Petition for Exemption by AirCover:

James Hill

3710 Flight Avenue

Redding, California 96002

AirCover has filed for an experimental airworthiness certificate for its small unmanned aircraft system to 

be operated in limited specific geographic locations for the purposes of testing, evaluation and 

demonstration. As part of its application for airworthiness, AirCover is required to apply for an 

exemption to 14 C.F.R. 91.9(b)(2) and 14 C.F.R. 19.203(a) & (b) because of the unique aspects of the UAS 

design.

- 14 C.F.R. 91.9(b)(2) requires a civil aircraft to have on board the current, approved rotorcraft 

flight manual, approved manual material, markings, and placards or any combination thereof..

- 14 C.F.R. 19.203 (a) requires a civil aircraft to an airworthiness certificate on the aircraft and 

must display the airworthiness certificate in a visible location within the cockpit of the aircraft.

AirCover’s small unmanned aircraft is a battery powered quad-rotor system with a gross weight of 3.7 

lbs. The aircraft does not have a cockpit and does not have the ability to hold or display an 

airworthiness certificate. The operators of the small unmanned aircraft will have the current approved 

flight manual and airworthiness certificate with them at the ground station.

Therefore, AirCover specifically request that is be exempted from the requirement to have on board the 

aircraft the current, approved rotorcraft flight manual, approved manual material, markings, and 

placards or any combination thereof; and that is be exempted from maintaining and display its civil 

airworthiness certificate in a visible location within the cockpit. In lieu of the requirements of 

91.9(b)(20 and 19.203(a), AirCover will maintain the current, approved rotorcraft flight manual, 

approved manual material, markings, and placards or any combination thereof and the civil 

airworthiness certificate with the ground station.

The requested exemption will not adversely affect the safety of flight. Having a manual onboard the 

small unmanned aircraft would be meaningless as the individual that needs to have access to the 

manual would not be on the aircraft. In addition, having the civil airworthiness certificate on board the 

unmanned aircraft would not provide regulators or potential occupants (as occupants are not possible) 

with notice of the aircraft’s civil airworthiness. 

Given that the FAA defines an unmanned aircraft system as both the aircraft and the ground station, it 

would seem that the ground station would also be considered part of the aircraft. Therefore, arguably 

having the manual and airworthiness certificate with the ground station would comply with the spirit of 

14 C.F.R. 91.9(b)(2) and 14 C.F.R. 19.203(a). 

All proposed operations will be conducted within a defined incident parameter. Each flight will be less 

than 45 minutes in duration. The operators will notify ATC in advance of the flights and will post a 
Notice to Airman regarding the proposed operations. The operations will be conducted by line of sight 

and less than 400 feet AGL. The operations will not obtain imagery or data of any individual’s private 

property. 

The requested exemption would benefit the public because of the nature of AirCover intended 

operations. AirCover’s product is a cost effective tool for public safety and agriculture. Currently, public 

safety and government agencies conduct agricultural research can apply for and operate an unmanned 

aircraft. However, a manufacturer cannot operate an unmanned aircraft without an airworthiness 

certificate. Without an airworthiness certificate, AirCover is unable to provide demonstration and 

training programs for public safety. Moreover, AirCover partners with various research entities and 

public safety to conduct mock operations, including programs with state homeland security agencies 

and Iowa Department of Agriculture. The use of the aircraft is for the public benefit.

The following summary may be used to publish in the Federal Register:

AirCover has petitioned the FAA for an exemption to the requirements set forth in 14 C.F.R. 

91.9(b)(2) and 14 C.F.R. 19.203(a) & (b). These two regulations require an aircraft to have 

onboard current, approved rotorcraft flight manual, approved manual material, markings, and 

placards or any combination thereof and the civil airworthiness certificate. Because of the 

unique aspects of the UAS design, it is unable to have onboard the aircraft these documents. 

However, these documents will be in the position of the operator at the ground station, which is 

deemed part of the aircraft by the FAA. The exemption to these regulations will not adversely 

affect the safety of flight.

The requested exemption will permit AirCover to obtain an experimental airworthiness 

certificate to allow it to provide training and demonstration flight in a defined geographic area. 

All proposed operations will be conducted within a defined incident parameter. Each flight will 

be less than 45 minutes in duration. The operators will notify ATC in advance of the flights and 

will post a Notice to Airman regarding the proposed operations. The operations will be 

conducted by line of sight and less than 400 feet AGL. The operations will not obtain imagery or 

data of any individual’s private property.