**Do uglas Trudeau, R**  **ealtor®, Tucson AZ** 

**- Section 333 Exemption**  **Petition**

Do uglas Trudeau, R ealtor®, Tucson AZ

- Section 333 Exemption Petition Page 6 of 9 

### A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements

for procurement of necessary airworthiness certificates in relation to FAR §

91.203(a)(1). The size, weight and enclosed operational area of my, Douglas

Trudeau ’s

, UAS permits exemption from Part 21 because my UAS meet s (and

exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act.

The FAA is authorized to exempt aircraft from the airworthiness certificate

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the

Reform Act. Both pieces of l egislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations. My,

Douglas Trudeau ’s

, current and projecte d UAS 's meet or exceed each of the

elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness

certificate. As no such certificate will be applicable in the form contemplated by the

FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are

no on board pilots or passengers, and given the size of the UAS's , this Regulation is

inapplicable. An equivalent level of safety will be achieved by maintaining a**Do uglas Trudeau, R**  **ealtor®, Tucson AZ** 

**- Section 333 Exemption**  **Petition**

Do uglas Trudeau, R ealtor®, Tucson AZ

- Section 333 Exemption Petition Page 7 of 9 

### s afety/ flight manual delineating areas of where safety can be defined

. 10 

### The FAA

has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737,

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilize s

electronic global positioning systems with a barometric sensor

.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and

regis trations. They are inapplicable for the same reasons described above. The equivalent

level of safety will be achieved by maintaining any such required certifications and

registrations by me, Douglas Trudeau

.

B. 14 C.F.R. § 45.23: Marking of The Aircr aft.

Applicable Codes of Federal Regulation require aircraft to be marked according to

certain specifications. My UAS are, by definition, unmanned. They therefore do not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

two

- inch lettering is difficult to place on such small aircraft with dimensions smaller that

minimal lettering requirement

. Regardless, I will mark its UASs in the largest possible

lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 C.F.R.

§ 45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see

the markings. The FAA has previously issued exemptions to this regulation through

Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F. R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial

operations. I, Douglas Trudeau, can achieve an equivalent level of safety as achieved by

current Regulations because my UAS do es not carry any pilots or passengers. Further,

while helpful, a pilot license will not ensure remote control piloting skills. T he risks

attend ed to the operation of my UAS is far less than the risk levels inherent in the

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing me, Douglas

Trudeau, to operate my UAS meet and exceed current safety levels in relation to 14

C.F.R. §61. 113 (a) & (b).

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

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows

helicopters to be operated at lower altitudes in certain conditions. My UAS will never

operate a t an altitude greater than 2 00 AGL ; safely below the standard of 400 AGL

. I,

Douglas Trudeau, will however operate my UAS in safe areas away from public and

traffic

, providing a level of safety at least equivalent to or below those in relation to

minimum s afe altitudes. Given the size, weight, maneuverability and speed of my UAS,

an equivalent or higher level of safety will be achieved.

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

10 Appendix E

- Safety/Flight Manual**Do uglas Trudeau, R**  **ealtor®, Tucson AZ** 

**- Section 333 Exemption**  **Petition**

Do uglas Trudeau, R ealtor®, Tucson AZ

- Section 333 Exemption Petition Page 8 of 9 The above

- cited Regulati ons require, amongst other things, aircraft owners and

operators to “have [the] 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 repai red as prescribed in part 43 of this chapter.

. . .”

These Regulations only apply to aircraft with an airworthiness certificate. They will not,

therefore, apply to my, Douglas Trudeau's, UAS. However, as a safety precaution I inspect m y

UAS before and after each flight.



### A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H,

entitled Airworthiness Certificates, sets forth require ments for procurement of necessary

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and

enclosed operational area of my UAS permits exemption from Part 21 because my,

Douglas Trudeau ’s

, UAS meet s an equivalent level of safety pursuant to Section 333 of

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of

the Reform Act. Both pieces of legislation permit the FAA to ex empt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed,

maneuverability and proximity to areas such as airports and dense populations. My

UAS meet s or exceed s each of the elements. 14 C.F.R. 91.7(a) prohibits the operation

of an aircraft without an airworthiness certificate. As no such certificate will be

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no

pilots or passengers, and given the size of the UAS's , this Regulation is inapplicable. An

equivalent level of safety will be achieved by maintaining a manual. The FAA has

previously issued exemptions to this regulation in Exemption Nos. 8 607, 8737, 8738,

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software

updates and curative measures for any damaged hardware. Therefore, an equivalent

level of safety will be achieved.