### U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 January 22, 2016

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations 

### Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, AGCO Corporation ("Operator") requests an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix

### A. 1 

### Operator seeks the exemption to allow it to use Unmanned Aerial Systems (UASs) in commercial aerial videography and aerial data collection involving crop and field inspections for research use, inspection of prototype and commercial agricultural vehicles during in-field conditions, and demonstrations of in-field performance of agricultural vehicles for dealers and customers, so long as those operations are conducted within and under the conditions specified herein or as established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. 

### § 44701

### (f). The UASs to be used by the petitioner are the 3DR Solo. The FAA has previously granted an exemption request for use of the 3DR Solo for commercial purposes2 

### Because the 3DR Solo specified in this request is the same craft that the FAA has already approved, and because Operatorwill operate the aircraft fully in compliance with the conditions in exemption precedent, the FAA need not provide notice in the Federal Register oraskfor public comment. As a result, this exemption qualifiesfor summary processing. As described more fully below, the requested exemption would authorize commercial operations using the UASs, which have a weight of well under 55 pounds. The UASs will be operated at low altitude in limited airspace undercontrolled conditions; it has automated control features. Use of these small, lightweight UASs for the proposed uses will provide significant benefits, particularly as compared to using traditional aircraft for these purposes. The proposed uses improve overall safety of inspection operations, monitoring and research gathering operations normally conducted by manned aircraft, provide efficiencies and enhance decision-making ability through safe economical aerial based inspection and photography. Compliance with the requested strict operating conditions, as they may be modified by the FAA, will ensure at least an equivalent level of safety to currently authorized operations using manned aircraft and likely will provide a greater level ofsafety. Consequently, as discussed below, grant ofthis exemption would enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system."

1 See 

### Pub. Law 112-95, 126 Stat. 11, 

### § 333 (2012). 2 See Mr. Michaellntschert, 

### FAA Exemption No. 11832, Regulatory Docket No. FAA-2015-1166 (June 16, 2015).- 2- 

### Operator also requests a blanket Certificate of Waiver orAuthorization ("COA") forflights up to 200 feet above ground level in the form approved by the FAA. Operator acknowledges that current FAA guidance requires a separate COA to fly at altitudes above 200 feet above ground level, and it will apply for COAs when required. Operator will also file any required Notices to Airmen for its flights. The name and address ofthe applicant are: AGCO Corporation Attn: Jeffrey S. Ellsworth 420W. 

### Lincoln Blvd. Hesston, KS Ph: 620-327-5882 Email: jeff.ellsworth@agcocorp.com The regulations from which the exemption is requested are as follows: 14 C.F.R. 

### § 61.23(a) & 

### (c); 14 C.F.R 

### § 61.101(e)(4) & 

### (5) 14 C.F.R. 

### § 61.113(a); 14C.F.R. 

### § 61.315(a); 14 C.F.R. 

### § 91.7(a); 14 C.F.R. 

### § 91.119(c); 14 C.F.R. 

### § 91.121 14 C.F.R. 

### § 91.151(a); 14 C.F.R. 

### § 91.405(a); 14 C.F.R. 

### § 91.407(a)(1); 14 C.F.R. 

### § 91.409(a)(2); 14 C.F.R. 

### § 91.417(a) & 

### (b) Appendix A provides detail on each rule listed above and also explains why an exemption from each rule is not only appropriate, but will provide an equivalent level of safety and serve the public interest. THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 

### Approval of this exemption application to permit commercial use of the UAS will advance the Congressional mandate in Section 333 of the Reform Act to accelerate the introduction of unmanned aerial systems into the national airspace system ("NAS") if it can be accomplished safely. The Reform Act directs the Secretary of Transportation to consider whether certain UASs may operate safely in the NAS before completion of the rulemaking to establish general requirements for use of UASs. The Secretary must determine what types of UASs will not create a hazard to users of the NAS or the public and will not pose athreat to national security in light ofthefollowing:

• The size, weight, speed, and operational capability ofthe UAS; • Operation ofthe UAS close to airports and populated areas; and • Operation ofthe UAS within the visual line ofsight ofthe operator.- 3-



### Reform Act§ 333(a)(1). Once the Secretary determines that UASs "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." /d. 

### § 333(c) (emphasis added)-' PUBLIC INTEREST BENEFITS AND EQUIVALENT LEVEL OF SAFETY 

### The Federal Aviation Act also expressly provides that "[t]he Administrator may grant an exemption from a requirement of a regulation

.... or any of sections 44702-44716 ofthis title if the Administratorfinds the exemption is in the public interest." 49 U.S.C. §44701

### (f). See also 

### 49 U.S.C. §44711(a); 49 U.S.C. §44704; 14 C.F.R. § 91.203(a)(1). This statutory authority specifically includes exempting civil aircraft (as defined under §40101 of the Act) from the airworthiness certificate requirement and regulations requiring that aircraft in commercial service be operated by commercial pilots. This proposed exemption is in the public interest because of its evident equivalent level of safety, as well as the significant public benefit, including reduced costs and improved safety, that will result from its proposed use. This exemption will apply to the UASs when operated in accordance with the conditions proposed below. These conditions provide for at least an equivalent level of safety to operations with conventional aircraft under the current regulatory structure (and, in practice, a higher level ofsafety). Specifically, use ofajet or piston powered aircraft forthe purposes proposed in this application would be high risk, requiring operation very close to people and structures. Such vehicles weigh thousands of pounds, carry large amounts of highly flammable fuel, and provide limited maneuverability. In comparison, a small UAS like the 3DR Solo presents little risk as it weighs much less than 55 pounds with payload, is powered by batteries, and is designed to be highly maneuverable. In addition, the UAS will not carry any passengers or crew and, as a result, will not expose individuals to the risks associated with conventional flight. Thus, operation of this small craft, in accordance with the strict conditions listed below, will provide an equivalent level ofsafety that is more than sufficientto supportthe grant ofthe requested exemption. When conducting commercial operations, Operator agrees to be bound by the following limitations, which are drawn from the exemption granted to Aeryon Labs, Exemption No. 11213: 1. Operations authorized by this grant of exemption are limited tothe UASswhen weighing less than 55 pounds including payload. Proposed operations ofany other aircraftwill require a new petition or a petition to amend this grant. 2. Operations forthe purpose ofclosed-set motion picture and television filming are not permitted. 3. The UAS may not be operated at aspeed exceeding 87 knots (100 miles per hour). Operator may use either groundspeed or calibrated airspeed to determine compliance with the speed restriction. In no case will the UAS be operated at airspeeds greaterthan

3 

### This provision requires the Administrator both to process applications for Section 333 exemptions, but also, if he deems the conditions proposed in an application must be modified to allow approval, to supply conditions forthe safe operation ofthe UAS. Operator is willing to consult with the FAA staffto address any issues raised bythis application that may require such modifications.-4-

the maximum UAS operating airspeed recommended by the aircraft manufacturer, which in this case is 47.8 knots (55 miles per hour). 4. The UAS must be operated at an altitude ofno morethan 400feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device otherthan 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 UAS must be operated within the visual line ofsight (VLOS) ofthe 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. TheVO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated beforethe flight and cannottransfer his or herdesignation forthe duration ofthe flight. The PIC must ensure thattheVO can perform the duties required ofthe VO. 7. The exemption and all documents needed to operatethe UAS and conduct its operations in accordance with the conditions and limitations stated in the 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. Ifa discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Operator mustfollowthe procedures as outlined in its operating documents. The Operator may update or revise its operating documents. It is the Operator's responsibility to tracksuch revisions and present updated and revised documentstothe Administratororany lawenforcement official upon request. The Operator must also present updated and revised documents if it petitionsforextension or amendmenttothis grant ofexemption. Ifthe Operatordetermines that any update or revision would affect the basis upon which the FAAgranted this exemption, then the Operator must petition for an amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8. Any UAS that has undergone maintenance or alterations that affectthe UAS operation orflight characteristics, e.g., replacement ofaflight critical component, must undergo a functional testflight priorto conducting further operations underthis exemption. Functional testflights may only be conducted by a PIC with aVO and must remain at least 500 feet from other people. The functional testflight must be conducted in such a mannerso 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. Priorto each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safeflight. The pre-flight inspection must accountforall potential- 5 -
discrepancies, e.g., inoperable components, items, or equipment. Ifthe inspection reveals a condition thataffects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition forsafeflight. 11. The Operator mustfollow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements forthe aircraft and aircraft components. 12. Each UAS operated underthis exemption must complywith all manufacturersafety bulletins. 13. Underthis grant ofexemption, a PIC must hold eithera recreational orsport pilot certificate. The PIC must also hold a current FAAairman medical certificate ora valid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, aterritory, a possession, orthe Federal government. The PIC must also meetthe 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 consistentwith howthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distancesfrom persons, vessels, vehicles, and structures. PIC qualification flight hours and currency must be logged in a manner consistentwith 14 CFR 

### § 61.51(b). Flights forthe purposes oftraining the Operator's PICs and VOs (training, proficiency, and experience-building) and determining the PIC's abilityto safely operate the UAS in a mannerconsistentwith howthe UAS will be operated underthis exemption are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential forflight operations are considered nonparticipants, and the PIC must operate the UAwith appropriate distancefrom 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 undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UAS may not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAAAirport/Facility Directory (AFD) orfor airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chart, unless a letterofagreementwith that airport's management is obtained orotherwise permitted by a COA issued to the exemption holder. The letterof agreementwith the airport management must be made available to the Administrator or any law enforcement official upon request. 17. The UAS may not be operated less than 500feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC. 18. Ifthe UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private orcontrolled-access property. 19. The PIC must abortthe flight in the event ofunpredicted obstacles oremergencies.- 6-

20. The PIC is prohibited from beginning aflight unless (considering wind and forecast weather conditions) there is enough available powerforthe UAS to conductthe intended operation and to operate afterthatfor at leastfive minutes orwith the reserve power recommended bythe manufacturer ifgreater. 21. AirTraffic Organization (ATO) Certificate ofWaiverorAuthorization (COA). All operations shall be conducted in accordance with an ATO-issued COA. The exemption holder may applyfora neworamended COA ifit intends to conduct operations that cannot be conducted undertheterms ofthe attached COA. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part47, 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 bythe Operatorto ensure the safe operation and flight ofthe UAS and any documents required under 14 CFR 

### §§ 91.9 and 91.203 must be available tothe PIC atthe Ground Control Station ofthe UAS anytime the aircraft is operating. These documents must be made available to theAdministrator orany law enforcement official upon request. 24. The UAS must remain clear and give wayto all manned aviation operations and activities at all times. 25. The UAS may not be operated by the PIC from any moving device orvehicle. 26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers orstructures are presentthat sufficiently protect nonparticipating persons from the UAS and/ordebris in the event ofan accident. The Operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and, b. The owner/controllerofanyvessels, vehicles orstructures has granted permission for operating closerto those objects and the PIC has made asafety assessment ofthe risk ofoperating closer

### to those objects and determined that it does not present an undue hazard. The PIC, VO, Operatortrainees oressential persons are not considered nonparticipating persons underthis exemption. 27. All operations shall be conducted over private orcontrolled-access property with permission from the property 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, orflight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable GOA must be reported- 7-



### 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 NTSBWeb site: www.ntsb.gov. ******** Privacy. 

### Operatorwill conduct all UAS operations in compliance with applicable federal, state, or local privacy laws and regulations. National Security. 

### Grant ofthis exemption will not raise any national security issues. In light of the size, load carrying capacity, speed at which the proposed craft operates, and because 

### it carries no explosives or other dangerous materials, the UAS poses no threat to national security. ******** 

### For these reasons, Operator seeks an exemption from the FARs set forth in Appendix A to operate commercially a small unmanned vehicle (55 lbs. or less) in the use case described above. Operator's compliance with the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line of sight, and national security

- is more than sufficient to support grant of an exemption to allow commercial operation of Operator's UAS for the purposes outlined herein and is fully consistent with exemption precedent. The FAA should promptly grantthis request. 

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## S\;IEI~sw~ Director of Intellectual Property, North America AGCO Corporation-8-

APPENDIXA

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY DEMONSTRATION UNDER APPLICABLE RULES SUBJECTTO EXEMPTION
Operator requests an exemption from thefollowing regulations as well as any additional regulations thatthe FAAstaff may deem to applyto its utilization ofthe UASs in commercial activities: 14 C.F.R. 

### § 61.23(a) and (c): Medical Certificates: Requirement and Duration Sections 61.23(a) and (c) address the requirement ofmedical certificatesfor pilots. Section 61.23(a) requires a person exercising the privileges ofa recreational pilotto hold at least athird class medical certificate. Section 61.23(c) permits the holderofa sport pilot certificateto act as PIC ofa light-sport aircraftwith eithera medical certificate or U.S. issued driver's license. Lightsport aircraft mayweigh up to 1,430 pounds and seat upto two persons, including the pilot. The proposed craftweighs much less than 55 poundswith payload and will not carry pilots, passengers, or cargo. The proposed craft also will be operated within visual line of sight ofthe PIC and below400feet above ground level and limited to operationswith permission over private orcontrolled-access property. Given these safety parameters, Operator requests thatthe FAAwaive Section 61.23(a) upon a finding that an equivalent level ofsafetywill be provided by allowing operation ofthe proposed craft by pilotswith a recreational orsport pilot certificate and avalid U.S. state issued driver's license, in lieu ofan FAA-issued medical certificate. Operatoralso requests thatthe FAAgrant relieffrom Section 61.23(c) to allowsport pilot certificate holders to operate aircraft otherthan light-sport aircraftwith avalid U.S. issued driver's license. The FAA has granted exemptions to conductsimilar operations in a number ofcases, including Exemptions 11213 and 11832.

14 C.F.R. § 61.101(e)(4) & (5), 61.113(a), and 61.315(a): Recreational Pilot Privileges and Limitations; Private Pilot Privileges and Limitations: Pilot in Command; Whatare the privileges and limits ofmysport pilotcertificate? Sections 61.101(e)(4) & (5) and 61.113(a) limit recreational or private pilots to non-commercial operations. Unlike a conventional aircraftthat carries a pilot, passengers, and cargo, the proposed craft in this case is remotely controlled with no passengers orproperty ofothers on board. Section 61.315(a) addresses the privileges and limitations ofthe holder ofa sport pilot certificate. Operating conditions need to take into accountthe characteristics ofthe particular UAS. The proposed craft has a high degree of pre-programmed control and various built-in navigation and othertechnical capabilities that strictly limitthe potential for operation outside ofthe operating conditions setforth in the exemption application. Thesefeatures include:

• Geo-fencing function; • An automated "return home" function; • The ability to land the UAS at its current location;-9-

• A pause function that stops the UAS's movement and causes itto hover at its current location; • Automatic return home ifsignal link is lost; • Automatic return home ifthe battery charge level reaches 5 percent or less; and • The abilityto take manual control ofthe UAS in emergencies. In light ofthese safetyfeatures, operators ofthe proposed craft should not be required to hold a commercial pilot certification. Rather, possession ofa recreational orsport pilot certificate should suffice. Given the proposed craft's size, speed, lack offlammable fuel and operational capabilities, its operation presents much less riskthan associated with commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft). Operation as setforth herein meets or exceeds the present level ofsafety provided underthe regulations cited above and does not rise tothe level of requiring a commercial pilotto operate the aircraft. Thus, an equivalent level ofsafetywill be provided by allowing operation ofthe proposed craft with a recreational orsports pilot certificate, underthe conditions setforth in the exemption request. The FAA has granted exemptions to conduct similar operations in a numberofcases, including Exemptions 11213 and 11832.

14C.F.R. 

### § 91.7(a): Civil Aircraft Airworthiness. This regulation provides that no person may operate a civil aircraft unless it is in airworthy condition. In previous grants, the FAA has stated that, since the petitioner's UAVwill not require an airworthiness certificate, the pilot, for purposes ofthis rule, may determine the aircraft is in an airworthy condition priorto flight. Given the size ofthe aircraft and the requirementsto which the Operator has agreed relating to airworthiness, as setforth in the manual provisions, an equivalent level ofsafetywill be achieved by ensuring compliancewith the manual provisions priorto eachflight. The FAA has granted exemptions to conduct similaroperations in Exemptions 11062through 11067, 11080, 11109, 11110, 11136, 11138, 11213 and 11832.

14 C.F.R. 

### § 91.119(c): Minimum Safe Altitudes. Section 91.119 establishes safe altitudesforoperation ofcivil aircraft. Specifically, 91.119(c) limits aircraftflying overareas otherthan congested areasto an altitude of500 feet above the surface, except overopen waterorsparsely populated areas. In those cases, the aircraft may not be operated closerthan 500 feet to any person, vessel, vehicle, orstructure. The proposed craftwill never operate at higherthan 400 feetAGL. It also will be operated to avoid congested orpopulated areas. Because the proposed use must be accomplished at relatively lowaltitudes and at altitudes lessthan 500 feet AGL, an exemption from Section 91.119(c) is needed. Given the UASs' weight and speed and the material with which they are built, an equivalent level of safetywill be achieved. Moreover, as setforth in the proposed conditions, all flights will be conducted with the permission ofthe landowner orthosewho control the land as well as the permission oflocal officials, if required. Advance noticetothe landownerwill ensure that all affected individuals will be aware ofthe flights. Given the characteristics ofthe sUAS, any risk ofthese operations will be much less than the risks associated with similar operations by- 10-

conventional aircraftweighing thousands of pounds and carryingflammable fuel. In addition, given the limitations on the altitude of UAS operations, the UAS will maintain separation between its operations and the operations ofconventional aircraftthat must comply with Section 91.119. The FAA has granted exemptions to conduct similaroperations in Exemptions 11062 through 11067, 11080,11110, 11136, 11138, 11150, 11153, 11213, and 11832. [14 C.F.R. § 91.121: AltimeterSettings
Section 91.121 requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating below 18,000feet MSL to: (a) the current reported altimeter setting ofastation along the route and within 100 nautical miles ofthe aircraft; (b) ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimetersetting ofan appropriate available station; or (c) in the case ofan aircraft notequipped with a radio, the elevation ofthe departure airport or an appropriate altimetersetting available before departure.
To provide an equivalent level ofsafety, the 3DR Solo autopilot establishes the reference altitude (ground level) with the on-board GPS during the pre-flighttests. The UAS's barometer and GPS equipment ensure safety by providing the PIC with information concerning the altitude ofthe UAS during flight.]

14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatforat least45 minutes." The UAS's battery provides approximately 25 minutes of powered flight, approximately 20 minutes with payload. Without an exemption from 

### § 14 C.F.R. 91.151, flights ofthe proposed craftwould not be possible. In light ofthe limitations on its proposed operations and the location ofthose proposed operations, an exemption from Section 91.15(a) is reasonable. Operating the small UAS does not pose the kinds of risks that Section 91.151(a) was meantto prevent, particularly in light ofthe UAS' size and the speed at which it operates as well as its lack ofonboard pilot, passenger, orcargo. Further, ifthe UAS reaches a critical battery state, it simply returns to home and lands. Operator believes that an equivalent level ofsafety can be achieved by maintaining five minutes of reserve fuel, which, allowing approximately 15 minutes offlight time with payload, would be more than adequateto return the proposed craftto its planned landing zone from anywhere in its operating area. Similarexemptions have been granted to other operators, including Exemptions 11062through 11067, 11080, 11109,11110, 11112, 11136, 11138,11150, 11153,11213, and 11832.- 11

-

14C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections Section 91.405(a) requires that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 of this chapter

...." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requires the owneroroperatorto keep records showing certain maintenanceworkthat has been accomplished by certificated mechanics, under Part43, or licensed pilots and records ofapproval ofthe aircraftfor return to service. The Operator ofthe proposed craftwill perform maintenance in accordancewith the manual provisions. An equivalent level ofsafetywill be achieved becausethe small UAS is not a complex mechanical device, and it will carry asmall payload and operate only in restricted predetermined areas. As provided in the manual provisions, the Operatorwill ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenancethat is performed; moreover, the Operator is the person mostfamiliarwith the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. The FAA has granted exemptionsfor similar operations in Exemptions 11062through 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11213, and 11832.