)	and	(b)

---14	CFR	Section	91.7(a)

---14	CFR	Section91.9(b)(2)

---14	CFR	Section 91.103

---14	CFR	Section	91.109

---14	CFR	Section	91.119

---14	CFR	Section	91.121

---14	CFR	Section	91.151(a)

---14	CFR	Section	91.405(a)

---14	CFR	Section	91.407(a)(1)

---14	CFR	Section	91.409(a)(1) and	(2)

---14	CFR	Section	91.417(a)	and	(b)

Description	of	proposed sUAS

The	applicant	proposed	to	utilize	the	Phantom	3	as	manufactured	by	DJI.	The	rotorcraft	weighs	

2.9	pounds	including	the	payload	that	consists	of	a	camera	sensor.	It	is	operated	from	the	ground	

utilizing	a	remote	controller	operating	at	a	frequency	of	2.400Ghz---2.483Ghz.	The	maximum	

airspeed	is	31	kts.	It	has	a	maximum	ascent	speed	of	985	feet	per	minute	and	a	maximum	descent	

speed	of	590	feet	per	minute.	The	Phantom	3	has	the	ability	to	hover,	and	move	in	the	vertical	

and	horizontal	plane	simultaneously.	It	is	equipped	with	integral	GPS	and	One-touch	auto	return	

home	technology.	It	is	also	equipped	with	an	intelligent	battery	which	will	provide	

approximately	23	minutes	of	flight	time,	and	will	cause	the	unit	to	return	to	the	takeoff	point	

upon	detection	of	low	battery	power	or	the	loss	of	connection	with	the	remote	control	unit.	

Please	see	the	manufacturer’s	specifications	attached	in	Appendix	“A”.

Safety

The	following	operating	procedures	will	apply	during	the	sUAS	and	operations	under	this	

exemption	request:

1. Any	and	all	required	permissions	and	permits	will	be	obtained	from	appropriate	state,	

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

governmental	agency.

2. Approval	will	be	obtained	from	relevant	property	owners	prior	to	an	operation.
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3. The	sUAS	to	be	deployed	by	the	applicant	is	the	Phantom	3	by	DJI,	which	has	an	operational	

weight	of	2.9	pounds.	See	the	complete	specifications	attached	herewith.

4. The	sUAS	pilot	in	command	(PIC)	will	be	trained	in	advance	for	the	safe	operation	of	the	

sUAS	to	be	operated.		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.	Knowledge	level	will	include	

operation	of	the	sUAS	in	both	normal	and	failsafe	modes	of	operation,	and	will	include	

familiarization	with	the	operation	manual	as	published	by	the	manufacturer	attached	as	

Appendix	“C”

5. All	operations	will	be	conducted	:

i. within	visual	line	of	sight	of	the	PIC

ii. utilizing	a	visual	observer	(VO)	if	the	sUAS	will	be	flown	beyond	the	line	of	

site	of	the	PIC

iii. at	less	than	400	feet	AGL	or	100	feet	above	an	elevated	launch	area

iv. within	class	G	airspace	unless	permission	is	received	at	least	24	hrs.	in	

advance	of	the	planned	flight.

v. under	daytime	VFR	conditions	as	defined	by	FAR	91.155.

vi. at	least	5	miles	from	Airport	Reference	Point

6. If	a	VO	is	required,	2-way	communications	between	the	PIC	and	the	VO	must	be	maintained	

for	the	duration	of	the	flight.

7. The	flight	area	of	the	sUAS	will	be	observed	for	best	takeoff	and	landing	locations.	Desired	

conditions	include	flat	and	level	surfaces	clear	of	debris,	at	least	15’	from	power	lines	and	

structures,	and	a	minimum	of	12’	from	PIC	and	Visual	Observer.

8. All	batteries	will	be	fully	charged	before	each	flight	and	each	flight	will	be	terminated	

when	the	battery	has	20%	power	level	remaining.

9. A	visual	safety	inspection	will	be	conducted	before	each	flight	to	ensure	the	

airworthiness	of	the	sUAS	in	accordance	with	the	manufacturer’s	operating	instructions	

and	the	open	pilot	preflight	checklist	(see	appendix	“B”).	This	will	include	checking	the	

propeller	tightness,	the	security	of	the	bumper	guards,	and	remote	controls.

10. A	preflight	briefing	will	be	issued	by	the	PIC	to	all	personnel	included	in	the	operation	

prior	to	launch.	All	personnel	who	will	be	performing	duties	for	the	operation	will	be	

present	for	the	briefing.

11. If	appropriate,	for	the	operation,	the	sUAS	will	utilize	GPS	navigation,	failsafe,	and	

Return	to	Home	(RTH)	and/or	flight	abort	safety	features.

Relief	requested
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Part	21,	Certification	Procedures	for	Products	and	Parts,	prescribes,	in	pertinent	part,	the	

procedural	requirements	for	issuing	and	changing	design	approvals,	production	approvals,	

airworthiness	certificates,	and	airworthiness	approvals.

The	applicant	requests	an	exemption	from	14	CFR	Part	21,	Subpart	H	and	the	requirement	

for	an	airworthiness	certificate	in	general.

Section	45.23(b)	prescribes,	in	pertinent	part,	that	when	marks	include	only	the	Roman	capital	

letter	“N”	and	the	registration	number	is	displayed	on	limited,	restricted,	or	light---sport	category	

aircraft	or	experimental	or	provisionally	certificated	aircraft,	the	operator	must	also	display	on	

that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	

inches	nor	more	than	6	inches	high,	the	words	“limited,”	“restricted,”	“light-sport,”	

“experimental,”	or	“provisional,”	as	applicable.

Due	to	the	small	size	of	the	sUAS,	the	applicant	requests	an	exception	from	14	CFR	

45.23(b)	that	would	allow	the	sUAS	to	display	the	registration	number	in	letters	and	

numbers	as	large	as	practical	on	it’s	fuselage.

Section	61.113(a)	and	(b)	prescribes	that—

(a) No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	(PIC)	of	

an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire;	nor	may	

that	person,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft.

(b) A	private	pilot	may,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft	in	connection	

with	any	business	or	employment	if:

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

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

Because	the	sUAS	is	incapable	of	carrying	a	pilot	or	passengers,	and	due	to	the	controlled	

area	of	operation,	the	applicant	seeks	an	exemption	from	this	regulation.	The	applicant	is	

the	holder	of	a	private	pilot	certificate.	We	believe	that	the	private	pilot	certification	

coupled	with	appropriate	training	as	outlined	in	the	flight	training	manual	for	this	sUAS	

(attached	in	Appendix	“C”)	exceeds	the	level	of	safety	provided	by	a	single	pilot	holding	a	

commercial	pilot’s	certificate	operating	in	a	conventional	aircraft.

Section	91.7(a)	prescribes	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	

condition.

Given	that	if	this	exemption	is	granted,	there	will	be	no	airworthiness	certificate,	and	no	

standard	exists	for	an	aircraft	of	this	type.	We	propose	to	utilize	the	manufacturer’s	

operating	and	maintenance	manual	in	conjunction	with	the	open	pilot	preflight	checklist	

attached	herewith	as	exhibit	“B”	to	assess	the	airworthiness	of	the	sUAS.
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Section	91.9(b)(2)	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	U.S.---registered	

civil	aircraft	unless	there	is	available	in	the	aircraft	a	current	approved	Airplane	or	Rotorcraft	

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

Due	to	the	size	and	configuration	of	the	sUAS,	there	is	no	room	or	capacity	to	carry	such	an	

item	on	the	aircraft.	We	propose	maintaining	and	equivalent	level	of	safety	by	keeping	the	

manual	at	the	ground	control	point	where	the	pilot	flying	the	sUAS	will	have	immediate	

access	to	it.

Section	91.103	prescribes	that	each	PIC	shall,	before	beginning	a	flight,	become	familiar	with	all	

available	information	concerning	that	flight,	to	include—

(a) For	a	flight	under	instrument	flight	rules	(IFR)	or	a	flight	not	in	the	vicinity	of	an	

airport,	weather	reports	and	forecasts,	fuel	requirements,	alternatives	available	if	the	

planned	flight	cannot	be	completed,	and	any	known	traffic	delays	of	which	the	PIC	has	

been	advised	by	air	traffic	control	(ATC);

(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	landing	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	aircraft	

performance	under	expected	values	of	airport	elevation	and	runway	slope,	

aircraft	gross	weight,	and	wind	and	temperature.

We	request	an	exemption	from	14	CFR	91.103	as	FAA	approved	flight	manuals	will	not	be	

used.	In	the	absence	of	the	flight	manuals,	the	PIC	will	take	all	pre-flight	actions	including	

but	not	limited	to	reviewing	weather,	flight	battery	requirements,	launch	and	landing	area	

assessments,	and	aircraft	performance	data	before	commencing	a	flight.

Section	91.109	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil	aircraft	(except	a	

manned	free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	fully	

functioning	dual	controls.

We	request	an	exemption	from	14	CFR	91.109	as	evidence	is	inconclusive	that	a	person	

with	a	sport	pilot	certificate	can	successfully	maneuver	or	train	someone	in	the	safe	

operation	and	maneuvering	of	a	sUAS	without	first	hand	flight	experience	with	the	

particular	sUAS.	Therefore	the	training	we	will	offer	will	provide	an	equivalent	level	of	

safety.

Section	91.119	prescribes	that,	except	when	necessary	for	takeoff	or	landing,	no	person	may	

operate	an	aircraft	below	the	following	altitudes:
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(a) Anywhere.	An	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing	without	

undue	hazard	to	persons	or	property	on	the	surface.

(b) Over	congested	areas.	Over	any	congested	area	of	a	city,	town,	or	settlement,	or	over	

any	open---air	assembly	of	persons,	an	altitude	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	paragraph	(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.

We	request	an	exemption	from	14	CFR	91.119	as	we	believe	an	equivalent	level	of	safety	

will	be	achieved	given	the	size,	weight,	and	speed	of	the	sUAS.	No	flights	will	be	taken	

without	proper	notices	given,	and	permission	being	received	from	the	property	owners,	

therefore	adequate	notice	will	be	provided	for	any	individuals	that	may	be	affected	by	the	

operation.	Additionally,	since	there	is	no	flammable	fuel	load,	any	potential	risk	

associated	with	these	operations	is	far	less	than	those	presently	presented	utilizing	

conventional	aircraft	operating	below	500	ft.	AGL.	Finally,	the	low	altitude	restriction	of	

the	sUAS	operations	will	ensure	separation	between	the	sUAS	and	conventional	aircraft	

that	must	comply	with	this	section.

Section	91.121	prescribes,	in	pertinent	part,	that	each	person	operating	an	aircraft	shall	maintain	

the	cruising	altitude	by	reference	to	an	altimeter	that	is	set	when	operating	below	18,000	feet	

mean	sea	level	(MSL)	to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	setting	

available	before	departure.

We	request	an	exemption	from	14	CFR	91.121	as	the	sUAS	is	not	equipped	with	a	

barometric	altimeter,	but	instead	outputs	GPS	altitude	data.	An	equivalent	level	of	safety	

will	be	achieved	by	the	PIC	verifying	the	altitude	at	the	launch	site	prior	to	and	during	the	

flight.

Section	91.151(a)	prescribes	that	no	person	may	begin	a	flight	in	an	airplane	under	visual	flight	

rules	(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—
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(1) During	the	day,	to	fly	after	that	for	at	least	30	minutes;	or

(2) At	night,	to	fly	after	that	for	at	least	45	minutes.

We	seek	an	exemption	from	14	CFR	151	as	we	believe	we	can	achieve	an	equivalent	level	

of	safety	by	requiring	an	operation	to	be	terminated	when	the	indicated	battery	power	

reaches	20%.	This	would	provide	more	than	sufficient	time	for	the	sUAS	to	return	to	its	

planned	landing	zone	from	anywhere	in	the	limited	operating	area.

Section	91.203(a)	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil	aircraft	unless	

it	has	within	it—

(1)	An	appropriate	and	current	airworthiness	certificate;	and

(3)	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).

Section	91.203(b)	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil	aircraft	unless	

the	airworthiness	certificate	or	a	special	flight	authorization	issued	under	§	91.715	is	displayed	

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

We	request	an	exemption	from	14	CFR	203(a)	and	(b).	Since	the	UAS	weighs	less	than	3	

pounds	carries	no	pilot	or	crew,	and	has	no	cockpit	or	cabin.	We	propose	to	keep	these	

documents	at	the	ground	control	point	where	the	PIC	will	have	immediate	access	to	them,	

to	the	extent	they	may	be	applicable	to	the	sUAS.

Section	91.405(a)	prescribes,	in	pertinent	part,	that	each	owner	of	an	aircraft	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,	Maintenance,	Preventive	Maintenance,	Rebuilding,	and	Alteration.

Section	91.407(a)(1)	prescribes	that	no	person	may	operate	any	aircraft	that	has	undergone	

maintenance,	preventive	maintenance,	rebuilding,	or	alteration	unless	it	has	been	approved	for	

return	to	service	by	a	person	authorized	under	§	43.7	of	this	chapter.

Section	91.409(a)(2)	prescribes,	in	pertinent	part,	that	no	person	may	operate	an	aircraft	unless,	

within	the	preceding	12	calendar	months,	it	has	had	an	inspection	for	the	issuance	of	an	

airworthiness	certificate	in	accordance	with	part	21.

Section	91.417(a)	and	(b)	prescribe,	in	pertinent	part,	that—

(a) Each	registered	owner	or	operator	shall	keep	the	following	records	for	the	periods	

specified	in	paragraph	(b)	of	this	section:

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

records	of	the	100-hour,	annual,	progressive,	and	other	required	or	approved	
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inspections,	as	appropriate,	for	each	aircraft	(including	the	airframe)	and	each	

engine,	propeller,	rotor,	and	appliance	of	an	aircraft.

																													The	records	must	include—

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

of	the	work	performed;	and

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

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

aircraft	for	return	to	service.

(2) Records	containing	the	following	information:

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

and	each	rotor.

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

propeller,	rotor,	and	appliance.

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

are	required	to	be	overhauled	on	a	specified	time	basis.

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

last	inspection	required	by	the	inspection	program	under	which	the	

aircraft	and	its	appliances	are	maintained.

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

safety	directives	including,	for	each,	the	method	of	compliance,	the	

AD	or	safety	directive	number	and	revision	date.	If	the	AD	or	safety	

directive	involves	recurring	action,	the	time	and	date	when	the	next	

action	is	required.

(vi) Copies	of	the	forms	prescribed	by	§43.9(d)	for	each	major	alteration	

to	the	airframe	and	currently	installed	engines,	rotors,	propellers,	

and	appliances.

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

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

the	work	is	repeated	or	superseded	by	other	work	or	for	1	year	after	the	work	

is	performed.

(2) The	records	specified	in	paragraph	(a)(2)	of	this	section	shall	be	retained	and	

transferred	at	the	time	the	aircraft	is	sold.
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(3) A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§	43.11	of	

this	chapter	shall	be	retained	until	the	defects	are	repaired	and	the	aircraft	is	

approved	for	return	to	service.

We	request	an	exemption	from	14	CFR	91.405(a),	91.407(a)(1),	91.409(A)(2),	and	

91.417(a)	and	(b)	as	we	believe	these	sections	apply	only	to	aircraft	with	an	airworthiness	

certificate.	The	applicant	will	meet	all	maintenance	requirements	as	prescribed	by	the	

manufacturer	in	accordance	with	the	operating	manual.	This	will	provide	an	equivalent	

level	of	safety	given	the	small	size	of	the	sUAS,	the	proximity	to	the	PIC	during	flight,	the	

short	duration	of	flights	and	the	low	altitude.		In	the	event	of	a	mechanical	issue,	the	sUAS	

can	land	immediately.	The	PIC	will	ensure	the	sUAS	is	in	proper	working	order	prior	to	

initiating	flight,	perform	all	required	maintenance,	and	keep	a	log	of	any	maintenance	

performed.

Attachments:

---Appendix	“A”	DJI	Phantom	3	Series	Specifications

---Appendix	“B”	Pilot	Preflight	Checklist

---Appendix	“C”	DJI	Phantom	Pilot	Training	Guide