From: 

Norman Melendres 

11090 SE 201 st St. 

Kent, WA 98031 

September 1, 2015 

Attn: 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

To whom it may concern: 

SKP Lab respectfully requests an exemption from several provisions of Title 14 of the Code of 

Federal Regulations (CFR) to permit the use of small unmanned aerial systems (UAS) to assist in 

Surveillance, Agricultural Crop Surveys, Property Inspections, Real-estate marketing, special event 

coverage, Emergency and Rescue, Disaster Relief, Site Inspection, Electric Transmission & 

Distribution Line Inspection, Highway Monitoring, Environmental Compliance, and private UAS pilot 

training. 

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

the FAA Modernization and Reform Act of 2012 (Modernization Act), that safe systems be permitted 

in the national airspace prior to the issuance of final regulations governing general use of these 

systems. A summary of this request suitable for publication in the Federal Register is provided as 

Appendix A. 

Appendix B provides the SKP Lab Operations Manual for flights covered under this Exemption 

Request. 

Initially SKP Lab will be operating a 3DR- SOLO UAS. The manual presents information 

regarding the design, aircraft Performance, and fail-safe features. The latest version of the User 

Manual can be downloaded from the manufacturer's website. 

Initially SKP Lab will be operating a Tarot- 680P UAS. The manual presents information 

regarding the design, aircraft Performance, and fail-safe features. The latest version of the User 

Manual can be downloaded from the manufacturer's website. 

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Background Information 

SKP Lab is in the business of areal videography, and surveying using UAS. Our operations include 

inspections for agriculture and construction companies, sight surveillance, real-estate, and other 

similar activities. We have developed specific SKP Lab Operational Procedures to insure the safety of 

all people, property, and the National Airspace System (NAS). As part of this SKP Lab is requesting 

FAA Exemption for UAS operations for safety, inspection and video capture usage. 

Regulatory Basis for Exemption Request 

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant an 

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

interest. The FAA has imposed a separate requirement in its procedural regulations, providing that 

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

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

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

enhancing the safety and efficiency of infrastructure operations and by providing the FAA with 

valuable user experience on UAS in a context with appreciable economic and societal benefits. As 

described more fully below, the requested exemption would permit the operation of UAS under tightly 

controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the 

contrary, as explained below, SKP Lab operations will serve to conduct activities that are time 

consuming, technically difficult, and potentially hazardous for non-UAS systems. Thus, the use of 

UAS has the potential to improve efficiency, resulting in faster, safer, and more efficient operations. 

Granting an Exemption will not Adversely Affect Safety 

SKP Lab notes that there is no applicable standard for an equivalency determination. It is clear that 

equivalency cannot be established for traditional, manned civil aircraft because the design and use 

profiles between traditional aircraft and UAS are simply too different. As such, we believe it makes 

more sense to focus on why the contemplated operations would not adversely affect safety, which is 

required by §11.81 (e). 

Operations by SKP Lab will be conducted UAS operations over client owned or controlled land, at 

altitudes well below that which would pose a risk to the NAS. In addition SKP Lab will be operating 

UAS at relatively low speeds. Accordingly, the risk of interference with another aircraft is minimal. 

SKP Lab also plans to conduct UAS operations at least five (5) miles from any airports (including 

heliports). In the event an operation needs to be conducted closer to an airport, SKP Lab will contact 

the airport operator and airport air traffic control tower of the contemplated operation and will comply 

with all directions issued by air traffic control at that airport. Two way radio communication will be 

maintained during the operation at such locations between the UAS operator and Air Traffic Control 

(Or CTAF as applicable). 

Due to the small size (Under 551bs) and lack of combustible fuel the UAS poses little risk to 

structures, and equipment in the event of an accident. Additionally the UAS will carry no passengers 

or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including 333 Aircraft Exemption Status exempting the applicant from conventional aircraft 

requirements and allowing commercial operations. These lightweight aircraft operate at slow speeds, 

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close to the ground, and in a controlled environment and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and people. 

The safety of those on the ground is protected by the fact that no one will be allowed into the area 

without the permission of the UAS operator. Security will be established for the flight area as part of 

the pre-flight inspection. Each individual within the secure area will be briefed prior to flight and will 

consent to being in the area. All others will be excluded from the area. 

SKP Lab will use a dedicated staff for UAS operations, each operator will hold holds an FAA Airman 

Certificate and at least a 3rd class medical. All operations will be within visual line-of-sight. Each PIC 

will conduct at least three take-offs and landings with the UAS on which he or she is trained every 90 

days. PIC's will establish their qualifications thru a combination of aeronautical knowledge, UAS 

airmanship skills, and verification through testing of flight ability before operations have commenced. 

Depending on the type of operation, additional ground-based visual observers may be employed as 

well. These observers will be within constant visual line of sight and in constant contact with the PIC. 

The visual observers will assist the PIC in avoiding objects near the UAS. 

Minimum requirements for the PIC include: 

1) Airline transport, commercial, private, recreational, or sport pilot FAA airman certificate 

and a Class Ill medical certificate; 

2) A minimum of 20 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at 

least 10 hours logged as a UAS pilot with a similar UAS; 

3) A minimum of 5 hours as UAS pilot with the make and model of UAS to be utilized for 

operations under the exemption and 3 take offs and landings in the preceding 90 days; 

4) Have undergone a qualification process as specified in the Flight Operations & 

Procedures 

Notes Regarding: 14 C.F.R. Part 21, Subpart H 

In accordance with the statutory Criteria provided In Section 333 of PL 112---95 In reference To 49 

USC 44704, And in consideration of the size, weight, speed, and limited operating area associated 

with the aircraft and its operation, we request that this aircraft exemption meets the Conditions of 

Section 333. Therefore, if granted Section 333 Relief of 14 CFR Part 21, and any associated noise 

certification and testing requirements of part 36, is not necessary. 

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Given the size of the UAS, two-inch lettering will be impossible. The UAS will be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N---Number) 

markings in accordance with 14 CFR part 45, Subpart C. 

Markings will be as large as practical. 

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness 

SKP Lab request is based on the fact that no airworthiness certificate will be issued for the UAS. SKP 

Lab's UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H. 

Based on the fact that an airworthiness certificate will not be issued, exemption from§ 91.7(a) is not 

necessary. 

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Notes Regarding: 14 CFR § 91.9Cb)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations was to display an aircraft's 

airworthiness, certification, and registration documents so they would be easily available to inspectors 

and passengers. Based on the FAA Memorandum subject "Interpretation regarding whether certain 

required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014, the 

requested relief from 14 CFR §§ 91.9(b)(2) and 91.203(a) and (b) is not necessary. 

Notes Regarding: §91.1 09 Flight instruction; Simulated instrument & certain flight tests 

Small UASs, by their design, do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. 

Aircraft being considered for use by SKP Lab allow the UAS Instructor to place the aircraft into 'loiter' 

mode (fixed altitude stationary hold). In the event of the student losing control, the UAS Instructor can 

quickly and via alternate equipment (equipment not in the hands of the student) place the aircraft into 

a mode that then allows the instructor to bring the aircraft back into control and back to the 

predetermined and/or safe landing location. SKP Lab does not describe training scenarios in which a 

dual set of controls would be utilized or required, i.e. dual flight instruction, provided by a flight 

instructor or other company-designated individual, which would require that individual to have fully 

functioning dual controls. Rather, SKP Lab evaluates the qualification of its PIGs based on their 

experience with the UAS to be operated and verifies through testing, in lieu of formalized training. As 

such, SKP Lab does not seek relief from 14 CFR § 91.109. 

Notes Regarding§ 14 CFR 91.119(b) 

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, because the SKP 

Lab's operations will only be conducted within the secured area described herein. 

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Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C. F. R. § 11 .81 , SKP Lab provides the following 

information: 

Contact Information: 

Norman Melendres 

CEO/President, SKP Lab 

11090 SE 201 St 

Kent, WA, 98031 

(425) 943-1693 

skplab@ outlook. com 

William Grace 

FAA Consultant, SKP Lab 

315 3rd St 

GoldBar, WA, 98251 

(616) 634-5180 

G racefuiWingsAviation@ gmail.com 

Regulatory Provisions from which SKP Lab seeks an Exemption 

SKP Lab believes it may need an exemption from the following provisions to conduct the 

contemplated operations. In some instances, relief is needed because relief from another provision 

renders compliance with the regulation at hand infeasible. 

• 333 Aircraft Exemption Status 

• 14 CFR §61.113(a) and (b) 

• 14 CFR §91.119(c) 

• 14 CFR §91 .121 

• 14 CFR §91.151 

• 14 CFR §91.405(a) 

• 14 CFR §91.407(a) 

• 14 CFR §91.409(a)(1 )&(2) 

• 14 CFR §91.417(a)&(b) 

SKP Lab believes an exemption is only needed from the above-listed regulatory provisions. To the 

extent that the FAA believes that additional relief is required for SKP Lab to conduct the operations 

described here, we request an exemption from any such regulatory provisions as well. 

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The Extent of Requested Relief and the Reasons Relief is Needed 

14 C.F.R. §61.113(a) and (b) 

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

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

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an 

aircraft. (b) A private pilot may, for compensation or hire, 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; and (2) The aircraft does not carry passengers or property for compensation or hire. 

SKP Lab anticipates initially using a cadre of specially trained staff to conduct the UAS operations. 

While these individuals will not hold commercial pilot licenses. The UAS will not carry property for 

compensation or hire since they will be used solely to assist in evaluation of the infrastructure, 

equipment, right-of-way, assets, bridges, tunnels and out-buildings in furtherance of SKP Lab's 

client's primary business, the successful operation of a infrastructure; however, the employees' 

operation of the UAS will not be incidental to their employment with SKP Lab, and they will be 

compensated for such work. Without an exemption, the pilot would be required to hold a commercial 

pilot certificate under §61.133. However, the risk associated with the contemplated operations is less 

than the risk posed by a traditional aircraft. The UAS will fly at altitudes well below the permissible 

limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope 

under the sole control of SKP Lab clients. Accordingly, the risk would be limited to SKP Lab 

personnel, who will be appropriately outfitted in safety gear, and SKP Lab client's property on the 

ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and 

would needlessly impose additional cost on SKP Lab. Because the contemplated operations would 

not comply with §61.113(b)(1) and none of the other exceptions to paragraph (a) apply, relief is 

needed from both paragraphs (a) and (b). 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General. 

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

altitudes: 

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

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure. 

SKP Lab submits that the only relief it requires from §91.119 is from the minimum altitudes listed in 

paragraph (c). Relief is required from paragraph (c) for fixed wing operations because asset 

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

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

assured through the grant of an exemption. The anticipated rotorcraft operations should be 

adequately addressed by paragraph (d) (1 ). Additionally, relief should not be needed from paragraph 

(a) because an emergency landing of the aircraft due to a power failure will not create an undue 

hazard to persons or property on the surface. As noted in the explanation of why an exemption will 

not adversely affect safety, SKP Lab clients has exclusive use of the land over which the UAS will be 

operated, and public access is restricted. It also has exclusive use of significant portions of land 

adjacent to the infrastructure and structures that will be the objects of evaluation and analysis. SKP 

Lab's Clients tightly control access to land and have the ability to assure that no individuals 

unassociated with the planned operations are on the affected land. As such, the risk of injury is 

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minimal. SKP Lab does not contemplate conducting operations over congested areas, so relief is not 

requested from paragraph (b). 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." 

As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption 

may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. Altitude information will be provided to the UAS pilot via a digitally encoded 

telemetric data feed, which downlinks from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed on board the aircraft, using GPS 

triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. 

Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by 

the pilot. 

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes. 

(b) 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. 

Operating the UAS in a pre-defined area with less than 30 minutes of reserve fuel does not raise the 

type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it has to be 

flown to an alternate airport or circle the planned airport in the event of unanticipated conditions. SKP 

Lab does not intend to use the UAS for point-to-point flights and will not operate the UAS beyond 

visual line of sight. Nor will the UAS require an airport in order to land. Rather, SKP Lab will operate 

the UAS using pre-planned flight paths (taking into account weather conditions) designed to allow the 

UAS to fly to the point of intended landing. As such, there is no need for a time-based excess fuel 

requirement. Rather it should be sufficient to require only as much additional excess flight capacity as 

necessary to safely land the UAS. We believe that a 25% battery reserve is more than sufficient to 

meet this objective. 

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

§91.405 Maintenance required. 

Each owner or operator of an aircraft- (a) Shall have that aircraft inspected as prescribed in subpart 

E of this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter; 

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

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

unless- (1) It has been approved for return to service by a person authorized under 

§43. 7 of this chapter; 

§91.409 Inspections. 

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

within the preceding 12 calendar months, it has had - (1) An annual inspection in accordance with 

part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 

of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. 

§91.417 {a) & {b) 

SKP Lab believes that an exemption from these three maintenance requirements is appropriate 

because the FAA has not developed maintenance standards that would allow an operator to meet the 

part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to 

approve a UAS for return to service under §91.407(a) or to conduct the initial airworthiness and 

annual return to service inspections required by §91.409(a). SKP Lab will maintain the aircraft as 

instructed in the owner's manual and ASTM F2909, where applicable, and will not operate the aircraft 

until it has reasonably determined that any needed repairs have been made. However, because of 

the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a)&(b), 

we believe an exemption from these provisions is appropriate. 

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

should you have any questions or concerns. 

ubmitted, 

N.6rma elendres 

CEO/Pre ident, SKP Lab 

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Appendix A - A for Federal Register 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register should the FAA determine that publication is needed. 

Petitioner: Drone Fleet & Aerospace Management, Inc. (SKP Lab) 

Sections of 14 C.F.R. Affected: 

• 333 Aircraft Exemption Status 

• 14 C.F.R. §61.113(a) and (b) 

• 14C.F.R.§91.119(c) 

• 14C.F.R.§91.121 

• 14C.F.R.§91.151 

• 14 C.F.R. §91.405(a) 

• 14 C.F.R. §91.407(a) 

• 14 C.F.R. §91.409(a) 

• 14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 

C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and 

91.417(a)&(b) to conduct UAS operations over SKP Lab Client's owned or controlled land, to assist in 

the safe evaluation and analysis of infrastructure and operations. In general, UAS operations are 

intended to be conducted in areas remote from both congested areas and airports. The nature of 

operations anticipated by SKP Lab requires that the UAS be flown at relatively low altitudes. SKP Lab 

expects that in most instances, the UAS will be flown less than 75 feet from the highest structure 

along the path of the UAS and in no instances will be flown higher than 400 feet above the ground. 

Accordingly, the risk of interference with other aircraft is minimal. 

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Appendix 8- Operating Procedures 

The following is SKP Labs operating instructions and procedures: 

Technology Considerations: 

Best-in-class, tried and proven technologies that are in advanced iterations. Software from highlyreputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the UAS loses 

communications, the UAS will have capability to return to a pre-determined location within the 

Security Perimeter and land. 

2. Auto descent (landing) if battery were to drop lower than nominal level. 

3. Flights will be terminated at 25% battery power reserve. 

4. Live video for operator gives real-time positioning feedback. In other words, we can monitor 

the scene from the vehicle's perspective for collision avoidance, and to maintain spatial 

orientation. 

5. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle health at all 

times: speed, altitude, number of GPS satellites (when available), heading and voltage. 

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) link failures 

occur (highly improbable), vehicle returns automatically to the point of launch. 

8. Altitude information will be provided to the UAS pilot via a digitally encoded telemetric data 

feed, which downlinks from the aircraft to a ground-based on-screen display. This altitude 

information will be generated by equipment installed on board the aircraft, using GPS 

triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination 

thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for 

accuracy by the pilot. 

Mechanical/Physical: 

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS to the pilot, 

thus eliminating the concern of signal severance (flying behind objects/walls). 

2. The UAS will weigh less than 55 lbs. and travel at less than 50 knots. 

3. Batteries should far exceed the capacity required for actual flight time. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

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5. UAS operated under this Exemption will be marked in accordance with 14 CFR part 45, or as 

otherwise authorized by the FAA. 

Personnel: 

1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal 

operator, director) 

2. A briefing will be conducted in regard to the planned UAS operations prior to each day's 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

3. The operator will obtain the consent of all persons involved in the UAS operations and ensure 

that only consenting persons will be allowed within 100 feet of the flight operations. 

4. Observer and pilot will at all times be able to communicate by voice. 

5. Written and/or oral permission from the relevant property holders will be obtained. 

6. Pilot and observer will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated. 

7. Additional precautions will be applied during UAS operations as being prudent to put 

operational signs to properly control and secure operations perimeter, informing close by 

residents, emergency and response crews, police/paramedics, et. al, who are in proximity 

during operation. 

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Operations: 

1. The UAS must weigh less than 55 pounds, including energy source(s) and equipment. 

Operations authorized by this petition of exemption are limited to the following aircraft 

described in Appendix B. Proposed operations of any other aircraft will require a new petition 

or a petition amendment to this request. 

2. The UAS may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operator's manual. All altitudes reported to ATC 

must be in feet AGL. 

4. The UAS 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 medical certificate. 

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times. 

The operator may update or revise its operator's manual. It is the operator's responsibility to 

track such revisions and present updated and revised documents to the Administrator upon 

request. The operator must also present updated and revised documents if it petitions for 

extension or amendment. If the operator determines that any update or revision would affect 

the basis for which the FAA grants this petition for exemption, then the operator must petition 

for amendment to their exemption. The FAA's UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operator's manual. 

6. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight in accordance with the operator's manual. The PIC who conducts the functional test flight 

must make an entry in the UAS aircraft records of the flight. The requirements and procedures 

for a functional test flight and aircraft record entry must be added to the operator's manual. 

8. Aircraft maintenance/component/overhaul, replacement, and inspection/maintenance 

requirements must be in accordance with the manufacturers manual: 

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a. Actuators I Servos; 

b. Transmission (single rotor); 

c. Motors; 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 
h. Remote command and control; 

i. Ground control station (if used); and 

j. Any other components as determined by the operator; 

9. The Pilot In Command (PIC) must possess at least an airline transport, commercial, private, 

recreational, or sport pilot FAA airman certificate and at least a current third-class medical 

certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate. 

1 0. Prior to operations conducted, the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of 20 flight cycles and 25 hours of total time as 

a UAS rotorcraft pilot and at least 1 0 hours logged as a UAS pilot with a similar UAS type 

(single blade or multi rotor). Prior documented flight experience that was obtained in 

compliance with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this petition of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119 

11. Prior to operations, the PIC must have accumulated and logged, in a manner consistent with 

14 CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of 

UAS to be utilized for operations under the exemption and three take-offs and three landings in 

the preceding 90 days. Training, proficiency, experience building, and take-off and landing 

currency flights can be conducted under this petition of exemption to accomplish the required 

flight time and 90 day currency. During training, proficiency, experience-building, and take-off 

and landing currency flights all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UAS with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

12. Prior to any flight operations authorized by this petition of exemption, the PIC and VO must 

have successfully completed a qualification process. As this is a requirement stipulated by the 

operator, the test must be developed and implemented by a qualified person designated at the 

sole discretion of the operator. A record of completion of this qualification process must be 

documented and made available to the Administrator upon request. 

13. Prior to operations, a flight demonstration, administered by an operator-approved and -

qualified pilot must be successfully completed and documented. This documentation must be 

available for review upon request by the Administrator. Because the knowledge and 

airmanship test qualifications have been developed by the operator, and there are no 

established practical test standards that support a jurisdictional FAA FSDO evaluation and 

approval of company designated examiners. 

14. The UAS may not be operated directly over any person, except authorized and consenting 

personnel, below an altitude that is hazardous to persons or property on the surface in the 

event of a UAS failure or emergency. 

15. Regarding the distance from participating persons, the operator's manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be 

essential to the operations. 

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16. Regarding distance from nonparticipating persons, the operator must ensure that no persons 

are allowed within 500 feet of the area except those consenting to be involved and necessary 

for the infrastructure inspection operations. This provision may be reduced to no less than 200 

feet if it would not adversely affect safety and the Administrator has approved it. For example, 

an equivalent level of safety may be determined by an aviation safety inspector's evaluation of 

the infrastructure inspection area to note terrain features, obstructions, buildings, safety 

barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news 

media, etc.) from debris in the event of an accident. 

17.1f the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered. 

18. The UAS must abort the flight in the event of unpredicted obstacles or emergencies. 

19. Each UAS operation must be completed with 15% battery power remaining. 

20. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practical. 

21. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. 

22. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

23. The preflight inspection must account for all discrepancies, i.e. inoperable components, items, 

or equipment, not covered in the relevant preflight inspection sections of the manufacturer's 

manual. 

24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request. 

25. The UAS must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.). 

26. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

27. The UAS may 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. 

28. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. 

The UAS may not operate within 5 nautical miles of the geographic center of an airport as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

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airport's management is obtained, and the operation is conducted in accordance with a 

NOT AM as required by the operator's COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

29. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

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