2/5/16

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590
**RE: Exemption Request Section 333 of the FAA**  **Reform A ct and**  **Part 11 of the Federal Aviation Regulations**  Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Alaska Aerial Technologies, LLC (“ Operator”) requests an exemption from the Federal Aviati on Regulations (“FARs”) listed below and discussed in Appendix A

. 1 Operator seeks the exemption to allow it to use the (2) 3DR Solo (s) in (i) commercial aerial photography and videography, including rural real estate documentation, rights

-of

-way and remote site documentation (ii) aerial monitoring and data collection involving , but not limited to, commercial volumetric measurements , construction site documentation , and other sites requiring low altitude aerial imaging. Additionally, Alaska Aerial Technologies, LLC has developed a relationship with various public safety agencies to assist with their future sUAS needs operating under Public Entity COAs , so long as th ose 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). T he operating conditions and limitations set forth below, which Ope rator is willing to accept, are identical to those in the exemption granted to Aeryon Labs, Inc. 2 The only material difference in this request is a change in the aircraft that Operator proposes to use; however, the FAA has also granted an exemption request for use of the 3DR Solo fo r commercial purposes
. 3 Because the 3DR Solo specified in this request is the same craft that the FAA has already approved , and because Operator will operate the aircraft fully in compliance with the conditions in exemption precedent , the FAA need not provide notice in the Federal Register or ask fo r public comment

. As a result, this exemption qualifies fo r summary processin g. As described more fully below, the requested exemption would authorize commercial operations using the 3DR Solo , wh ich is a small unmanned aerial vehicle (“UAV”) with a we ight of well under 55 pounds. The 3DR Solo will be operated at low altitude in limited airspace under controlled conditions; it has automated control features. Operator will provide com mercial

1 See Pub. Law 112

-95, 126 Stat. 11, § 333 (2012). 2 See Aeryon Labs, Inc., FAA Exemption No. 11213, Regulatory Docket No. FAA

-2014

-0642 (Mar. 24, 2015). 3 See Mr. Michael Intschert, FAA Exemption No. 11832, Regulatory Docket No. FAA

-2015

- 1166 (June 16, 2015).U.S. Department of Transportation

2/5/16 Page Two services in accordance with the FAA sUAS regulations and our own operations and procedures document. Any individual operating the [3DR Solo] will hold at least a recreational or sport pilot certificate and a U.S. state issued driver’s license

. U se of this small, lightweight UAV for the proposed uses will provide significant benefits, particularly as compared to using traditional aircraft fo r these purposes
. Alaska Aerial Technologies, LLC has used traditional manned aircraft, both fixed wing and helicopters fo r aerial photography since it began in 2007. The need for smaller, lighter, less expensive imaging platforms that can operate at low altitudes has been evident fo r years. Wea re experienced assessing risks, working with the FAA and ATC, and have done work for agencies including the National Park Service. Our PIC is a commercial airline pilot with current instrument , commercial SEL, SES, commercial MEL, an d ATP ratings. Utilizing sUAS will enhance our capabilities and safety by decreasing the need fo r traditional aircraft for close

- in aerial imaging. 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 of safety

. Consequently, as discussed below, grant of thi s 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.” Operator also requests a blanket Certificate of Wa iver or Authorization (“ COA”) for flights up to 200 feet above ground level in the fo rm 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 of the applicant are: Alaska Aerial Technologies, LLC Attn: Brandon Anderson PO Box 2283 Seward, AK 99664 Ph: 907

-491

-0385 Email: Brandon@alaskaaerial.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); 14 C.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);U.S. Department of Transportation

2/5/16 Page Three 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 fro m each rule is not only appropriate, but will provide an equivalent level of safety and serve the public interest. **THE AP**  **PLICA BLE LEGA** **L STA NDA** **RD UNDER SECTION 333** Approval of this exemption application to permit commercial use of the 3DR Solo will advance the Congressional m andate in Section 333 of the Reform Act to accelerate the introduction of unmanned aerial systems (“ UASs”) into the national airspace system (“NAS”) if i t can be accomplished safely. The Reform Act directs the Secretary of T ransportation to consider wheth er certain UASs may operate safely in the NAS before completion of the rulemaking to establish general requirements for use of UASs

. T he Secretary must determine what types of UASs will not create a hazard to users of the NAS or the public and will not pose a threat to national security in light of the following:

 The size, weight, speed, and operational capability of the UAS ;  Operation of the UAS close to airports and populated areas; and
 Operation of the UAS within the visual line of sight of the operator. Reform Act § 333(a)(1). Once the Secretary determines that UASs “may operate safely in the national airspace system, the Secretary shall establish requirements fo r the safe operation of such aircraft in the national airspace system.” Id. § 333(c) (em phasis added). 4

**PUBLIC INTEREST BENEFITS AND**  **EQUIVA LENT LEVEL OF SA** **FETY** The Federal Aviation Act also expressly provides that “[t] he Administrator may grant an exemption from a requirement of aregulation

. . . . or any of sections 44702

-44716 of this titl e if the Administrator finds 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. Th is 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 ,

4 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 for the safe operation of the UAS. Operator is willing to consult with the FAA staff to address any issues raised by this application that may require such modifications.U.S. Department of Transportation

2/5/16 Page Four that will result from its proposed use
. This exemption will apply to the 3DR Solo when operated in accordance with the conditions proposed below

. T hese conditions provide fo r at least an equivalent level of safety to operations with conventional aircraft under the current regulatory structure (and, in practice, a higher level of safety)

. Specifically, use of a jet or piston powered aircraft for the purposes proposed in this application would be high risk, requiring operation very close to people and structures

. S uch vehicles we igh thousands of

pounds, carry large amounts of highly flammable fu el, and provide limited maneuverability. I n comparison, a smal l UAS like the 3DR Solo presents very little risk as it we ighs much less than 55 pounds with payload , is powered by batteries , and is designed to be highly maneuverable. I n 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. T hus, operation of this small craf t , in accordance with the strict conditions listed below, will provide an equivalent level of safety that is more than sufficient to support the grant of th e requested exemption

. Wh en 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 to the 3DR Solo when we ighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. Operations for the p urpose of closed

-set motion picture and television filming are not permitted. 3. The UAS may not be operated at a speed 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 greater than the maximum UAS operating airspeed recommended by the aircraft manufacturer, wh ich in this case is 47.8 knots (55 miles per hour)

. 4. The UAS 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 UAS 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. d river’s license. 6. All operations must utilize a visual observer (VO). The UAS 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 VLO S 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 theU.S. Department of Transportation

2/5/16 Page Five 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. The exemption and all documents needed to operate the 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. If a 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 mu st be followed. Otherwise, the O perator must follow the procedures as outlined in its operating documents. The O perator m ay update or revise its operating documents. It is the O perator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcem ent official upon request. The O perator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the O perator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the O perator must petition for an amend m ent 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 O perator 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 O perator 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.U.S. Department of Transportation

2/5/16 Page Six 13. Un der this grant of exemption, a PIC must hold either a 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 Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PI C 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. 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 curre ncy 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 cons istent 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 fl ights, 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 UAS may not operate within 5 nautical miles of an airport reference point (AR P) 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 managem ent 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 UAS 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 UAS must return to a predetermined 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 UAS 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.U.S. Department of Transportation

2/5/16 Page Seven 21. Air Traffic Organization (ATO) Certificate of Wa iver or Authorization (COA). All operation s 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. 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 availa ble to the Administrator or any law enforcement official upon request. 24. The UAS 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 Fl ight 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 UAS and/or debris in the eve nt 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 i n 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 reportedU.S. Department of Transportation

2/5/16 Page Eight 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 W eb site: www.ntsb.gov.

******** **Privacy**

. Operator will conduct all UAS operations in compliance with applicab le federal, state, or loca l privacy laws and regulations

. **National Security** 

. Grant of this exemption will not raise any national security issues. I n light of the size, load carrying capacity, speed at which the proposed craft operates, and because it carries no explosives or oth er dangerous materials, the UAS poses no threat to national security.

******** For these reasons , Operator seeks an exemption fro m 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

– i s more than sufficient to support grant of an exemption to allow commercial operation of Operator’s UAS fo r the p urposes outlined herein and is fully consistent with exemption precedent

. T he FAA should promptly grant this request. Very truly yours , Brando n Anderson Owner, Alaska Aerial Technologies, LLC

cc: Wi lliam Crozier Robert Pappas Jake Troutman Dean Griffith, Esquire Thuy H. Cooper**AP PENDIX A** 

**EXEMPTION REQUEST A ND EQUIVA** **LENT LEVEL OF SA FETY**  **DEMONSTRA TION**  **UNDER AP**  **PLICA BLE RULES SUBJECT TO EXEMPTION**  Operator requests an exemption from the following regulations as well as any additional regulations that the FAA staff may deem to apply to its utilization of the 3DR Solo 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 of medical certificates for pilots

. Section 61.23(a) requires a person exercising the privileges of a recreational pilot to hold at least a third class medical certificate. Section 61.23(c) permits the holder of a sport pilot certificate to act as PIC of a light

-sport aircraft with eithe r a medical certificate or U.S. issued driver’s license. Light

sport aircraft may weigh up to 1,430 pounds and seat up to two persons, including the pilot. The proposed craft weighs much less than 55 pounds with payload and will not carry pilots, passeng ers, or cargo. The proposed craft also will be operated within visual line of sight of the PIC and be low 400 feet above ground level and limited to operations with permission over private or controlled

-access property. Given these safety parameters, Ope rator requests that the FAA waive Section 61.23(a) upon a finding that an equivalent level of safety will be provided by allowing operation of the proposed craft by pilots with a recreational or sport pilot certificate and a valid U.S. state issued driver’s license, in lieu of an FAA

- issued medical certificate. Operator also requests that the FAA grant relief from Section 61.23(c) to allow sport pilot certificate holders to operate aircraft other than light

-sport aircraft with a valid U.S. issued driver’s license. The FAA has granted exemptions to conduct similar operations in a number of cases , including Exemption s 11213 and 11832

. **1 4 C.F.R. §**  **61. 101(e)(4)**  **& (5), 61.113(a), and 61.315(a)**  **: Recreational Pilot Privileges and**  **Limitations; Pri** **vate Pilot Privileges and Limitatio ns:**  **Pilot in Command; What are the**  **privileges and limits of my sport pilot certificate?**  Section s 61.101(e)(4) & (5) and 61.113(a) limit recreational or private pilots to non

-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the proposed craft in this case is remotely controlled with no passengers or property of others on board. Section 61. 315(a) addresses the privileges and limitations of the holder of a sport pilot certificate. O perating conditions need to take into account the characteristics of the particular UAS. The proposed craft has a high degree of pre

- programmed control and various built

- in navi gation and other technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. T hese features include:

 Geo

-fencing function;
 An automated “return home” function;
 T he abil ity to land the UAS at its current location;
 A pause function that stops the UAS’s movement and causes it to hover at its current location;- 2

-

 Automatic return home if signal link is lost ;  Automatic return home if the battery charge level reaches 5 percent or less; and
 The ability to take manual control of the UAS in emergencies. In light of these safety features, operators of the proposed craft should not be required to hold a commercial pilot certification. Rather, possession of a recreational or sport pilot certificate should suffice

. Given the proposed craft’s size, speed, lack of flammable fuel and operational capabilities, its operation presents much less risk than associated with commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft) . Operation as set forth herein meets or exceeds the present level of safety provided under the regulations cited above and does not rise to the level of requiring a commercial pilot to operate the aircraft

. Thus, an equivalent level of safety will be provided by allowing operation of the proposed craft with a recreational or sports pilot certificate, under the conditions set forth in the exemption request. The FAA has granted exemptions to conduct simil ar operations in a number of cases, including Exemption s 11213 and 11832

. **14 C.F.R. § 91.7(a): Civil A** **ircraft A irw** **orthiness.** 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 petition er’s UAV will not require an airworthiness certificate, the pilot , fo r purposes of this rule, may determine the aircraft is in an airworthy condition prior to flight. Given the size of the aircraft and the requirements to which the Operator has agreed relating to airworthiness, as set forth in the manual provisions , an equivalent level of safety will be achieved by e nsuring compliance with the manual provisions prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080, 11109 , 11110, 11136, 11138, 11213 and 11832

. **14 C.F.R. § 91.119(c): Minimum Safe A** **ltitudes.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be o perated closer than 500 feet to any person, vessel, vehicle, or structure. The proposed craft will never operate at higher than 400 feet AGL. It also will be operated to avoid congested or populated areas

. Because the proposed use must be accomplished at relatively low altitudes (seldom over 100’ AGL) and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed. Given the 3DR Solo ’s weight and speed and the material with which it is built , an equivalent level of safety will be achieved

. Moreover, as set forth in the proposed conditions, all flights will be conducted with the permission of the landowner or those who control the land as well as the permission of local officials , if required

. Advance notice to the landowner will ensure that all affected individuals will be aware of the flights. Given the characteristics of the sUAS, any risk of these operations will be much less than the risks associated with similar operations by conventional aircraft weighing thousands of pound s and carrying flammable fuel. In addition, given the limitations on the altitude of UAS operations, the UAS will maintain separation- 3

-

between its operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has gra nted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 , 11110, 11136, 11138, 11150, 11153, 11213 , and 11832

. **[14 C.F.R. § 91.121: A ltimeter Settings** 
Section 91.121 requires that each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL to: (a) the current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (b) if there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (c) i n the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.
To provide an equivalent level of safety, the 3D R Solo autopilot establishes the reference altitude (ground level) with the on

- board GPS during the pre

-flight tests. The UAS’s barometer and GPS equipment ensure safety by providing the PIC with information concerning the altitude of the UAS during flight.] **14 C.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 under 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

– (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.” The 3DR Solo ’s battery provides approximately 2 5 minutes of powered flight , approximately 20 minutes with payload

. Without an exemption from § 14 C.F .R. 91.151, flights of the proposed craft would not be possible

. In light of the limitations on its proposed operations and the location of those 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 meant to prevent, particularly in light of the UAS’ size and the speed at whi ch it operates as well as its lack of onboard pilot, passenger, or cargo. Further, if the 3DR Solo reaches a critical battery state, it simply return s to home and land s
. Operator believes that an equivalent level of safety can be achieved by maintaining five minutes of reserve fuel, which, allowing approximately 15 minutes of flight time with payload , would be more than adequate to return the proposed craft to its planned landing zone from anywhere in its operating area. Similar exemptions have been granted to other operators, including Exemptions 11062 through 11067, 11080, 11109, 11110, 11112, 11136 , 11138, 11150, 11153, 11213 , and 11832

. **14 C.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 or owner “shall have that aircraft inspected as prescribed in subpart E of thi s part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of- 4

-

this chapter

. . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. The O perator of the proposed craft will perform maintenance in accordance with the manual provision s . An equivalent level of safety will be achieved because the small UAS is not a complex mechanical device , and it will carry a small payload and operate only in restricted predetermined areas. As provided in the manual provisions, the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance that is performed; moreover, the Operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080, 11109 , 11110, 11112, 11136, 11138, 11213 , and 11832

.