32530 Prescott ! Romulus, MI 48174

P: 734.368.0170 E: gr8day4flying@gmail.com

August 16 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue , SE Washington, DC 20590

Aerial Inspection & Filming Services, LLC’s Petition for

Exemption to Operate Small Unmanned Aircraft Systems

FAA Regulatory Docket

NAME AND ADDRESS OF PETITIONER

Aerial Inspection & Filming Services , LLC Attn: Joseph C. K. Sayer , ATP, CFI

32530 Prescott Romulus, MI 48174

734.368.0170 gr8day4flying@gmail.comAugust 16 , 2015 Page 2

SUMMARY of PETITION Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No.

112

- 95, 126 Stat.11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, Aerial Inspection & Filming Services

, LLC (“ AIF Services ”), a developer and operator of small unmanned aircraft systems (singularly a “sUAS” or cumulati vely “sUASs”) seeks an exemption from the Federal Aviation Regulations listed below, to allow commercial operation of its sUASs.

Aerial Inspection & Filming Services , LLC a division of JST Development, LLC

, General Contr actor, Electrical Contracting and C onstruction C onsultants since 2003

, that provides professional construction services

. AIF Services is a n inspection and filming services company

, specializing in the development and commercialization of small unmanned aircraft systems for the use in data and imagery collection for both public and private sec tor clients. Under the leadership of Joseph Sayer a n A irline T ransport P ilot

, Gold Seal CFI and former FAA A ccident P revention C ounselor for the Detroit , MI

FSDO

, AIF Services will work with sUAS manufactures , engineers and pilots to advance

sUAS system safety and reliability. Wit h a solid understanding of structural insp ections and aeronautical operations AIF Services is uniquely qualified to carry out a wide verity

of sUAS assignments

.

This requested exemption would permit t he operation of small unmanned aircraft systems

under controlled condition s in airspace that (a) is limited, (b) is predetermined, (c) is controlled as to access, and (d) would provide safety enhancement s to the already safe

op erations in the inspection and filming industry . Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s responsib ilities to

“ establish requirements for the safe operation of such aircra ft systems in the national airspace system.” Reform Act 333 (c).

The Applicant hereby requests exemption from the following FARs:

• 14 C.F.R. 61.3

• 14 C.F.R. 61.113(a)&(b)

• 14 C.F.R. 61.133(a)

• 14 C.F.R. 91.9(b)(2)

• 14 C.F.R. 91.103(b) (1)&(2)

• 14 C.F.R. 91.105August 16 , 2015 Page 3

• 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203(a) & (b)

• 14 C.F.R. 91.319(a)(1)

• 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize AIF Services to conduct commercial operations using the DJI Phantom 3 , DJI Inspire 1, 3DR X8+ and Aeronavics SkyJib X4

XL sUAS s for aerial surveying, remote sensing, building and infrastructure inspection, cell phone towers, bridges, insurance adjusting, real estate marketing and survey s precision agriculture, aerial filmmaking and photography, public entity support operations, utility system inspections and patrolling, construction site inspection and

monit oring, wildlife and fores try monitoring, educational, training and research operations, flare stack inspection, and pipeline inspection and patrolling.

In order to ensure at least an equivalent level of safety to currently authorized operations using manne d aircraft, all operations will be subject to the strict operating requirements

defined in the AIF Services sUAS Flight Operations Manual and Preflight Checklist ( AIF

Services will provide these documents if required, but requests that the FAA treat them a s proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket). Additionally, this petition for exemption is supported by the information contained in the manufacturer’s operations m anuals for all the sUASs listed as well as the manufacturer’s operations m anuals for the Pixhawk autopilot navigation system.

All AIF Services sUAS will be operated only by individuals who hold at least an FAA issued private, recreational, or sport pilot certificate and who have successfully completed AIF Services ’ sUAS Training Program (the AIF Services sUAS Training Program Outline will be submitted separately if required and AIF Services requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) and not include this

document i n the public docket).

T he sUAS operator requirements , characteristics and operating parameters detailed below

will ensure that all AIF Services sUAS operations are carried out with an equivalent or higher level of safety than currently authorized manned aircraft operations. The sUAS applications cited below will provide clear evidence that approval of this exem ption is in the public interest.August 1 6 , 2015 Page 4

CHARACTERISTICS OF THE sUAS

All the sUAS operated by AIF Services have well

- established performance histories and have already been utilized for commercial use by other operators with FAA exemptions

. Part of AIF Services’ risk mitigation plan is to integrate these specific aircraft into our

fleet.

sUAS FAA Exemption Number

DJI Phantom 3 11481

DJI Inspire1 11279

3DR X8+ 11307

Aeronavics SkyJib X4 XL 11559

Pixhawk Autopilot & Navigation 11192

The maximum takeoff weight of any sUAS operated by AIF Services would not exceed

55 lbs. No sUAS operated by AIF Services is capable of exceeding speeds of 7 5 mph

. All four sUAS contain an on

- board GPS and an inertial measurement unit for flight

stabilization and automatic failsafe r eturn to home in case of control signal loss

. Additionally, these sUAS offer geo

- fencing and max altitude features to restrict the maximum vertical and horizontal distance the aircraft will fly from its home point. All these systems have the feature of displaying r eal time flight data, including battery status,

altitude and distan ce from home

. The Pixhawk system used on the 3DR X8+ and Aeronavics SkyJib X4 XL records “blackbox” type data via line telemetry for mission

review. This provides a substantial accountability for existing flight operations . This

valuable data can be collected, reviewed and analyzed by industry for future safety

related enhancements.

Each sUAS operated by AIF Services for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accordan ce with 14 C.F.R. Part 45, Subpart C, in a size as large as practical for the size of the sUAS

.

All sUASs operated by AIF Services will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the sUAS’s maintenance log. Maintenance log entries will include the date, sUAS ID number, registration number, current sUAS flight time, a description of work performed, and the name of the individual who completed the work. An y sUAS that hasAugust 16 , 2015 Page 5

undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight, prior to use in any commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undu e hazard to persons and property. The PIC who conducts the functional test flight must make an entry in the aircraft records. A pre

- flight inspection of the sUAS will be completed by the PIC prior to each flight operation as specified in the AIF Services s UAS Flight Operations Manual. If the inspection reveals a condition that affects the safe operation of the sUAS , the aircraft is prohibited from operating until the necessary maintenance has been performed and the

sUAS is found to be in a condition for saf e flight. All AIF Services s UAS will comply with all applicable manufacturer safety bulletins.

Additional information for each aircraft ’s specifications, performance limitations, operating procedures, and pre

- flight inspections is contained in the attached documents. The safety and reliability of these sUAS is further supported by the fact that numerous FAA exemptions have previously been approved for their use in commercial operations.

sUAS OPERATOR REQUIREMENTS

All AIF Services sUAS operators will hold at least an FAA issued private, recreational, or sport pilot certificate and will have successfully completed AIF Services’ sUAS Training Program. Completion of the AIF Services sUAS Training Program will ensure safe operations by not allowing any PIC to operate a sUAS unless that PIC has demonstrated, that he/she is able to safely operate the sUAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. All operators will either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations a nd issues perti nent to commercial operation of AIF Services’ small unmanned aircraft systems

.

The individual acting as PIC of a sUAS will be identified prior to any flight and will not change once the flight has begun. The PIC is the individual in operatio nal control of the flight operation from beginning to end and is responsible for safe flight of the sUAS. All PIC flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR § 61.51(b).

In order to act as PIC, all AIF Services sUAS operators will 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 posses sion, or the Federal governmentAugust 16 , 2015 Page 6

s UAS OPERATING PARAMETERS

AIF Services realizes that every flight/mission carries with it a level of risk and hazards associated with that specific operation. These risks are dynamic and cumulative in nature, and because of this we have incorporated the p rocedures and guidelines provided within the FAA document titled: Risk Management Handbook, 2009. This information resource will provide a model that will assist us in quantifying specific risks. Utilizing the Risk Matrix tool will enhance our ability to m itigate various risks and improve our overall aeronautical decision making process, as it relates to each individual mission.

In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all AIF Services comm ercial sUAS operations will be conducted in accordance with the following specific operating limitations:

• T he sUAS will not be operated a t a speed exceeding 75 miles per hour

. In no case will the sUAS be operated at airspeeds greater than the maximum sUAS operating airspeed recommended by the aircraft manufacturer.

• All operations shall be conducted in accordance with an ATO

- issued COA.

• All sUAS operations will occur at or below 500 ft AGL or the maximum altitude specified in the COA limitations, unless the purpose of the flight is to inspect a building or structure which is taller than 500 ft. If the purpose of the flight is to inspect a building or structure which is taller than 500 f t then the max altitude of

t he sUAS will be restricted to 30 ft above the highest point of that building or structure. All altitudes must be reported in feet AGL.

• No sUAS will be operated within 3 nautical miles of an airport reference point (ARP) as denot ed 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 obta ined or otherwise permitted by a COA issued to

AIF Services . The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

• No sUAS will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling ATC office is obtained or the flight is otherwise permitted by a COA issued to AIF Services . The letter of agreement from ATC

must be made available to t he Administrator or any law enforcement official upon

request.

The sUAS 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, a s specified on the PIC’s FAA

- issued airman medicalAugust 16 , 2015 Page 7

certificate or U.S. driver’s license.

• All operating documents and a grant of exemption must be accessible during sUAS operations and made available to the Administrator upon reque st. If a discrepancy exists between the conditions and limitations in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations in the grant of exemption take precedence and must be followed. Otherwise, t he PIC must follow the procedures as outlined in the operating

documents. AIF Services may update or revise its operating documents. However,

it is AIF Services’ responsibility to track such revisions and present updated and

revised documents to the Admini strator or any law enforcement official upon
request. AIF Services must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If AIF Services determines that any update or revision would affect the basis upon which the FAA granted the exemption, then AIF Services must petition for an amendment to the grant of exemption.

• sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteo rological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. The sUAS will 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 t he PIC.

• Prior to each flight the PIC will inspect the sUAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft is prohibited from operating until the necessar y maintenance has been performed and the sUAS is found to be in a condition for safe flight. All maintenance and al terations will be properly documented in the

aircraft records.

• Any sUAS that has undergone maintenance or alterations that affect the sUAS

o peration or flight characteristics, e.g. replacement of a flight critical component,

will undergo a functional test flight. The PIC who condu cts the functional test flight will make an entry in the aircraft records.

• If the s UAS loses communications or los es its GPS signal, the sUAS will return to a predetermined location.

• The PIC wil l abort the flight in the event of unpredicted obstacles or emergencies.

• The PIC is prohibited from beginning a flight unless the sUAS’s battery level i s at 75% or higher. Th e PIC will begin returning the sUAS to the designated landing area when the battery level drops below 25%.August 16, 2015 Page 8

• Documents used by the operator to ensure the safe operation and flight of the sUAS and any documents required unde r 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the sUAS any time the

aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

• The sUAS will r emain clear and give way to all manned aviation operations and

activities at all times.

• The sUAS will not be operated by the PIC from any moving device or vehicle.

• sUAS will not be operated directly over nonparticipating persons unless barriers or structures are present that sufficiently protect nonp articipating persons from the

sUAS and/or debris in the event of an accident. sUAS will not be operated over

any open

- air a ssembly of people.

• Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours.

Acc idents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

APPLICATIONS AND PUBLIC INTEREST

The requested exemption would allow AIF Services to operate the DJI Phantom 3 , DJ I Inspire 1, 3DR X 8+ and Aeronavics SkyJib X4 XL sUAS s for the purposes of inspection

a nd photography of buildings and other structures. These inspections and investigations

are co mpleted on both residential, commercial , industrial and institutional properties and are typically conducted in support of the property insurance industry. Use of sUAS for these applications will offer significant advantages related to safety, time, and cost. Most properties throughout the country are insured, and property owners have an interest in insurance underwriting, coverage, and claims processing; therefore it is clear that grant of this exemption would be in the public interest.

Current options for gathering the data which under this exemption would be collected using sUAS, include use of ladders, lifts, and manned aircraft. Use of ladders and lifts are inherently dangerous and result in numerous injuries each year. Use of manned aircraft is typically not feasible and therefore valuable information remains beyond the reach of the investigator. In most cases, use of a sUAS is quicker and easier than any other alternative and often yields better information. Due to their small size and the fact they carry no fuel, sUAS pose a very low risk of damage to persons or st ructures on the ground. Because these sUAS are electric powered, they create no harmful emissions and makeAugust 16 , 2015 Page 9

very little noise. Given these improvements t he quality of the data can be enhanced by t he ability of the sUAS to bring the sensor closer to the target. In many instances this can help prevent catastrophic structural failure.

AIF Services will also lead efforts to advance the safety and reliability of sUAS s in

various operations. Working with aircraft manufac tures , engineers and pilots AIF Services will continually look to improve flight systems, aircraft capability and training

material. AIF Services believes this substantially complies with the intent of serving the public good.

SUMMARY THAT CAN BE PUBLISHE D IN THE FEDERAL REGISTER

AIF S ervices requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulations which would allow it to operate s UAS s for commercial use: 14 C.F.R Sections 61.3, 61.113(a)& (b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417

CONCLUSIONS

AIF Services respectfully requests that the FAA grant the exemption sought in this

request. AIF Services believes that considering the small size and weight of the sUAS s , along with the sUAS s PIC training and certification requirements stipulated above and the strict operating guidelines proposed herein, it is clearly demonstrated that the sUAS s will be operated safely in the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft.

We are prepared to modify or amend any part of this request as deemed necessary by the FAA to satisfy the need for an equiva lent level of safety. Please contact us at any time if you require additional information or clarification.

Respectfully submitted,

Joseph C. K. Sayer , ATP, CFI

President Aerial Inspection & Filming Services , LLCAugust 16 , 2015 Page 10

ATTACHMENTS :

FAA

- A

- H

- 8083

- 2 Risk Management Han d book

DJI Phantom 3 Specs Sheet

DJI Phantom 3 User Manual

DJI Phantom 3 Intelligent F ight Battery Safety Guidelines

DJI Phantom 3 Quick Start Guide

DJI Phantom 3 Safety Guidelines and Disclaimer

3DR X8+ Overview 3DR X8+ Operation Manual 3DR X8+ Flight Checklist 3DR Safety Information

DJI Inspire1 User Manual

DJI Inspire1 Maintenance Manual

DJI Inspire1 Quick Start Guide

DJI Inspire1 Release Notes

DJI Disclaimer and Warning

Aeronavics SkyJib X4 XL Flight Operation and Safety Information Aeronavics SkyJib X4 XL Pre

- Flight Safety C heck Aeronavics SkyJib X4 XL B uild Manual

3DR Pixhawk Description

3DR Pixhawk Manual

3DR Pixhawk Mission Planner Recording Manual

3DR Pixhawk Mission Planner Manual

3DR Pixhawk Flight Data Screen ManualAugust 16 , 2015 Page 11

APPENDIX A: REGULATIONS REQUIRING EXEMPTION

AIF Services requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the the DJI Phantom

3 , DJI Inspire 1, 3DR X8+ and Aeronavics SkyJib X4 XL s UAVs :

14 C.F.R. § 61.3: Requirements for c ertificates, ratings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot fli ght crewmember of a civil aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercisin g the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may be used.

The regulation provides also that no person that holds a private pilot certifi cate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; (2) The aircraft does not carry passengers or property for compensation or hire.

Given the size, weight, speed, operational limitations, and range of the sUAS, AIF

Services proposes that operators of the s UAS should not be required to hold a commercial pilot certification. Instead, operators should be required to:

Hold at least an FAA issued private, recreational, or sport pilot certificate. All operators
will either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the

DJI Phantom 3 , DJI Inspire 1, 3DR X8+ and Aeronavics SkyJib X4 XLs s UAS.

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. AIF Services proposes to provide an equivalent leve l of safety by maintaining a copy of all documents used by the operator to ensure the safe operation and flight of the s UAS as well as documentation of an exemption and COA with the ground control station and accessible to the PIC during flight operations.August 16 , 2015 Page 12

14 C.F.R. § 91.103: Preflight action

This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include runway lengths at airports of intended use, and the following takeoff and landing distance information.

This regulation is not applicable due to the fact AIF Services sUAS operations will not occur at an airfield. To provide an equivalent level of safety, the PIC will complete a preflight inspection as directed by the manufacturer’s manuals and AIF Services s UAS operations manual before any flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls."

The equivalent level of safety will be achieved through AIF Services’ sUAS flight training program and conducting flight training within controlle d environments.

14 C.F.R § 91.105: Flight Crewmembers at Stations

The regulation states that required crewmembers must be at their stations in the aircraft during specific portions of a flight.

This is not applicable since the sUAS carry no crewmembers. An equivalent level of safety will be maintained by ensuring that the PIC is identified prior to any flight and that the PIC does not change during a flight. The PIC will maintain control of the s UAS for the duration of the flight.

14 CFR § 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the s UA S will be operating at a maximum of 500 feet AGL, these operations can not comply with this requirement.

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS. Additionally the sUAS will be operated in a defined and relatively small AOI. Moreover, the sUAS will not be operated over any o pen

- air assembly of persons or over any person not involved with the operation. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.August 16 , 2015

P age 13

14 CFR 91.121

– Altimeter settings

This section 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:

The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

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;

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. To provide an equivalent level of safety, the sUAS utilize a GPS system, barometric pressure sensors, and internal gyroscopes to calculate the altitude.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Given the area of operation for the UAS, AIF

Services believes th at an equivalent level of safety is achieved by requiring at least 75% battery power in order to begin a flight and requiring the UA to return to land when the battery power reaches 25%.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: No person may operate a civil aircraft unless it has an appropriate and current.

U.S. Department of Transportation

– Federal Aviation Administration Page 11 Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015 Appendix

Aairworthiness certificate.

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.

To obtain an equivalent level of safety and meet the intent of 91.203, AIF Services proposes to maintain a copy of all documents used by the operator to ensure the safe operation and flight of the sUAS as well as documentation of an exemption and COA with the ground control station and these will be available to the Administrator or any law enforcement official upon request.August 16 , 2015 Page 14

14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

- Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. 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.

AIF Services proposes that the maintenance, as well as preflight inspections of the sUAS will be accomplished by the PIC. All maintenance will be conducted and logged in

accord ance with the manufacturer’s specifications. An equivalent level of safety will be achieved because the sUAS are small in size, are not complex mechanical devices, and can be evaluated safely.