September 1, 2015

Exemption No. 12693

Regulatory Docket No. FAA−2015−1510

Mr. David Mason

Project Manager

Nobles Consulting Group

2844 Pablo Avenue

Tallahassee, FL 32309

Dear Mr. Mason:

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 letters dated April 27 and July 23, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Nobles Consulting Group (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial imagery in support of surveying and mapping operations.

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

the regulations that the petitioner seeks an exemption.

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

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

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

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 and DJI Phantom 2 Vision.

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

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

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
2

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

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

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

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

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

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

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

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

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

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

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

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

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

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

by this exemption is in the public interest.

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

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

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

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

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

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, Nobles Consulting Group is granted an exemption from 

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

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

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

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

 

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

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

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

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, Nobles Consulting Group is hereafter referred to as the operator.

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

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and 

the DJI Phantom 2 Vision when weighing less than 55 pounds including payload. 

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

amend this exemption.

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

not permitted. 

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

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

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

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

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

U.S. driver’s license.

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

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

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

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

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

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, 
4

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

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

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

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

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

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

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

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

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

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

in a condition for safe operation.

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

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

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

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

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

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

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

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

aircraft components.

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

safety bulletins.

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

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

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

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

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

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

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

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

operated under this exemption, including evasive and emergency maneuvers and 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

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

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

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

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

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

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

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

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

power recommended by the manufacturer if greater.

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

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

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

operations that cannot be conducted under the terms of the attached COA.
6

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

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

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

be as large as practicable.

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

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

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

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

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

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

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

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

present an undue hazard.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

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

contained on the NTSB Web site: www.ntsb.gov.
7

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

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

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

as documented in this grant of exemption.

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

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

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

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

must include at least the following:

a. Dates and times for all flights;

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

under this grant of exemption;

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

the UAS;

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

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

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

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

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

g. Signature of exemption holder or representative; and

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

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

essential to accomplish the operation.

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

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

exemption holder’s MPTOM.

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

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

parts 45, 47, 61, and 91.
8

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 27, 2015 

Nobles Consulting Group 

Attn: David Mason 

2844 Pablo Ave 

Tallahassee, FL 32309\ 

850-385-1179 Ext 322 

U.S. Department of Transportation 

Docket Management System 

West Building – Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Regarding: Petition for Exemption Pursuant to Section 333 of the FAA Reform Act of 2012 

and Part 11 of the Federal Aviation Regulation and Relief Pursuant to Title 14 

Chapter 1 Subpart 11 Section 61(b). 

Dear Madam or Sir, 

Section 333 of the Reform Act grants the Secretary the authority to assess and make a 

determination through an exemption process if an unmanned aircraft system of appropriate size, 

weight, and operational capabilities operated in a specified manner does not pose a threat to 

users, bystanders, National Airspace System (NAS) and National Security. Section 333 also 

provides that the Secretary can determine whether a certificate of waiver, certificate of 

authorization or airworthiness certification under section 44704 of Title 49 USC is required for 

unmanned aircraft and establish requirements for safe operation of the Unmanned Aerial 

Systems (UAS) in the NAS. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 

14 C.F.R. Part 11, Nobles Consulting Group, Inc., (NCG) a Surveying and Engineering Company, 

seeks exemption from the Federal Aviation Regulations of Title 14 CFR’s listed below: 

• Part 21 - Certification Procedures for Products and Parts 

• 45.23 - Display of marks; general 

• 45.29 – Size of Marks 

• 61.23 – Medical Certificates: Requirements and duration
Page 2 of 6

• 61.3 – Requirements for certificates, ratings and authorizations 

• 61.113 (a) & (b) - Private Pilot Privileges and Limitations: Pilots in Command 

• 61.133 (a) Commercial Pilot Privileges and limitations 

• 91.7(a) – Civil Aircraft Airworthiness 

• 91.9 - Civil Aircraft Flight Manual, Marking and Placard Requirements 

• 91.109 (a) – Flight Instruction: Simulated Instrument flight and Certain Flight Tests 

• 91.119 – Minimum Safe Altitudes; General 

• 91.121 – Altimeter Settings 

• 91.151 (a) – Fuel Requirements for Flight in VFR Conditions 

• 91.203 – Civil Aircraft Certifications Required 

• 91.405 (a) – Maintenance Required 

• 91.407 (a) 1. – Operation After Maintenance, Preventative Maintenance, rebuilding, or 

Alteration 

• 91.409 (a) 2 – Inspections 

• 91.417 (a) and (b) – Maintenance Records 

In addition to the above request; Pursuant to Title 14 Chapter 1 Subchapter B Part 11 Subpart A 

Section 11.61(b) Using a petition for exemption, you may ask FAA to grant you relief from 

current regulations in 14 CFR. In accordance with Title 14 Chapter 1 Subchapter B Part 11 

Subpart A Section 11.61(b), NCG seeks relief from the requirement that the Pilot in Command 

(PIC) have at a minimum Pilot Certification of Sport Pilot and that a visual observer be required 

as has been prescribed in some of the more recent Section 333 Exemptions issued in order to 

commercially operate a small UAS in the NAS. 

It is understood that UAS are not manned aircraft, however, many of them are battery operated, 

have limited operating time windows due to battery life, have distance from operator limitations 

based on radio control efficacy and built in flight safety parameters. However, Pursuant to title 

14 Chapter 1 Subchapter F Part 103 Ultralight Vehicles, Ultralight Vehicles are not authorized 

for commercial use, can operate if unpowered or powered if weighing under 254 pounds, have 

fuel capacity of not more than 5 U.S. Gallons, and cannot travel at more than 55knots at full 

power. However, Unlike the requirements that UAS operator are compelled to adhere to, Under 

Section 103.7 – Certification and registration – Ultralight vehicles are not required to meet 

airworthiness standards, the operators of these aircraft are not required to meet aeronautical 
Page 3 of 6

knowledge requirements, nor are there age or experience requirements in order to operate 

them. In addition there is no requirement that there be medical certification for operation. Given 

that these aircraft can occupy the same airspace as commercial small frame UAS operations 

through 333 Exemption, the same dangers persist for other aircraft in the area. 

Based on the above argument, NCG requests that their PIC of flight operations for commercial 

UAS services be required to have the same level of pilot certification as those that operate 

Ultralight aircraft. However, understanding that airspace safety is of paramount importance, any 

NCG UAS pilot will first be required to participate in a UAS based ground school with a focus on 

FAA flight regulation and requirements, and participate in appropriate UAS flight training in 

accordance with aircraft platform and manufacturer specifications. In addition, in order to 

provide a level of security, any NCG UAS pilot must also undergo and clear a background check 

thorough enough to obtain a Transportation Worker Identification Credential (TWIC) card. 

An exemption is being requested because; 1.) Existing current regulations do not allow NCG to 

commercially operate UAS in the NAS. 2.) NCG can provide safe operation of the subject UAV 

at a level that is equal to or greater than safety levels described by current regulation. 3.) The 

request is in the public interest. 

As more fully described below, the requested exemption would authorize NCG to utilize small 

relatively inexpensive (under 5 pounds) UAS for low altitude aerial imagery in support of 

surveying and mapping operations, in the United States. All UAS flight operations will occur 

only during daylight hours in predetermined limited airspace that is well defined by project 

boundaries. All flight operations be guided by Advisory Circular AC 91-57, and the Academy of 

Model Aeronautics (AMA) National Model Aircraft Safety Code relating to Model Aircraft 

Operation. 

The specific UAS’s that are proposed for use are quad copters manufactured by DJI and include 

the DJI Phantom II and the DJI Phantom Vision 2. Significant description of aircraft origin, 

capabilities, and safety features can be found in Singer’s Creations request for Exemption FAA 

Docket ID: FAA-2014-0915-0001. 

Operationally, NCG Provides that: 
Page 4 of 6

1. All NCG Flights will follow guidelines set forth in FAA Advisory Circular 91-57 and the 

Academy of Model Aeronautics National Model Aircraft Safety Code. 

2. The UAS will weigh less than 5 lbs. 

3. Flights will be operated within unaided visual line of sight (VLOS) of a Pilot in Command 

(PIC). 

4. Maximum total flight time for each operational flight will be 20 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 20 minute limit. 

5. Flights will be operated at an altitude of no more than 400 feet 

6. A Pre Flight Check and Aircraft internal Compass calibration will be conducted prior to 

each flight to ensure proper operation of the aircraft. 

7. Any NCG PIC will have taken and passed an initial aeronautical knowledge test, will 

have aircraft flight training as suggested by the manufacturer and will have been vetted 

by the TSA via issuance of a of Transportation Worker Identification Credential 

(TWIC) card

8. The UAS will only operate within an area of a well-defined boundary as requested and 

specified in any authorized Certificate of Operation (COA) applied for and received by 

NCG. 

9. A flight plan will be prepared and a briefing will be conducted in regard to the planned 

UAS operations prior to each flight operation. It will be mandatory that all personnel who 

will be performing duties within the boundaries of the safety perimeter be present for this 

briefing. 

10. The operator will obtain the consent of all persons involved in the flight area and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation. 

11. Written and/or oral permission from the relevant property holders will be obtained. 

12. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

13. If the UAS loses communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

   
Page 5 of 6

Summary

Nobles Consulting Group, Inc. is seeking relief In accordance with Section 333 of the 

FAA Modernization Act and 14 CFR Chapter 1 Section 11.61(b) from specific 

requirements of Title 14 of the Code Of Federal Regulations. Part 21, Part 45 Sections 

45.23 and 45.29; Part 61 Sections 61.23, 61.3, 61.113 (a)&(b), and 61.113(a); Part 91 

Sections 91.7(a), 91.9, 91.109(a), 91.119, 91,121, 91.151(a), 91.203, 91.405(a), 

91.407(a)1 and 91.417 (a)&(b). Filed by David Mason, Nobles Consulting Group, 2844 

Pablo Ave, Tallahassee, FL 32308. Tel: (850)-385-1179. Fax (850) 385-1404. 

David@NCGinc.com
Page 6 of 6

Appendices 

Table of Contents 

Advisory Circular 91-57 – Model Aircraft Operating Standards 

Academy of Model Aeronautics National Model Aircraft Safety Code 

Singer’s Creations - FAA Docket ID: FAA-2014-0915-0001. 

DJI Phantom II Training Guide 

DJI Phantom II Owner’s Manual 
2844 PABLO AVENUE -IIIINCG TALLAHASSEE, FL 32308 

P:850.385.1179 

NOBLES CONSULTING.GROUP,INC F:850.385.1404 

July 23, 2015 

U.S. Department of Transportation 

Docket Management System 

West Building — Ground Floor, Room W 12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Regarding: FAA Docket Number 2015-1510-002 Notice of Request for Additional Information 

Dear Madam or Sir, 

We are in receipt of your request for additional information and seek to continue review of our 

exemption request. In response to your request for additional information it has been noted that 

in order for our application to be considered further we must submit the following: 

"The reasons why granting the request would be in the public interest: that is, how it would 

benefit the public as a whole." 

and 

"Any additional information, views, or arguments available to support your request." 

In response to your request for additional information we provide the following: 

The use of UAS for the proposed operations will provide significant public benefit, including 

reduction of environmental impacts such as reduced emissions associated with UAS use for 

aerial data collection as opposed to normal full sized rotary or fixed wing aircraft. Also the use 

of UAS for the proposed operations can reduced the time of aircraft exposure in the NAS. The 

aircraft selected is battery operated, can take off and land vertically and use will be confined to 

the area of operation instead of having to travel from another location. Also, since the proposed 

UAS is battery powered and carries no fuel reducing risk of fire of fuel spillage or in the event of 

a mishap thus benefitting public safety. 

Additionally, NCG is seeking exemption from pilot certification requirements to utilize UAS 

commercially, NCG's exemption request specifically states that any NCG Pilot in Command 

PENSACOLA NICEVILLE CHIPLEY TALLAHASSEE VALDOSTA 
(PIC) will be required to participate in and satisfactorily complete in a UAS Based ground school 

with a focus on FAA flight regufation and requirements, and participate in appropriate UAS flight 

training in accordance with aircraft manufacturer requirements. For security purposes, NCG 

has provided that any NCG PIC will have to undergo and clear a background check thorough 

enough to obtain a Transportation Worker ldentification Credential (TWIC) card. Although, this 

is not in keeping with how recent exemptions have been issued, the level of safety provided will 

be equivalent to those that have been previously granted Section 333 exemptions and is in the 

public interest and will benefit the public in that the operator will be trained. The requirement 

that the PIC must have pilot certification is not a guarantee that the UAS will be operated in a 

safe manner. For many certified pilots, being a PIC for a UAS is outside of their core 

competency and training is still required. The only difference is that the certified pilot has actual 

in the air flight time and has undergone training for operating in the NAS. This is why NCG 

provides that any PIC is required to have formal training on flight regulation, and flight training 

with the proposed airframe. NCG's approach is inherently more safe than the average uncredentialed hobbyist flying unregistered aircraft in the NAS without any formal training 

regarding FAA rules and regulations. Although we don't like to think about it, this is an all too 

often occurring scenario since the advent of the "off the shelf' easily flown UAV's. Additionally, 

there are companies that are currently providing commercial UAV services that have not gone 

through the exemption request process that are gaining a competitive edge on those of us that 

are compelled to follow the rules. 

I hope this is the information that you are seeking from us. 

If you have any further questions or need any additional information please contact us as soon 

as possible. 

Sincerely, 

~ 

David Mason 

Project Manager 

Nobles Consulting Group