Page	| 1 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	m ay c oncern,

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14 CFR	Part	11, Midwest	Drone	Service s / 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

• Ce l l	t o w e r i n s p ec t io ns

• Energy	Systems	inspections

• Pipel i ne i n s p ec t io ns

• Aerial	data	collection

• Residentia l Rea l E stat e s ales p r e s entations

• Public safe t y support opera t ions

• 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	res cue	(lost	child,	etc.)

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

• Limited	Access/Disaster	Area	Surveying (sink	hole,	land	slide,	tornado	or hurricane,	flooding)Page	| 2 The	requested	exemption	would	permit	the	operations	of	sUAS	by	the	applicant	under	con trolled conditions	in	airspace	 that	is	1)	limited,	2)	predetermined,	3)	controlled	as	 to	access,	4)	would provide	safety	a n d	environmental	enhancements	not	possible	with	larger,	manned	aircraft,	and 5)	mitigate	the	inherent	risk	associated	with	the	deploym ent	of	men and women	in	climbing	and /or	rappelling	operations	as	may	often	times	be required.

The applicant	holds	a n 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	siz e	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	signifi cantly 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	r educed	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	unde r	essentially	the	same	operating	parameters.	Below	is	a list	of	exemptions	granted	which	we	believe	engage	in similar operations :

- -- 11062	Astraeus	Aerial

- -- 11109 Cla yc o I nc.

- -- 11112 VDOS G lobal

- -- 11213	Aeryon	Labs,	Inc.

- -- 11969 HighGround	Images,	LLC

- -- 11941 S oaring S k y ,	LLC

- -- 11940	Aerial	Associates	Phot ography,	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	s UAS	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	(inc luding	but	not	limited	to	ult ra

- light crafts,	skydiving	activities,	parasailing	activities,	hang	gliders,	and	hot	air	balloons.Page	| 3 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 Su b par t	H

- -- 14	CFR Sectio n	45.23(b)

- -- 14	CFR Sectio n	61.113(a) an d	(b)

- -- 14	CFR Sectio n	91.7(a)

- -- 14	CFR Sec t ion91.9( b )(2)

- -- 14	CFR Sec tion 91.103

- -- 14	CFR Sectio n	91.109

- -- 14	CFR Sectio n	91.119

- -- 14	CFR Sectio n	91.121

- -- 14	CFR Sectio n	91.15 1 (a)

- -- 14	CFR Sectio n	91.405(a)

- -- 14	CFR Sectio n	91.407(a)(1)

- -- 14	CFR Sectio n	91.409(a)(1) an d	(2)

- -- 14	CFR Sectio n	91.417(a) an d	(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	m aximum	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	i s	equipped	with	i ntegral	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	o peration.Page	| 4 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	operati on	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,	th e	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	publ ished	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	req uired,	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	debr is,	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	tightn ess,	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	b riefing.

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	requestedPage	| 5 Part	21,	Certification	Procedures	for	Products	and	Parts,	prescribes,	in	pertinent	p art,	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	experime ntal	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,”	“ligh t

- 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	practica l	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	c ompensation	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	holdin g	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	airworthines s	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	airworthines s	of	the	sUAS.Page	| 6 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	groun d	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	un der	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	advi sed	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	aircraf t 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,	t he	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	par t,	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:Page	| 7 (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	2,00 0	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,	o r	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	t he	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	th ese	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	eleva tion	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

—Page	| 8 (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	pe rson	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	2 03(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	applica ble	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	thi s	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	maintenanc e,	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	approvedPage	| 9 inspections,	as	appropriate,	for	each	aircraft	(inc luding	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	comp letion	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	di rectives	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	se ction	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.Page	| 10 (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	pr ovide	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	sU AS	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