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.com
August 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 cumulatively 

“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 Contractor, Electrical Contracting and Construction Consultants since 2003, that 

provides professional construction services. AIF Services is an 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 sector clients. Under the leadership of Joseph Sayer an Airline Transport Pilot, 

Gold Seal CFI and former FAA Accident Prevention Counselor for the Detroit, MI

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

sUAS system safety and reliability. With a solid understanding of structural inspections 

and aeronautical operations AIF Services is uniquely qualified to carry out a wide verity 

of sUAS assignments.

This requested exemption would permit the operation of small unmanned aircraft systems 

under controlled conditions in airspace that (a) is limited, (b) is predetermined, (c) is 

controlled as to access, and (d) would provide safety enhancements to the already safe 

operations in the inspection and filming industry. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s responsibilities to 

“establish requirements for the safe operation of such aircraft 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. 91.105 
August 16, 2015

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• 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 sUASs for aerial surveying, remote sensing, building and infrastructure inspection,

cell phone towers, bridges, insurance adjusting, real estate marketing and surveys

precision agriculture, aerial filmmaking and photography, public entity support 

operations, utility system inspections and patrolling, construction site inspection and 

monitoring, wildlife and forestry 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 manned 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 as 

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 manuals for all the sUASs listed as well as the manufacturer’s 

operations manuals 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 in the public docket).

The 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 exemption is in 

the public interest.
August 16, 2015

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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 75 mph. 

All four sUAS contain an on-board GPS and an inertial measurement unit for flight 

stabilization and automatic failsafe return 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 real time flight data, including battery status, 

altitude and distance 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 accordance 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. Any sUAS that has
August 16, 2015

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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 undue 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 sUAS 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 safe flight. All AIF Services sUAS 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, vessels, 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 and issues pertinent 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 operational 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 possession, or the Federal government
August 16, 2015

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sUAS 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 procedures 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 mitigate 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 commercial sUAS operations will be conducted in 

accordance with the following specific operating limitations:

• The sUAS will not be operated at 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 ft then the max altitude of 

the 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 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 management is obtained 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 the 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, as specified on the PIC’s FAA-issued airman medical 
August 16, 2015

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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 request. 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, the 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 Administrator 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 meteorological 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 the 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 necessary 

maintenance has been performed and the sUAS is found to be in a condition for 

safe flight. All maintenance and alterations will be properly documented in the 

aircraft records. 

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

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

will undergo a functional test flight. The PIC who conducts the functional test 

flight will make an entry in the aircraft records. 

• If the sUAS loses communications or loses its GPS signal, the sUAS will return to 

a predetermined location. 

• The PIC will 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 is at 

75% or higher. The PIC will begin returning the sUAS to the designated landing 

area when the battery level drops below 25%. 
August 16, 2015

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• Documents used by the operator to ensure the safe operation and flight of the 

sUAS and any documents required under 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 remain 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 nonparticipating persons from the 

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

any open-air assembly 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. 

Accidents 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, DJI 

Inspire 1, 3DR X8+ and Aeronavics SkyJib X4 XL sUASs for the purposes of inspection 

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

are completed 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 structures on the ground. 

Because these sUAS are electric powered, they create no harmful emissions and make 
August 16, 2015

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very little noise. Given these improvements the quality of the data can be enhanced 

bythe 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 sUASs in 

various operations. Working with aircraft manufactures, 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 PUBLISHED IN THE FEDERAL REGISTER

AIF Services 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 sUASs 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 sUASs, 

along with the sUASs PIC training and certification requirements stipulated above and 

the strict operating guidelines proposed herein, it is clearly demonstrated that the sUASs

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 equivalent 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, LLC 
August 16, 2015

Page 10

ATTACHMENTS:

FAA-A-H-8083-2 Risk Management Handbook

DJI Phantom 3 Specs Sheet

DJI Phantom 3 User Manual

DJI Phantom 3 Intelligent Fight 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 Check

Aeronavics SkyJib X4 XL Build Manual

3DR Pixhawk Description

3DR Pixhawk Manual

3DR Pixhawk Mission Planner Recording Manual

3DR Pixhawk Mission Planner Manual

3DR Pixhawk Flight Data Screen Manual
August 16, 2015

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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 sUAVs:

14 C.F.R. § 61.3: Requirements for certificates, 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 flight 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 exercising 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 certificate 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 sUAS 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 sUAS.

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 level of 

safety by maintaining 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 accessible to the PIC during flight operations.
August 16, 2015

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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 sUAS 

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 controlled 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 sUAS 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 sUAS will be 

operating at a maximum of 500 feet AGL, these operations cannot 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 open-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

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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 that 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

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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 

accordance 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.