UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

Petition of ) 

) 

Amplify Energy, Inc. ) 

) 

for an exemption from §§61.23(a) and (c), ) 

61.10l(e)(4) and (5), 61.113(a), 61.315(a) ) 

91.7(a), 91.119(c), 91.121, 91.151(a)(l), ) 

91.405(a), 91.407(a)(l), 91.409(a)(l) and ) 

(2), and 91.417(a) and (b) ) 

September 03, 2015 

Regulatory Docket No. FAA-2015-

Chris Denten 

General Counsel 

Amplify Energy, Inc. 

60 I California Street, Suite 1150 

San Francisco, CA 94108 

415-788-8816 

legal@amplifyenergy.com 

--

*** Confidential Treatment has been Requested for Portions of this Document *** 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON. DC 20591 

Petition of ) 

) 

Amplify Energy, Inc. ) 

) 

for an exemption from §§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)(l), ) 

91.405(a), 91.407(a)(l). 91.409(a)(l) and ) 

(2). and 91.417(a) and (b) ) 

September 03, 2015 

Regulatory Docket No. FAA-2015-__ 

Chris Denten 

General Counsel 

Amplify Energy, Inc. 

60 I California Street, Suite 1150 

San Francisco, CA 941 08 

415-788-8816 

legal@amplifyenergy.com 
Petition for Exemption 

Pursuant to Section 333 of the FAA Modernization and Refonn Act of 2012 (Section 

333) 1 and 14 C.F.R. Part 11 (Part 11), Amplify Energy, Inc., an engineering services company 

that evaluates the quality and performance of solar power plants, respectfully requests an 

exemption from several provisions of Title 14 of the Code of Federal Regulations (C.F.R.) to 

penn it the use of small unmanned aerial systems (sUAS) to assist in the inspection of solar 

panels operating and maintained in the United States. 

The grant of an exemption is consistent with Congress' intent, reflected in Section 333, 

that safe small unmanned aircraft systems be pennitted in the national airspace prior to the 

issuance of final regulations governing general use of these systems. 2 

Regulatory Basis for Exemption Request 

In addition to the waiver authority provided in Section 333, the FAA may grant an 

exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public 

interest. The FAA has imposed a separate requirement in Part 11, providing that the petitioner 

shall explain why granting the exemption would not adversely affect safety or how the 

exemption would provide at least an equivalent level of safety as compliance with the underlying 

regulation. 3 In this case, approval of this exemption would advance the public interest by 

enhancing the safety and efficiency of solar panel inspections and operations and by providing 

the FAA with valuable user experience on sUAS. As described more fully below, the requested 

exemption would permit the operation of sUAS under tightly controlled conditions, thus 

ensuring that operations will not have an adverse impact on safety. To the contrary, as explained 

below, Amplify Energy anticipates that use of sUAS will enhance safety in the inspection of its 

customers' solar panel and related solar products. 

Granting an Exemption is in the Public Interest 

The safety and efficiency of solar photovoltaic (PV) systems is heavily dependent upon 

regular inspection of the solar panels, whether located on the roofs of commercial properties, or 

in large ground mounted arrays operated by power companies across the United States. There 

are a wide variety of factors that can affect safety and perfonnance, including quality of system 

design and installation, product workmanship, weather or other site-specific events, and even 

nonnal wear and tear. In addition, the solar panels need to be inspected and maintained 

throughout their usable life. By using sUAS surveillance, Amplify Energy will be able to 

substantially upgrade its capacity to detect and address conditions before they become a problem. 

1 P.L.I12-95, 126 Stat 11, February 14,2012. 

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding 

that a type of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated 

areas, and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a 

threat to national security. 

3 14 C.F.R. §11.81(e). 

2 
Operations and maintenance employees routinely inspect solar panels. At present, this 

work is done primarily by company personnel in motor vehicles or on foot. This is often a laborintensive and sometimes dangerous job. Employees may currently be required to inspect panels 

that are installed on the tops of buildings, where there is a significant risk of falling. While the 

company does all it can to make these inspections as safe as possible, there is an irreducible 

element of risk involved whenever employees are required to go out and inspect the customer's 

solar panels. While the use of sUAS for inspection and surveillance would not eliminate these 

risks entirely, it would reduce the risks to employees by allowing them to work from safer 

locations during sUAS aerial operations. 

The operations anticipated by Amplify Energy are similar to the types of operations 

currently being conducted by other energy infrastructure companies and by insurance companies 

operating under exemptions already granted by the FAA under Section 333. Accordingly, 

Amplify Energy believes there is precedent in the FAA allowing these types of operations. 

Amplify Energy therefore requests that the FAA waive publication of this request in the Federal 

Register. Should the FAA determine publication is appropriate, a summary of this request 

suitable for publication in the Federal Register is provided as Appendix A. 

Granting an Exemption will not Adversely Affect Safety 

Amplify Energy notes that there is no applicable standard for an equivalency 

determination of sUAS. As such, we believe it makes more sense to focus on why the 

contemplated operations would not adversely affect safety, which is all that § 11.81 (e) requires. 

Amplify Energy contemplates conducting sUAS operations over the customers' owned or 

controlled land, solely during daylight hours, and at altitudes well below that which would pose a 

risk to other aircraft. The nature of operations anticipated by Amplify Energy requires that the 

sUAS be flown at relatively low altitudes and relatively low speeds. Flights will be operated at 

an altitude of no more than 400 feet AGL. Accordingly, the risk of interference with another 

aircraft is minimal. Amplify Energy also plans to conduct sUAS operations at least five miles 

from any public airports (including heliports). In the event an operation needs to be conducted 

closer to an airport, Amplify Energy will inform the airport operator and airport air traffic control 

tower of the contemplated operation and will comply with any directions issued by air traffic 

control at that airport. 

All operations will be within visual line-of-sight of the sUAS operator (PIC) and any 

visual observer. The aircraft will yield the right of way to manned aircraft. The PIC will have at 

least a recreational or sport pilot certificate and the valid medical certificate or driver's license 

required for the type of pilot certificate held. Each PIC will continue to meet the flight review 

requirements specified in 14 C.F.R. §61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. Depending on the type of operation, additional ground-based visual observers 

may be employed as well. These observers will be within constant visual line of sight of the 

sUAS and in constant contact with the PIC. The visual observers will assist the PIC in avoiding 

objects near the sUAS. Flight will be aborted in the case of unforeseen obstacles or emergencies. 

3 
The sUAS Meets the Requirements under Section 333, Justifying a Waiver of the Requirement 

for an Airworthiness Certificate 

Amplify Energy has designed and constructed its own sUAS (AEUA V -0 I) that it will 

use in the operations contemplated by this exemption request, a fuller description of which is 

attached as Appendix B. The aircraft has a total width of approximately one meter, including 

rotors. The aircraft is equipped with three cameras (one of which is used for first person view 

flight), a GPS and compass unit, and a 4 m2 parachute. The weight of the aircraft, including 

payload, is approximately 25 lbs. The aircraft will be operated at speeds less than I 00 mph. 

In addition, Amplify Energy may use a DJI S I 000 sUAS in the anticipated operations. 

The FAA has already determined that this sUAS merits a waiver from the airworthiness 

requirements under the criteria listed in Section 333 and has already granted numerous 

exemptions to other commercial operators using this make and model of sUAS. This submission 

does not include the User Manual for the DJI S 1000 as it has already been reviewed by the 

Administrator in granting previous exemptions. A copy of the User Manual for the DJI S 1000 

will be submitted on request. 

Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. § 11.81, Amplify Energy 

provides the following information: 

Contact Information 

Chris Denten 

General Counsel 

Amplify Energy, Inc. 

601 California Street, Suite 1150 

San Francisco, CA 941 08 

415-788-8816 

legal@amplifyenergy.com 

Regulatory Provisions from which Amplify Energy seeks an Exemption 

Amplify Energy believes it may need an exemption from the following provisions to 

conduct the contemplated operations. In some instances, relief is needed because relief from 

another provision renders compliance with the regulation at hand infeasible. 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61.101(e)(4) and (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 

4 
14 C.F.R. §91.15I(a)(l) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a)(l) 

14 C.F.R. §91.409(a)(l) and (2) 

14 C.F.R. §91.417(a) and (b) 

Amplify Energy believes an exemption is only needed from the above-listed regulatory 

provisions. To the extent that the FAA believes that additional relief is required for Amplify 

Energy to conduct the operations described here, we request an exemption from any such 

regulatory provisions as well. 

The Extent of Requested Relief and the Reasons Relief is Needed 

14 C.F.R.61.23(a) and (c),l4 C.F.R. 61.101(e){4) and (5), 14 C.F.R. 61.113{a), and 14 C.F.R. 

61.315(a) 

§61.23 Medical certificates: Requirement and duration. 

(a) Operations requiring a medical certificate. Except as provided in paragraphs 

(b) and (c) of this section, a person-

( I) Must hold a first-class medical certificate: 

(i) When exercising the pilot-in-command privileges of an airline transport pilot 

certificate; 

(ii) When exercising the second-in-command privileges of an airline transport 

pilot certificate in a flag or supplemental operation in part 121 ofthis chapter that 

requires three or more pilots; or 

(iii) When serving as a required pilot flight crew member in an operation 

conducted under part 121 of this chapter if the pilot has reached his or her 60th 

birthday. 

(2) Must hold at least a second class medical certificate when exercising: 

(i) Second-in-command privileges of an airline transport pilot certificate in part 

121 of this chapter (other than operations specified in paragraph (a)(l )(ii) of this 

section); or 

(ii) Privileges of a commercial pilot certificate; or 

(3) Must hold at least a third-class medical certificate-

(i) When exercising the privileges of a private pilot certificate; 

(ii) When exercising the privileges of a recreational pilot certificate; 

(iii) When exercising the privileges of a student pilot certificate; 

(iv) When exercising the privileges of a flight instructor certificate and acting as 

the pilot in command; 

(v) When exercising the privileges of a flight instructor certificate and serving as 

a required pilot flight crewmember; 

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, 

commercial pilot, or airline transport pilot certificate, or for a flight instructor 

certificate; or 

5 
(vii) When performing the duties as an Examiner in an aircraft when 

administering a practical test or proficiency check for an airman certificate, rating, 

or authorization. 

*** 

(c) Operations requiring either a medical certificate or U.S. driver's license. (1) A 

person must hold and possess either a medical certificate issued under part 67 of 

this chapter or a U.S. driver's license when-

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot 

privileges in a light-sport aircraft other than a glider or balloon; 

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft 

other than a glider or balloon; 

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot 

rating while acting as pilot in command or serving as a required flight 

crewmember of a light-sport aircraft other than a glider or balloon; or 

(iv) Serving as an Examiner and administering a practical test for the issuance of a 

sport pilot certificate in a light-sport aircraft other than a glider or balloon. 

(2) A person using a U.S. driver's license to meet the requirements of this 

paragraph must-

(i) Comply with each restriction and limitation imposed by that person's U.S. 

driver's license and any judicial or administrative order applying to the operation 

of a motor vehicle; 

(ii) Have been found eligible for the issuance of at least a third-class airman 

medical certificate at the time ofhis or her most recent application (if the person 

has applied for a medical certificate); 

(iii) Not have had his or her most recently issued medical certificate (if the person 

has held a medical certificate) suspended or revoked or most recent Authorization 

for a Special Issuance of a Medical Certificate withdrawn; and 

(iv) Not know or have reason to know of any medical condition that would make 

that person unable to operate a light-sport aircraft in a safe manner. 

***** 

§61.101 Recreational pilot privileges and limitations. 

*** 

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot 

may not act as pilot in command of an aircraft-

*** 

(4) For compensation or hire; 

(5) In furtherance of a business; 

***** 

§61.113 Private pilot privileges and limitations: Pilot in command. 

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as pilot in command of an aircraft. 

***** 

6 
§61.315 What are the privileges and limits of my sport pilot certificate? 

(a) If you hold a sport pilot certificate you may act as pilot in command of a lightsport aircraft, except as specified in paragraph (c) of this section. 

***** 

The FAA has previously determined that individuals holding a recreational or 

sport pilot certificate possess the requisite knowledge of the national airspace system to 

safely operate a sUAS. This is particularly true since many of the skills required for a 

private or commercial pilot's certificate do not apply to the operation of a sUAS. The 

FAA has also recognized that, absent an exemption, all pilots other than commercial 

pilots could not receive compensation for their work as PIC. Accordingly, the FAA has 

granted well over one hundred exemptions that permit an individual possessing at least a 

recreational or sport pilot certificate to act as PIC and be compensated. Granting 

Amplify Energy's request would be consistent with FAA precedent in this regard. 

14 C.F.R. 91. 7(a) 

§91. 7 Civil aircraft airworthiness. 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

***** 

Amplify Energy has requested that the FAA determine that the sUAS that is the subject 

of this exemption request need not have an airworthiness certificate, as evaluated under the 

criteria set forth in Section 333. The sUAS will not have a type design or type certificate, as the 

FAA has not developed standards applicable to sUAS. The types of operations contemplated by 

Amplify Energy also will not qualify the sUAS for an experimental airworthiness certificate. 

Accordingly, relief from §91.7(a) is required. 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: 

*** 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

***** 

Amplify Energy submits that the only relief it requires from §91.119 is from the 

minimum altitudes listed in paragraph (c). Relief is required as inspection of solar panels 

conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at 

this altitude also pose a heightened risk of collision with another aircraft, safety can only be 

7 
assured through the grant of an exemption. As noted in the explanation of why an exemption 

will not adversely affect safety, Amplify Energy's customers own or otherwise control the land 

over which the sUAS will be operated, and public access may be restricted. Amplify Energy will 

assure that no individuals unassociated with the planned surveillance are on the affected land 

unless they are behind or underneath a barrier or other structure sufficient to protect them from 

the aircraft or aircraft debris. 

14 C.F.R. 91.121 

§91.121 Altimeter settings. 

(a) 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-

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of this 

section, the current reported altimeter setting of an appropriate available station; 

or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92 '' Hg. 

(b) The lowest usable flight level is determined by the atmospheric pressure in the 

area of operation as shown in the following table: 

Current altimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.41 through 28.92 190 

28.91 through 28.42 195 

28.41 through 27.92 200 

27.91 through 27.42 205 

27.41 through 26.92 210 

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the 

minimum flight level, the pilot shall take the flight level equivalent of the 

minimum altitude in feet and add the appropriate number of feet specified below, 

according to the current reported altimeter setting: 

Current altimeter setting Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

8 
127.41 through 26.92 3,000 

The FAA requires any altitude reported to Air Traffic Control to be in feet AGL. As 

noted in the aircraft description, the AEUAV-01 aircraft is equipped with a GPS. as is the DJI 

S 1000. The altitude indicator for the GPS may be set at zero feet AGL rather than local 

barometric pressure or field altitude before Amplify Energy commences the flight. Because 

operations will take place at only low altitudes, Amplify Energy seeks relief from §91.121 to the 

extent necessary to comply with any conditions and limitations on altitude imposed as a part of 

any grant of this exemption request. 

14 C.F.R. 91.151(a){1) 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin 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. 

***** 

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve fuel does 

not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in 

the event it has to be flown to an alternate airport or circle the planned airport in the event of 

unanticipated conditions. Amplify Energy does not intend to use the sUAS for point-to-point 

flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an 

airport in order to land. Rather, Amplify Energy will operate the sUAS using pre-planned flight 

paths (taking into account weather conditions) designed to allow the sUAS to fly to the point of 

intended landing. As such, it should be sufficient to require only as much additional excess 

flight capacity as necessary to safely land the sUAS. We believe that a 25% residual battery life 

is more than sufficient to meet this objective. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a)(l) and (2), and 14 C.F.R. 91.417(a) and 

(b) 

§91.405 Maintenance required. 

Each owner or operator of an aircraft 

(a) 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; 

***** 

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or 

alteration. 

(a) No person may operate any aircraft that has undergone maintenance, 

rebuilding, or alteration unless9 
(1) It has been approved for return to service by a person authorized under §43. 7 

of this chapter; 

***** 

§91.409 Inspections. 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had _ 

(I) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter: or 

(2) An inspection tor the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

***** 

§91.417 Maintenance records. 

(a) Except for work performed in accordance with §§91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) ofthis section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 1 00-hour. annual, progressive. and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 

(i) The total time in service ofthe airframe, each engine, each propeller, and each 

rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies ofthe forms prescribed by §43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

10 
(I) The records specified in paragraph (a)(l) ofthis section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service. 

***** 

Amplify Energy believes that an exemption from these four maintenance requirements 

is appropriate because the FAA has not developed maintenance standards that would allow an 

operator to meet the part 91 maintenance requirements. In particular, there are no individuals 

authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct 

the initial airworthiness and annual return to service inspections required by §91.409(a). 

Amplify Energy will maintain the aircraft as instructed in the operator's manual and will not 

operate the aircraft until it has reasonably determined that any needed repairs have been made. 

However, because of the technical impossibility of meeting the requirements of §§91.405(a), 

407(a) and 409(a). Amplify Energy believes an exemption is merited. Since none of these 

underlying requirements (e.g., inspection intervals) can be met and will require an exemption, 

Amplify Energy believes an exemption from §91.417, which references these sections, is also 

appropriate. A copy of the User Manual for the AEUAV-01 is attached as Appendix C. 

Amplify Energy understands the FAA has already reviewed the User Manual for the DJI S 1000 

and has not provided it here. Amplify Energy will provide the manual if requested by the FAA. 

Please do not hesitate to contact me at the phone number or via the e-mail address 

provided above should you have any questions or concerns. 

Attachments 

Respectfully submitted. 

Chris Denten 

General Counsel 

11 
Appendix A- Summary for Federal Register Publication 

Pursuant to 14 C.F.R. Part 1 L the following summary is provided for publication in the Federal 

Register should the FAA determine that publication is needed. 

Petitioner: Amplify Energy, Inc. 

Sections of 14 C.F.R. Affected: 

14 C.F.R. §61.23(a) and (c) 

14 C.F.R. §61.101(e)(4) and (5) 

14 C.F.R. §61.1 13(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)(l) 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a)(l) 

14 C.F.R. §91.409(a)(l) and (2) 

14 C.F.R. §91.417(a) and (b) 

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. 

§§61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(l), 

91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b) to conduct sUAS operations, 

solely during daylight hours, to assist in the safe inspection and operation of solar panels. The 

nature of operations anticipated by Amplify Energy requires that the sUAS be flown at relatively 

low altitudes. Flights will be operated at an altitude of no more than 400 feet AGL. Accordingly, 

the risk of interference with other aircraft is minimal. 

12 
Appendix B- Description of Amplify Energy PV Inspection Aircraft 

Confidential Treatment Requested 

13 
Appendix C- User Manual for Amplify EnergyPV Inspection Drone (UA V) Model 

AEUAV-01 

Confidential Treatment Requested 

14