Catalyst Aviation, LLC 

68 Stacy Haines Road, Suite 110 

Lumberton, NJ 08048 

October 16, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sir or Madam, 

Catalyst Aviation, LLC is applying for an exemption from the Federal Aviation Regulations referenced in this 

document to allow for commercial operations utilizing its UAS equipment for the purposes of aerial data 

collection and photography. The company’s main objective is to be able to use UAS equipment to aid in the 

inspection of electric transmission and distribution systems. Catalyst Aviation, LLC intends to conduct all 

operations in accordance with the regulations set forth by the Federal Aviation Administration. 

Our company currently operates under a Part 135 Certificate. A helicopter is used to perform aerial 

inspections of various electrical systems. During these inspections, a utility worker identifies possible defects 

in the various components of a structure. We believe in many cases, the use of a UAS would significantly 

lower operational costs, increase public safety, reduce noise, and result in a reliable inspection method. All 

of these factors result in a benefit to the general public. 

Catalyst Aviation, LLC believes this application will satisfy all conditions set forth in Section 333 of the 

Reform Act. Safety is always our main concern and we feel the use of UAS for utility inspection meets or 

exceeds the level of safety currently experienced with traditional aircraft used for these purposes. 

The details of this application begin on the following page. Thank you for your consideration. 

Regards, 

Robet DeSosa 

Robert DeSousa 

Pilot / Flight Coordinator, Catalyst Aviation, LLC 

1
Exemption is Requested From the Following Regulations: 

Part 21, Subpart H ; 

45. 23 (b), 45. 25, 45. 27 (a), 45. 29 ; 

61. 113 (a) (b) , 61. 133 (a) ; 

91. 7 (a); 

91. 9 (b)(2)(c); 

91. 103; 

91. 105; 

91. 109 (a); 

91. 119; 

91. 121; 

91. 151 (a)(1) (b); 

91. 203 (a) (b); 

91. 405 (a); 

91. 407 (a)(1); 

91. 409 (a)(2); 

91. 417 (a) (b); 

Catalyst Aviation, LLC seeks exemption from the above mentioned FARs and presents the methods by which 

the company will ensure an equivalent or exceeding level of safety in regard to the regulations from which 

the exemption is sought. (14 CFR 11.81 (e). 

2
14 CFR Part 21, Subpart H, Airworthiness Certificates 

Section 91.203(a)(1) requires civil aircraft to have “an appropriate and current airworthiness certificate.” Part 

21, Subpart H (“Airworthiness Certificates”) establishes the procedural requirements and applicability for the 

issuance of airworthiness certificates as directed by 14 C.F.R. § 91.203(a)(1). 

Equivalent level of safety: The UAS operated will have a gross weight less than 55 lbs. and will be operated 

at speeds below 87 knots (100mph). Risk to persons or property is reduced since no personnel or 

passengers will be carried and no flammable fuel is required. All operations will be conducted using an 

Operator and if deemed required, a Visual Observer(s). All operations will be conducted in accordance with 

the limitations and conditions stated in this petition. The Federal Aviation Act and Section 333 of the Reform 

Act authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate upon 

consideration of the UAS’ size, weight, speed, operational capability and proximity to airports and populated 

areas. 

The conditions by which the UAS will be operated, as described in this petition, given the size, weight, 

speed and proximity to airports and populated areas achieve or exceed the level of safety currently 

experienced by using manned aircraft for the same purposes. 

The FAA has stated that no exemption is required from this section if a finding is made under the Reform Act 

that a UAS provides an equivalent level of safety compared to aircraft normally used for the same 

application. Please see granted exemptions 11138, 11062, 11067, 11080, 11114, and 11112. 

14 CFR 45.23 (b) , Display of marks; general 

This regulation states: “...the operator must also display on that aircraft near each entrance to the cabin, 

cockpit, or pilot station, in letters not less than two inches nor more than six inches high, the words ‘limited’, 

‘restricted’, ‘light-sport’, ‘experimental’, or ‘provisional’, as applicable.” 

Equivalent level of safety: Given the size of the UAS, letters not less than two inches in size may not be 

practical. If the size of the UAS is too small to display markings in the size described in 45.23 (b), then 

markings will be displayed in the largest practicable manner. Since the UAS does not have a cabin, cockpit, 

or cabin entrance, markings cannot be displayed “near the entrance”. Marking will be placed in the most 

visible areas of the UAS to allow for identification. 

14 CFR 45.25 , Location of marks on fixed wing aircraft 

14 CFR 45.25 states the aircraft “... must display the required marks on either the vertical tail surfaces or the 

sides of the fuselage...”. 

Equivalent level of safety: The design of the UAS is significantly different than traditional manned aircraft. 

Because of this, the marking requirements of 14 CFR 45.25 may not be feasible. An equal level of safety will 

be achieved by displaying markings on the most visible surfaces of the UAS to allow for easy identification. 

3
14 CFR 45.27 (a) , Location of marks; non-fixed-wing aircraft 

Regulation 14 CFR 45.27 (a) states that: “Each operator of a rotorcraft must display on that rotorcraft 

horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by 45.23.” 

Equivalent level of safety: The design of the UAS is significantly different than traditional manned aircraft. 

Because of this, the marking requirements of 14 CFR 45.25 may not be feasible. An equal level of safety will 

be achieved by displaying markings on the most visible surfaces of the UAS to allow for easy identification. 

14 CFR 45.29 , Size of marks 

Regulation 14 CFR 45.29 describes the required size of the marks and characteristics of the lettering for 

aircraft. In many cases, it dictates that marks be at least 12 inches high. 

Equivalent level of safety: The UAS is significantly smaller in size and can have a very different design 

layout when compared to traditional manned aircraft. The size and layout of marks described in 14 CFR 

45.29 may not be feasible. An equal level of safety will be achieved by displaying markings on the most 

visible surfaces of the UAS to allow for easy identification. If the UAS is too small to display markings in 

standard size, the aircraft markings will be displayed in the largest practicable manner. 

14 CFR 61.113 (a) (b) and 14 CFR 61.133 (a) , Private pilot privileges and limitations; pilot in command; 

commercial pilot privileges and limitations 

Regulation 14 CFR 61.113 restricts private pilots from flying aircraft for compensation or hire and requires a 

second class medical certificate. 14 CFR 61.133 requires a pilot to hold a commercial pilot’s license when 

acting as pilot in command of an aircraft used for compensation or hire. 

Equivalent level of safety: The UAS operated by Catalyst Aviation, LLC will be operated as part of a 

commercial operation, however no passengers or cargo will be carried. All UAS operations will remain below 

500 feet AGL, below 87 knots (100 mph), will not carry flammable fuel and will not exceed the weight of 55 

lbs. Please reference FAA Docket No. FAA-2014-0352. The FAA determined that UAS operations did not 

warrant the additional cost and restrictions imposed by requiring the operator to have a commercial pilot 

certificate along with a Class II Medical Certificate. 

All Catalyst Aviation LLC’s UAS operators will posses at least a private pilot certificate with a valid Class III 

Medical Certificate. Training will be provided to all operators. This training will be provided by either a third 

party or a custom in-house program. The program will follow industry best practices and consist of ground 

instruction as well as actual hands-on training to simulate the operating environment. 

Additionally, the security screening conducted by the Transportation Security Administration of certified 

airmen will satisfy the requirements of Section 333 to ensure that no operation poses a threat to national 

security. 

4
14 CFR 91.7 (a) , Civil aircraft airworthiness 

This regulation states: “No person may operate a civil aircraft unless it is in airworthy condition.” 

Equivalent level of safety: The FAA has stated that no exemption is required to the extent that the 

requirements of Part 21 are waived or found inapplicable. Catalyst Aviation LLC requests that the 

requirements of Part 91.7 be treated in accordance with FAR Part 21 Subpart H. Catalyst Aviation LLC’s 

operators will inspect the aircraft prior to each flight and ensure the aircraft is safe for flight. See granted 

exemption 11062. 

14 CFR 91.9 (b) (2) (c) , Approved flight manual in the aircraft 

Regulation 14 CFR 91.9 (b) (2) states: “No person may operate a U.S. registered civil aircraft ... for which an 

Airplane or Rotorcraft Flight Manual is not required by 21.5 of this chapter, unless there is available in the 

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof.” 

Regulation 14 CFR 91.9 (c) states: “No person may operate a U.S. registered civil aircraft unless that aircraft 

is identified in accordance with Part 45 of this chapter.” 

Equivalent level of safety: Catalyst Aviation LLC requests exemption from this regulation as outlined in the 

request for exemption from Regulation 14 CFR 91.203 (a) and (b). An equivalent level of safety and 

compliance will be achieved by keeping the proper documentation at the location of the Ground Control 

Station available to the operator at all times. This documentation includes the UAS operation manual 

provided by the manufacturer or equivalent documents created by Catalyst Aviation, LLC. 

The FAA, in accordance with the FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight 

manual, registration certificate and other documentation will be kept at the control station with the operator 

during flight. The Chief Counsel’s Office has held that for UAS operations, this alternative method 

constitutes full compliance with the regulations. See granted exemption 11062. 

14 CFR 91.103 , Preflight action 

This regulation requires the pilot in command to become familiar with specific information before each flight, 

including the information contained in the FAA approved flight manual on board the aircraft. 

Equivalent level of safety: The UAS design is significantly different than that of traditional manned aircraft. 

Because of this, the UAS does not have a flight manual physically on board. The operator will become 

familiar with the manufacturer supplied UAS manual for information prior to flight. The manual will be kept at 

the ground station during operations. In addition, the operator will review information prior to flight to 

maintain the safety of operation. This information will include but no limited to, the weather, battery levels, 

landing and takeoff distances and performance data. 

The FAA has stated that no exemption is required (see Grant of Exemption No. 11062, p.20) however, an 

exemption is requested to the extent that an FAA approved flight manual is required. 

5
14 CFR 91.105 , Flight crew members at stations 

14 CFR 91.105 contains requirements for crew members during takeoff and landing. Crew members are 

required to be at their stations unless absence is necessary to perform their duties. It also requires crew 

members to keep safety belts, including shoulder harnesses if equipped, fastened. 

Equivalent level of safety: The UAS does not carry pilots or passengers. There are no crew member 

stations. The UAS does have a Ground Control Station from which the operator controls the aircraft. The 

Ground Control Station may be a fixed location or mobile. However, the Ground Control Station is not a part 

of the aircraft and therefore may not have seats or safety belts. 

In addition to the operator, a visual observer will be utilized to keep the UAS in line of sight view and look out 

for general safety. The visual observer may not be at the fixed or mobile location and may or may not use a 

seat equipped with a safety belt. 

The use of a safety belt may not be feasible because the stations are not physically part of the aircraft and 

are not in motion. 

14 CFR 91.109 (a) , Flight instruction 

14 CFR 91.109 (a) states: “No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls.” 

By design, UASs do not generally have functioning dual controls. Control is accomplished via radio signals 

from a Flight Control System / Ground Control Station. 

Equivalent level of safety: During flight instruction, the aircraft will remain at a safe distance from nonparticipating individuals causing no safety hazard. No pilots or passengers will be on board the aircraft. 

We believe an equivalent level of safe training can be achieved without dual controls especially given the 

size and speed of the UAS. 

The FAA has previously granted exemptions for flight training without dual controls. See granted exemptions 

11109, 11138, and 11110. 

14 CFR 91.119 , Minimum safe altitudes 

14 CFR 91.119 states that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle 

or structure. The nature of Catalyst Aviation LLC’s operations may require operation in close proximity to 

items such as power lines towers or poles. However, operations will never be performed over nonparticipating individuals. 

Equivalent level of safety: The UASs operated by Catalyst Aviation LLC are significantly smaller than 

traditional, manned aircraft such as rotorcraft that are used for similar operations. The UAS does not carry 

persons or cargo, weighs less than 55 lbs., does not carry flammable fuel, will not exceed 87 knots (100 

6
mph) and will never be flown over non-participating individuals. Operations will remain below 500 AGL and 

will utilize an operator and visual observer to avoid risk to persons or property. This provides a greater level of 

safety when compared to traditional aircraft used for the same purposes. See granted exemptions 4063, 

11138, 11136, 11112, 11110, 11109, 11080, 11066, 11063, 11062 and 11067. 

14 CFR 91.121 , Altimeter settings 

14 CFR 91.121 requires aircraft to be operated by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure when operating below 18,000 feet MSL. Some UASs contain a 

barometric pressure sensor. Other types utilize GPS sensors to determine altitude. 

Equivalent level of safety: The operator will confirm the elevation of the departure point prior to takeoff. 

This information will be compared to the altitude provided by the GPS sensor or barometric sensor on the 

UAS. The sensor information is displayed at the Ground Control Station. The operator will determine the 

maximum permissible altitude to maintain flight below 500 feet AGL. This altitude will not be exceeded. The 

maximum permissible altitude will also be monitored by visual means. Visual reference will be maintained by 

the operator and visual observer as a secondary backup to the data provided by the UAS sensors. This will 

provide a level of safety that equals or exceeds the regulation. See granted exemptions 11153, 11150, 11138, 

and 11159. 

14 CFR 91.151 (a) (1) (b) , Fuel requirements for flight in VFR conditions 

14 CFR 91.151 (a) (1) states: “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...” 

14 CFR 91.151 (b) states: “No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.” 

Catalyst Aviation LLC will only operate the UAS during daylight hours in VFR conditions. Because of 

technical limitations, most UASs limit total flight time to approximately 30 minutes before the battery is 

depleted. No meaningful flight time would be possible given the limitations of 14 CFR 91.151 (a) (1) and (b). 

Equivalent level of safety: The UAS flight will be terminated with at least 20% reserve power. This will allow 

the UAS to return to the landing zone with adequate power remaining to conduct a safe and controlled 

landing. Given the UAS’s size, weight, and speed, this limitation provides an equivalent or greater level of 

safety when compared to manned aircraft referenced in this regulation. See granted exemptions 2689F, 

5745, 10673, 10808, 11138, 11136, 11112, 10650, and 10159. 

7
14 CFR 91.203 (a) (b) , Carry civil aircraft certification and registration 

This regulation states: (a) “... no person may operate a civil aircraft unless it has ... an appropriate and current 

airworthiness certificate.” Furthermore: (b) “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.” 

Equivalent level of safety: With regard to 14 CFR 91.203 (a), an equivalent level of safety is achieved 

through the methods and characteristics outlined in the request for exemption from 14 CFR Part 21, Subpart 

H. 

With regard to 14 CFR 91.203 (b), the UAS does not carry pilots or passengers, does not have storage to 

carry certification and registration documents, and does not have a cabin or cockpit entrance. An equivalent 

level of safety is achieved by maintaining the proper documentation at the Ground Control Station. This 

documentation is readily available to the operator. See granted exemptions 9565A, 9565B, 9789, 9789A, 

9797, 9797A, 9816A and 9816. 

The FAA, in accordance with the FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight 

manual, registration certificate and other documentation will be kept at the control station with the operator 

during flight. The Chief Counsel’s Office has held that for UAS operations, this alternative method 

constitutes full compliance with the regulations. See granted exemption 11062. 

14 CFR 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a) (b) , Maintenance inspections 

Regulations 14 CFR 91.405 (a), 91.407 (a)(1), 91.409 (a)(2) and 91.417 (a) (b) specify maintenance and 

inspection standards in reference to 14 CFR Part 43. Part 91.405 (a) requires that each owner or operator of 

an aircraft “...shall have the aircraft inspected as prescribed in Subpart E of this chapter and shall between 

required inspection...have discrepancies repaired as prescribed in Part 43 of this chapter.” 

An exemption is requested from these regulations because Part 43 and these sections apply only to aircraft 

with an airworthiness certificate. The UASs will not have this certificate. 

Equivalent level of safety: The UASs will be maintained and inspected in accordance with the manual 

supplied by the manufacturer. This includes but is not limited to maintenance, overhaul, replacement and 

inspection requirements for the UAS. Prior to the first flight of the day, the operator will carry out preflight 

inspections to ensure the UAS is in proper condition for safe operation. Any discrepancies that may affect 

the safety of operations will be addressed and repaired before the commencement of any flight. Given the 

size, operating limitations, and characteristics of the UAS described, this provides a level of safety equivalent 

to or greater than traditional manned aircraft used for similar operations. 

8
Statutory Authority for Requested Exemptions 

This petition is submitted in accordance with Section 333 of the Reform Act. Pursuant to Section 333 of the 

Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it does not 

create a hazard to users of the National Airspace System or the public, and does not pose a threat to national 

security based on the following considerations: 

1) The size, weight, speed, and operational capability; 

2) Operation in proximity to airports and populated areas; 

3) Operation within visual line of sight of the operator. 

The Federal Aviation Act grants the FAA Administrator authority to grant exemptions from the agency’s 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public’s best interest. See 49 U.S.C 106 (f), 44701-44716. The party requesting the exemption must explain 

the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect 

safety or how it would provide a level of safety at least equal to the existing regulations. See 14 CFR 11.81. 

Catalyst Aviation LLC Profile 

Catalyst Aviation LLC operates under a current Part 135 Certificate. All aircraft are maintained to the highest 

standards. The company founder and all current pilots posses commercial airmen certificates with valid 

medicals. All current pilots are also part of our Part 135 Training Program. 

Catalyst Aviation LLC prides itself on providing safe, cost effective solutions for our customers. In order to do 

this, we are constantly innovating and evolving both as individuals and as a company. Much of the work the 

company performs is for the electric utility industry. By taking advantage of cutting edge technology, we 

believe we can perform critical inspections in a safer, more cost effective manner than ever before. This 

results in increased reliability for utility customers and a significant benefit to the general public. By utilizing 

small, unmanned aircraft whenever possible, safety margins increase and noise pollution decreases 

dramatically. 

Catalyst Aviation LLC has always operated traditional aircraft in a safe and efficient manner and this would 

carry over in our UAS program. 

Proposed Operations 

Catalyst Aviation LLC is requesting exemptions from the Federal Aviation Regulations stated in this petition 

pursuant to Section 333 of the Reform Act in order to perform power line and utility monitoring inspections of 

critical infrastructure and components. 

Inspections of electric utility components are currently performed using four traditional methods: (1) by 

manned aircraft (usually helicopter), (2) by motor vehicle, (3) by foot, or (4) utility worker climbing the utility 

structures. In many cases, these methods can be replaced or supplemented by using UAS to perform the 

inspection. The UAS can often provide better results, increased employee/public safety, and decreased 

costs when compared to current methods. 

9
Catalyst Aviation LLC will operate their UASs with high resolution, gimbal mounted cameras. Photos and/or 

video will be acquired of the structures to be inspected. Areas of a structure that were previously hard to 

inspect using traditional methods will now be accessible. This improves upon current inspection methods 

resulting in reliable power distribution, fewer outages, and potentially lower costs for power consumers. 

The ability to inspect the power system using UAS will increase employee safety, increase public safety , 

decrease inspection costs and many improve natural disaster response time. In addition, environmental 

benefits exist due to the fact that generally UAS do not release emissions. 

Proposed Operational Environments 

Catalyst Aviation LLC will operate its UAS n support of utility inspections. Most utilities utilize a helicopter to 

perform required inspections. The helicopter is often required to operate in the wire environment at low 

altitudes in order to place a utility worker in position to see various components. The helicopter is often 

operated for long periods of time in less than optimal conditions for safety such as in areas in which an 

autorotation may be difficult or impossible in the event of an engine failure. This can potentially place the 

aircraft, occupants and public in harms way. 

Catalyst Aviation LLC plans to initially operate the following UAS models: 

1) DJI Phantom 3 Professional; 

2) DJI Inspire 1; 

3) DJI S1000 + 

Performing inspections with the UAS would eliminate these hazards. Since no persons are carried on board, 

crew safety increases. Because of it’s small size, hazards to the public are reduced or eliminated. The risk of 

fire due to carrying flammable fluids is also eliminated. All of this while also helping the environment. 

The UAS will be controlled by radio transmission from a Ground Control Station. All remote control 

equipment will consist of industry standard devices available to both professionals and consumers and will 

utilize FCC approved transmission and reception components. 

The UAS will be operated in the immediate area surrounding a utility structure such as a tower or pole. These 

structures are typically contained within a “right of way” (property) owned by the utility company. At no time 

will operations be conducted over non-participating persons. The flight area will constantly be monitored by 

both the operator and visual observer. Permission from the controlling utility company will be obtained prior 

to conducting any commercial flight operations within the right of way or in the vicinity of the structure. 

The operator and visual observer will remain in voice contact at all times during flight via either direct 

contact, radio or equivalent methods, depending on the optimal observer position as determined by the 

operator and observer. The observer will assist the operator in identifying both air and ground hazards. If 

such a hazard is observed, the flight will be altered or terminated immediately. Operation will resume once it 

is established that no hazards exist. 

10
Predetermined potential landing zones will be identified and briefed by the operator, observer, and 

participating persons prior to flight. Landing zones will be selected according to proximity to obstructions, 

observed ground conditions and limited exposure to persons and property. 

Operating Conditions and Limitations 

All operations will be conducted according to and in compliance with the following conditions and 

limitations: 

(A) All UASs utilized will weigh less than 55 lbs. (25 kg).

(B) The aircraft will remain within visual line-of-sight (“VLOS”) of the operator and / or visual observer(s) at all 

times using vision unaided by any device with the exception of corrective lenses.

(C) A visual observer (“VO”) may be utilized to satisfy the VLOS and observation requirements as defined 

herein.

(D) The aircraft will not operate over non-participating persons.

(E) Flight operations will be conducted only between the period of official sunrise and sunset as defined in 

the Aeronautical Information Manual (AIM).

(F) The UAS will yield right-of-way to other aircraft, manned or unmanned. If there is a risk of a collision, the 

operator will immediately maneuver away.

(G) Prior to flight, the UAS operator will assess weather conditions using FAA approved weather sources and 

direct weather observation, will check airspace restrictions and TFRs and will assess the location of people 

and property to lessen risks if he or she loses control of the UAS.

(H) Flight operations will be conducted only with flight visibilities at or exceeding 3 statute miles.

(I) The UAS will not be operated in airport flight paths, restricted airspace, or areas under current Temporary 

Flight Restrictions (TFRs).

(J) The operator will discontinue the flight when continuing would pose a hazard to other aircraft, people or 

property.

(K) The UAS will not exceed an airspeed of 87 knots (100 mph).

(L) The UAS will not be operated at an altitude exceeding 500 feet above ground level (“AGL”).

(M) Operations will not be conducted in Class A airspace.

11
(N) ATC permission will be obtained prior to operations in Class B, Class C, Class D or Class E airspace.

(O) A thorough preflight of the UAS will be conducted by the designated operator in command (“OIC”) prior 

to the first flight of the day or after any suspected or observed anomalies or damage.

(P) The OIC will follow the suggested preflight actions as outlined in the sUAS operator’s manual or, if 

available, Catalyst Aviation LLC’s UAS operation guidelines.

(Q) The operator will not operate a UAS should he or she know or has any reason to know of any physical or 

mental condition that would interfere with their safe operation of the aircraft.

(R) The UAS will not be operated in a careless or reckless manner.

Operator Requirements and Certification 

All Catalyst Aviation LLC operators will abide by the following conditions and requirements: 

(A) All operators will hold a current and valid Private, Commercial or ATP pilot certificate with ratings for one 

or more of the following categories: single-engine land airplane, multi-engine land airplane or rotorcraft 

helicopter. This requirement may be alternatively satisfied when / if FAA UAS operator testing, certification 

and currency requirements are approved.

(B) All operators will be 18 years of age or older.

(C) Operators or a designated Catalyst Aviation LLC official will make available to the FAA, upon request, the 

UAS for inspection or testing.

(D) Operators or a designated Catalyst Aviation LLC official will maintain a log of flights as practicable for 

future currency or flight logging requirements.

(E) An operator or a designated Catalyst Aviation LLC official will report an accident to the FAA within 10 days 

of any operation that results in damage to property, other than the aircraft, estimated to exceed $25,000 for 

repair (including materials and labor) or fair market value in the event of total loss, whichever is less and / or 

results in significant injury or death.

UAS Registration, Markings and Requirements 

All Catalyst Aviation LLC UAS will be registered and marked according to the following conditions and 

requirements: 

(A) All UAS to be operated by Catalyst Aviation LLC will be maintained in condition for safe operation.

(B) The UAS will be inspected prior to flight by the OIC to ensure that it is in a condition for safe operation.

12
(C) All UAS to be operated by Catalyst Aviation LLC for commercial operations will be registered with the 

FAA.

(D) All UAS to be operated by Catalyst Aviation LLC for commercial operations will be marked with an aircraft 

registration number according to 14 C.F.R. Part 45 or in the largest practicable manner taking into account 

the size and configuration of the aircraft.

Public Benefit and Interest 

Currently, aerial power line inspections are performed via helicopter or fixed-wing aircraft. The aircraft are 

typically flown at low altitude and in relative close proximity to the power line, structures or components. The 

use of aUAS rather than a manned aircraft in such applications will further the public interest in several areas 

including but not limited to the following:

• The UAS carries no passengers, pilot or crew, thereby increasing pilot, passenger and worker safety.

• The UAS can often eliminate the need for a worker to climb a tower or pole in order to inspect components 

thereby increasing worker safety.

• The UAS carries no flammable fuel thereby increasing safety to the general public.

• The UAS has a lower noise signature than a typical helicopter thereby improving public welfare.

• The UAS has no emissions thereby reducing the environment impact over traditional manned aircraft.

• The UAS is less expensive to operate than a traditional manned aircraft thereby decreasing the cost of 

power line inspection. This allows utility companies to inspect their infrastructure more frequently, more 

thoroughly and at a potential discount thereby increase public welfare. 

• The UAS is less expensive to acquire than a manned aircraft thereby allowing for more inspection crews to 

operate concurrently. This can result in better-maintained infrastructure and more reliable power distribution 

for the public.

• The UAS may respond to natural disasters and storm-related damage quicker than mannedaircraft. This 

results in faster power restoration and lower outage time for the public.

13