New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 1

Jerrud	Smith

New	Vision	Media	Inc.

6804	Caine	Road

Columbus,	Ohio	43235

Phone	Number

(614)	222-0966

Website	

www.newvisionmediainc.com

June	17th 2015

U.S.	Department	of	Transportation

Docket	Management	System	1200

New	Jersey	Ave.,	SE	Washington,	D.C.	20590

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	

Aviation	Regulations	from:	14	CFR	21	subpart	H;	14	CFR	45.23(b);	14	CFR	61.113(a);	14	CFR	91.7(a);	

14	CFR	91.9(b)(2);	14	CFR	91.103;14	CFR	91.109;	14	CFR	91.119(c);	14	CFR	91.121;	14	CFR	

91.151(a);	14	CFR	91.203	(a)	and	(b);	14	CFR	91.405	(a);	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)(1)	

and	(2);	14	CFR	91.417(a)	and	(b)	

To	whom	it	may	concern:

Pursuant to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	and	14	CFR	Part	11,	New	

Vision	Media	Inc.,	operator	of	small	Unmanned	Aerial	Systems	(UAS),	hereby	applies	for	an	

exemption	from	the	listed	Federal	Aviation	Regulations	to	allow	commercial	operation	of	a	small

UAS,	so	long	as	such	operations	are	conducted	within	and	under	the	conditions	outlined	herein or	as	

may	be	established	by	the	FAA	as	required	by	Section	333.

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	

sensors,	would	provide	professional	services	in	the	following	areas:

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,

architecture,	land	surveying,	engineering	and	other	related	professional	activities.

2.	Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	public	events,	

cinematography	and	newsgathering.

3.	Aerial	inspection/photography	of	residential/commercial	structures	under	contract	with	the	

owners	or	local	government	authority.

4.	Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not	

limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.
New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 2

5.	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	operations	

in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	authorities	or	government	has	

requested	it	by	contract	or	donation.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	designated	UAS as	

set	forth	in	this	document	under	controlled	conditions	in	the	NAS	that	would	be	a)	limited	b)	

controlled	c)	predetermined	and	d)	safe.	Approval	of	this	exemption	would	increase	public	

awareness	of	UAS	operations	and	enhance	safety	to	aid	in	fulfilling	the	Secretary	of	Transportation’s	

(the	FAA	Administrator’s)	responsibilities	to	“....establish	requirements	for	the	safe	operation	of	such	

aircraft	systems	in	the	national	airspace	system.”

The	name,	phone,	email	and	address	of	the	applicant:

New	Vision	Media	Inc.

Jerrud	Smith

Phone:	(614)	222-0966

Email:	jsmith@newvisionmediainc.com

Address:	6804	Caine	Road

		Columbus,	OH	43235

Regulations	from	which	the	exemption	is	requested:

14	CFR	Part	21	subpart	H

14	CFR	45.23	(b)

14	CFR	61.113(a)

14	CFR	91.7	(a)

14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.109

14	CFR	91.119(c)

14	CFR	91.121

14	CFR	91.151	(a)

14	CFR	91.203	(a)	&	(b)

14	CFR	91.405	(a)

14	CFR	91.407	(a)	(1)

14	CFR	91.409	(a)	(2)

14	CFR	91.417	(a)	&	(b)

The	small	UAS’s New	Vision	Media	Inc.	will	be	using	are	multi-rotor	craft	weighing	no	more	than	

55lbs.	including	payload.	Under	normal	conditions	they	operate	at	speeds	of	no	more	than	45	Mph	or	

39	Knots	and	have	the	ability	hover	and	move	along	a	vertical	and	horizontal	plane	simultaneously.	

They	will	operate	in	line	of	sight	only	and	by	the	exempted	person	only	obeying	all	other	local	and	

federal	laws.

Given	the	small	size	of	the	UAS	in	scope	and	the	controlled	environment	provided,	the

proposed	operations	will	adhere	to	the	Reform	Act’s	safety	requirements.	The	approval	of	this	

application	presents	no	national	security	issues.	Regarding	the	level	of	safety	surrounding	the	

proposed	operations	and	the	public	benefit,	reduction	in	environmental	impacts,	including	but	not	
New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 3

limited	to	reduced	emissions	and	noise,	the	grant	of	the	requested	exemption	is	in	the	public	interest.	

Accordingly,	the	applicant	graciously	requests	that	the	FAA	grant	the	requested	exemption.

Under	the	terms	of	this	exemption,	New	Vision	Media	Inc.	intends	to	fly	safely	with	an	UAS,	

specifically	a	DJI	Inspire	1 and	DJI	Phantom	Series.	

DJI	INSPIRE	1	TECHNICAL	SPECIFICATIONS	

Cinema Capture	Videography	only	utilizes	safe	and	reliable	UASs.	DJI	is	an	industry	leader	in	small	

UAS	production.	DJI UASs	are	loaded	with	groundbreaking	software.

DJI	Inspire

• Weight	(Battery	Included)	6.47	lbs.

• Hovering	Accuracy	(GPS	Mode)	Vertical	1.5	ft,	Horizontal	7.5	ft

• Max	Angular	Velocity	Pitch:	300deg/s;	Yaw	lSOdeg/s

• Max	Tilt	Angle	30deg/s

• Max	Ascent	Speed	15	ft/s

• Max	Decent	Speed	12	ft/s

• Max	Speed	66	ft/s

• Diagonal	Distance	22.0	in.	(Landing	gear	lowered),	22.9	in.	(Landing	gear	raised)

• DJI	Inspire	Battery

§ Model	(Standard)	TB47

§ Voltage	22.2v

§ Capacity	4500mAh

§ Energy	99.9Wh

§ Net	Weight	1.26	lbs.

• DJI	Inspire	Gimbal

§ Operating	Current	- Station:	750mA,	Motion:	900mA

§ Controllable	Range	- Pitch:	-90deg	to	+30deg

§ Max	Controllable	Speed	- Pitch:	120deg/s,	Pan:	180deg/s

• DJI	Inspire	Remote	Controller

§ Frequency

§ 5.725GHr5.850GHz	(Remote	Controller	to	Remote	Controller)

§ 2.400GHr2.483GHz	(Remote	Controller	to	Aircraft)

§ Battery	Capacity	6000mAh

§ Working	Current/Voltage	l.2A@7.4V

DJI	Phantom	2	Vision	Plus	(P2VP)

• Weight	(Battery	&	Propellers	Included)	–2.74	lbs.

• Hover	Accuracy	(Ready	to	Fly)	–Vertical:	24	ft;	Horizontal:	7.5	ft

• Max	Yaw	Angular	Velocity	-2000/s

• Max	Tilt	Angel	-350

• Max	Ascent	Speed	–18	ft/s

• Max	Descent	Speed	– 6	ft/s

• Max	Flight	Speed	–45	ft/s
New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 4

• DJI	P2VP	Battery

§ DJI	5200mAH	LiPo	Battery

§ DJI	P2VP	Gimbal

§ Working	Current	–Static:	750mA;	Dynamic:	900mA

§ Control	Accuracy	-±0.030

§ Controllable	Range	–Pitch:	-900	-00

§ Maximum	Angular	Speed	–Pitch:	900/s

• DJI	P2VP	Camera

§ Operating	Temperature	Range	-320F	-1040F

§ Sensor	Size	–1/2.3	in.

§ Effective	Pixels	–14M

§ Resolution	–4384x3288

§ HD	Video	Recording	–1080p30	&	720p

§ Recording	Field	of	View	-1100/850

• DJI	P2VP	Transmitter

§ Operating	Frequency	–5.728GHz	–5.85GHz

§ Communication	Distance	(unobstructed)	–FCC	Compliance:	2400	ft

§ Receiver	Sensitivity	(1%PER)	--93dBm

§ Transmitter	Power	–FCC	Compliance:	100mW	1.1.4.5	Working	Voltage	–

120mA@3.7V

§ DJI	P2VP	Range	Extender

§ Frequency	–2412-2462MHz

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	operation	limitations	proposed	for	an	equivalent	or	higher	level	of	safety	because

operations	will	further	enhance	the	safety	of	the	persons	and/or	property	using	conventional

aircraft.	These	limitations	and	conditions	to	which	the	applicant	agrees	to	adhere	to	when	conducting	

commercial	operations	under	the	FAA	issued	exemption	as	set	forth	in	the	Flight Operations	Manual	

(FOM)	include:

1. The	UAS	will	weigh	significantly	less	than	55	lbs. It	weighs	less	than	6.5 pounds	with	battery

and	camera.

2. Flights	will	be	operated	within	line	of	sight	of	the	Pilot	in	Command	(PIC)	and/or	Visual

Observer	(VO).

3. Maximum	flight	time	for	each	operational	flight	will	be	depending	on	the	UAS	model	in

operation,	but	will	not	exceed	30	minutes.	Flights	will	be	terminated	at	30%	battery	power	

reserve	or	22	minutes	of	flight	time	whichever	occurs	first.

4. Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(AGL)

and	not	more	than	200	feet	above	an	elevated	platform	from	which	filming	is	planned.

5. Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot	and	at	least	one	Visual
New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 5

Observer	(VO),	and	may	include	a	third,	but	separate,	Camera	Operator	(CO).

6. The	UAS	pilot	will	be	a designated	Pilot	in	Command	(PIC)	.	The	PIC	will	have	logged	a

minimum	of	40 hours	on	the	designated	UAS.

7. A	safety	briefing	will	be	performed	prior	to	each	day’s	flights	consisting	of	all	the	days’

production	activities.

8. Flights	will	not	be	closer	than	a	5	mile	radius	of	the	geographic	center/Airport.

9. The	operator	will	obtain	verbal/written	consent	of	all	persons	involved	with	the	planned

operation	and	ensure	that	only	consenting	persons	will	be	allowed	within	100	feet	of	the	

flight	operation,	and	the	radius	may	be	reduced	to	30	feet	based	upon	an	equivalent	level	of	

safety	determination,	as	U.S.	Department	of	Transportation	required	under	the	FOM.	With	

the	advanced	permission	of	the	FSDO,	operations	at	closer range	may	be	approved.

10. The	PIC	and	VO	will	have	been	trained	in	operation	of	UAS	and	receive	up to date

information	for	the	particular	UAS	to	be	operated.

11. The	PIC	and	VO	will	be	able	to	communicate	by	voice	and/or	radio	at	all	times.

12. Written	and/or	verbal	permission	and	permits	will	be	obtained	from	territorial,	state,	

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

governmental	agencies	as	appropriate	to	flight	operations.

13. If	the	UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the	UAS will	

have	the	capability	to	return	to	a	predetermined	location	within	a	designated	location	and	

land	autonomously.

14. The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles, weather,	

or	emergencies	such	as	low	battery.

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)

Subpart	H, entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements	for	the	

issuance	of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size	and	limited	

operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an	exemption	from	Part	21	

Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety	under	Part	11	and	Section	333	of	

the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701	(f))	and	Section	333	of	the	Reform	Act	

both	authorize	the	FAA	to	exempt	aircraft	from	the	requirement	for	an	airworthiness	certificate,	

upon	consideration	of	the	size,	weight,	speed,	operational	capability,	and	proximity	to	airports	and

populated	areas	of	the	particular	UAS.	In	all	cases,	an	analysis	of	these	criteria	demonstrates	that	the	

UAS	operated	without	an	airworthiness	certificate	in	the	restricted	environment	and	under	the	

conditions	proposed	will	be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	

rotorcraft)	operating	with	an	airworthiness	certificate	without	the	restrictions	and	conditions	

proposed.	
New Vision Media Inc. l www.newvisionmediainc.com l 614.222.0966 Page 6

The	UAS	to	be	operated	hereunder	is	less	than	55	lbs.	fully	loaded,	carries	neither	a	pilot	nor	

passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	operates exclusively	within	a	

secured	and	designated	area.	Unlike	other	civil	aircraft,	operations	under	this	exemption	will	be	

tightly	controlled	and	monitored	by	both	the	operator	and	under	the	requirements	and	in	

compliance	with	local	public	safety	requirements.	These	safety	enhancements	provide	a	greater	

degree	of	safety	to the	public	and	property	owners	than	conventional	operations	conducted	with	

airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpart	H.	 Lastly,	application	of	these	same	

criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	posed	by	the	UAS, due	to	its	

size,	speed	of	operation,	location	of	operation,	lack	of	explosive	materials	or flammable	liquid	fuels,	

and	inability	to	carry	a	substantial	external	load.	

14	C.F.R.	§	45.23 (b).	Marking	of	the	Aircraft	

The	regulation	requires:	When	marks	include only	the	Roman	capital	letter	"N"	and	the	registration	

number	is	displayed	on	limited,	restricted	or	lightsport	category	aircraft	or	experimental	or	

provisionally	certificated	aircraft,		the	operator	must	also	display	on	that	aircraft	near	each	entrance	

to	the	cabin,	cockpit,	or	pilot	station,	in	letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the	

words	"limited,"	“restricted,"	"lightsport,"	"experimental,"	or	"provisional,"	as	applicable.

Even	though	the	UAS will	have	no	airworthiness	certificate,	an	exemption	may	be	needed	as	the	UAS	

will	have	no	entrance	to	the	cabin,	cockpit	or pilot	station	on	which	the	word	“Experimental”	can	be	

placed.	Given	the	size	of	the	UAS,	two-inch	lettering	will	be	impossible.	The	word	“Experimental”	will	

be	placed	on	the	fuselage	in	compliance	with	§45.29	(f).	US	Department	of	Transportation	February

20,	2015	The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	marked	on	its	fuselage	as	

required	by	§45.29	(f)	where	the	pilot,	observer	and	others	working	with	the	UAS	will	see	the	

identification	of	the	UAS	as	“Experimental.”	

14	C.F.R.	§	61.113 (a)	and	(b):		Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command

Pursuant	to	14	CFR	61.113	(a)	&		(b),	no	person	who	holds	a	private	pilot	certificate	may	act	as	a	

pilot	in	command	of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire.	The	

proposed	UAS	operations	may	achieve	an	equivalent	level	of	safety	as	achieved	by	current	

Regulations	because	the	applicant’s	UAS	do	not	carry	any	pilots	or	passengers	nor	property.	The	

risks	attendant	to	the	operation	of	UAS	is	far	less	than	the	risk	levels	inherent	in	the	commercial	

activities	outlined	in	14	CFR	61.	 I	feel the	operation	and	limitations	set	forth	in	the	FOM	will	equate	

to	the	safe	operation	of	the	UAS.

14	C.F.R.	§91.7(a):	Civil	Aircraft	Airworthiness

The	regulation	requires	that	no	person	may operate	a	civil	aircraft	unless	it	is	in	airworthy	condition.	

As	there	will	be	no	airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	

no	FAA	regulatory	standard	will	exist	for	determining	airworthiness.	Given	the	size	of	the	aircraft	for	

maintenance	and	use	of	safety	checklists	prior	to	each	flight,	an	equivalent	level	of	safety	will	be	

provided.

14	C.F.R.	§	91.9 (b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft

Section	91.9	(b)	(2) provides:	No	person	may	operate	a	U.S	registered civil	aircraft	...	(2)	For	which	an	

Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of	this	chapter,	unless	there	is	available	

in	the	aircraft	a	current	approved	airplane	or	Rotorcraft	Flight	Manual, approved	manual	material,	

markings,	and	placards,	or	any	combination	thereof.	The	UAS,	given	its	size	and	configuration	has	no	

ability	or	place	to	carry	such	a	flight	manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	
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board,	but	because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivalent	

level	of	safety	will	be	maintained	by	keeping	the	flight	 manual	at	the	ground	control	point	where	the	

pilot	flying	the	UAS	will	have	immediate	access	to	it.

14	C.F.R.	§	91.103: Preflight	Action

This	regulation	requires	each	pilot	in	command	to	take certain	actions	before	flight	to	insure	the	

safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be	provided	for	the	aircraft	an	

exemption	will	be	needed.	The	PIC	will	take	all	actions	as	stated	in	the	FOM	in	Section	4	under	

Normal	Procedures	including	but	not	limited	to	reviewing	weather,	flight	battery	requirements,	

landing	and	takeoff	distances	and	aircraft	performance	data	before	initiation	of	flight

14	C.F.R.	§91.109:	Flight	Instruction

Section	91.103	provides	that	no	person	may	operate	a civil	aircraft	(except	a	manned	free	balloon)	

that	is	being	used	for	flight	instruction	unless	that aircraft	has	fully	functioning	dual	controls.	UAS	

and	remotely	piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual	controls.	Flight	control	

is	accomplished	through	the	use	of	a	control	box	that	communicates	with	the	aircraft	via	radio	

communications.		The	FAA	has	approved	exemptions	for	flight	training	without	fully functional	dual	

controls	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	equivalent	

level	of	safety	is	provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	aircraft	

and	by	the	size	and	speed	of	the	aircraft.

14	C.F.R.	§91.119: Minimum	Safe	Altitudes

Section	91.119	establishes	safe	altitudes	for operation	of	civil	aircraft.	Section	91.119	(d)	allows	

helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	provided	the	person	operating	the

helicopter	complies	with	any	route	or	altitudes	prescribed	for	helicopters	by	the	FAA.	As	this	

exemption	is	for	a	UAS	that	is	a	helicopter	and	the	exemption	requests	authority	to	operate	at	

altitudes	up	to	400	AGL,	or	not	more	than	200	above	an	elevated	platform	from	which	filming	is	

planned,	an	exemption	may	be	needed	to	allow	such	

operations.	As	set	forth	herein,	the	UAS	will	never	operate	at	higher	than	400	AGL	with	the	exception	

that	in	circumstances	where	the	UAS	is	used	to	survey	or	photograph	a	structure	whose	height	

exceeds	400	feet	AGL,	the	UAS	will	not	be	operated	more	than	200	feet	above	the	highest	point	on	the	

structure.	It	will	however	be	operated	in	a	restricted	area	with	security	perimeter,	where	buildings	

and	people	will	not	be	exposed	to operations	without	their	preobtained	consent.	The	equivalent	level	

of	safety	will	be	achieved	given	the	size,	weight,	and	speed	of	the	UAS	as	well	as	the	location	where	it	

is	operated.		No	flight	will	be	taken	without	the	permission	of	the	property	owner	or	local	officials.		

Because	of	the	advance	notice	to	the	property	owner	and	participants	in	the	filming	activity,	all	

affected	individuals	will	be	aware	of	the	planned	flight	operations.	Compared	to	flight	operations	

with	aircraft	or	rotorcraft	weighting	far	more	than	the	maximum	55lbs.	proposed	herein	and	the	lack	

of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less	than	those	presently	presented

with	conventional	aircraft	operating	at	or	below	500	AGL.	In	addition,	the	low	altitude operations	of	

the	UAS	will	ensure	separation	between	these	UAS	operations	and	the	operations	of	conventional	

aircraft	that	must	comply	with	Section	91.119.	

14	C.F.R. §91.121	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft to	maintain	cruising	altitude	by	reference	

to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure	airport	or	an	appropriate	altimeter	

setting	available	before	departure.”	As	the	UAS	may	not	have	a	barometric	altimeter,	but	instead	a
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GPS	altitude	read	out,	an	U.S.	exemption	may	be	needed.	An	equivalent	level	of	safety	will	be	achieved	

by	the	operator,	pursuant	to	the	safety	check	list	and	live	flight	data	monitoring,	confirming	the	

altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	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	

applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	

exemptions.		Operating	the	UAS	in	a	tightly	controlled	area	where	only	people	and	property	owners	

or	official	representatives	who	have	signed	waivers	will	be	allowed	does	not	engender	the	type	of	

risks	that	Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.	The	

applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting flights	to	22	minutes	

or	30%	of	battery	power	— whichever	happens	first.	This	restriction	would	be	more	than	adequate	

to	return	the	UAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.

14	C.F.R.	§91.203 (a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

The regulation	provides	in	pertinent	part:	(a)	Except	as	provided	in	§	91.715,	no	person	may

operate	a	civil	aircraft	unless	it	has	within	it	the	following:	(1)	An	appropriate	and	current

airworthiness	certificate.	.	.	.	(b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	

certificate	required	by	paragraph	(a)	of	this	section	or	a	special	flight authorization	issued	under	

§91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to	passengers	or	crew.	The	

UAS	fully	loaded	weighs	well	under	the	proposed	55lb limit	and	is	operated	without	an	onboard	

pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to	

display	them	on	the	UAS.	An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	

at	the	ground	control	point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	them,	to	the	

extent	they	are	applicable	to	the	UAS.	

14	C.F.R.	§91.405 (a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections.

These regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft	inspected	as	

prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	except	as	provided	in	

paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter...,”	

and	others	shall	inspect	or	maintain	the	aircraft	in	compliance	with	Part	43.		Given	that	these	

sections	and	Part	43	apply	only	to	aircraft	with	an	airworthiness	certificate,	these	sections	will	not	

apply	to	the	applicant.	Maintenance	will	be	accomplished	by	the	operator	pursuant	to	the	flight	

manual	and	operating	handbook.	An	equivalent	level	of	safety	will	be	achieved	because	the	UAS	is	

very	limited	in	size	and	will	carry	a	small	payload	and	operate	only	in	restricted	areas	for	a	limited

period of	time.	If	mechanical	issues	arise	the	UAS can	land	immediately	and	will	be	operating	from	no	

higher	than	400	feet	AGL.	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	performed.	Moreover,	the	

operator	is	the	person	most	familiar	with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	

airworthy	condition	to	provide	the	equivalent	level	of	safety.	

An	equivalent	level	of	safety	will	be	achieved	because	maintenance	and	inspections	will	be	

performed	in	accordance	with	the	UAS	Manufacturer's	User	Manual.	As	provided	in	the	FOM,	the	

operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight	and	perform	required	

maintenance	needed.