July 15, 2015

Exemption No. 12057

Regulatory Docket No. FAA–2015-1564

Mr. Ryan Nolin

439 Lancelot Lane

Lexington, KY 40517

Dear Mr. Nolin:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 25, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct precision imaging for agricultural, forestry, wildlife management and survey 

industries.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is an Event 38 E384.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 
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meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Ryan P. Nolin is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Ryan P. Nolin is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Event 38 E384 

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
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documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. 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.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. 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.

15. 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.

16. The UA may not operate within 5 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 the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. 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 practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
April 25, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Regarding Exemption Request of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Attachments: A) E384 Maintenance Manual

 B) E384 Operations Manual

 C) E384 Training Syllabus

Dear Sir or Madam:

Ryan Nolin, an unmanned aircraft systems (UAS) consultant, and UAS operator, is 

requesting an exemption from the Federal Aviation Regulations listed below pursuant to 

section 333 of the FAA Modernization and Reform Act of 2012. 

The granted exemptions would allow Ryan Nolin to safely and properly operate small 

Unmanned Aircraft Systems (sUAS) for the commercial purpose of precision imaging for 

agricultural, forestry, wildlife management and survey industries. By following the 

procedures outlined in this document and attached appendices or established by the 

FAA, Ryan Nolin believes an equivalent level of safety can be achieved to current Federal 

Aviation Regulations (FARs).

Because the sUAS Ryan Nolin plans to operate (Event 38 E384) weighs less than 10lbs, is 

made of foam, and is electric powered, operations produce less noise, less air pollution 

and congestion in the National Airspace (NAS). These reasons are all in the well being of 

the general public.

Being a sUAS also has the added benefit of reducing risks to personnel and property in 

the air and on the ground. Because flight operations will require consent from 

landowners, operate below 500 feet and operate in a similar fashion to current manned 

aircraft no new privacy issues will arise.

The requested exemption is in the public interest of our nation. By granting this 

exemption Ryan Nolin, the public and surrounding communities will all benefit from 

added economic, environmental and positive sUAS outlook impacts.

Ryan Nolin

439 Lancelot Lane

Lexington, KY 40517

Phone: 802-318-3456

Email: ryan@skyviewcustoms.com
The Specific sections of 14 CFR from which Ryan Nolin seeks exemption:

14 C.F.R Part 21 Subpart H

14 C.F.R 61.113 (a)&(b)

14 C.F.R 91.7 (a)

14 C.F.R 91.151

14 C.F.R 91.405 (a)

14 C.F.R. 91.407 (a)(1)

14 C.F.R. 91.409 (a)(1) & (a)(2)

14 C.F.R 91.417 (a) (b)

Appendix A discusses why each C.F.R is appropriate for exemption, how an equivalent 

level of safety is achieved and how it is in the public’s interest.

Characteristics of the Aircraft: 

Ryan Nolin will operate the E384 fixed wing sUAS, which is manufactured by Event38 of 

Akron, Ohio. The principle construction material for the E384 airframe is EPO foam, 

carbon fiber tail boom with an all up weight (AUW) no greater than 10lbs. The E384 is 

powered by a single lithium polymer battery that drives a single brushless motor. The 

E384 has a maximum flight time of 100 minutes with operating speed of 27 mph. The 

pilot in command (PIC) will communicate with the E384 with a 2.4 ghz remote control 

radio and a 915mhz data telemetry radio connected to a ground control (GC) computer. 

The E384 aircraft has several failsafe systems in place:

 In the event of the loss of remote control (unlikely due to visual line of sight 

(VLOS) operations under 400ft) the E384 will perform a “return to home” 

command.

 In the event of the loss of ground control connection (unlikely due to VLOS 

operations under 400ft) the E384 will perform “return to home” command.

 In the event of a low battery (less than 20%) the E384 will perform a “return to 

home” command.

In addition to the above failsafes, a gps guided “Geofence” will prevent the E384 from 

flying beyond its intended flight path.

Ryan Nolin holds an Airframe and Powerplant certificate (#3474636) and will thus 

perform all E384 maintenance. Maintenance procedures will be followed in accordance 

with Event38 maintenance manuals (attachment A). All maintenance procedures will be 

logged.

Similar aircraft is already approved for operation. See exemption #11166
Proposed procedural and operational standards

Pilot In Command (PIC) and Visual Observer

 As PIC, Ryan Nolin will have at minimum a Sport Pilot’s license.

 A visual observer (VO) will maintain contact with the PIC and be used to ensure 

the E384 remains in VLOS and will fully understand all operating limitations set 

forth in this petition.

 Flights will be conducted during day-light hours and under Visual Flight Rules 

(VFR).

 Flights will be conducted within VLOS of the PIC and VO.

 As PIC, Ryan Nolin will complete Event 38 training for the E384 aircraft in 

accordance with the Event38 training syllabus (attachment C). 

 As PIC, Ryan Nolin will be responsible for all aircraft and preflight inspections.

Flight Operational Limits

 All required permissions/permits from governmental agencies will be obtained 

prior to each flight.

 Permission from relevant property owners will be obtained prior to each 

operation.

 Preflight Safety briefings will be conducted before each flight to discuss potential 

safety hazards and operational boundaries.

 Flight plans will not extend past the 100-minute flight limit of the E384 aircraft.

 All flights will be conducted no more than 400 feet above ground level (AGL) and 

5 miles from any airport.

 All flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures.

 Operations over congested areas will be avoided.

 The E384 will take off and land next to the PIC and VO.

 Alternate emergency landing zones will be established during the preflight safety 

briefing.

 The E384 will always give way to manned aircraft.

 A ground control station will always be present in the area of the PIC and VO to 

relay real-time E384 information, such as battery level, altitudes, speeds, 

location and global positioning system (GPS) health.

 Certificates of Approval (COA) will be secured before each flight as required by 

FAA regulations.

 The PIC will abort flights in the event of obstacles or emergencies.

 The E384 aircraft will be registered in accordance with 14CFR Part 47 and have 

identification (N-Number) markings in accordance with 14 CFR part 45, Subpart C. 

Markings will be as large as practical.

 All documents used by the operator to ensure safe operation and flight of the 

E384 will be available to the PIC at the ground control station of the sUAS 

anytime the aircraft is operating. 

Safety in the National Airspace and on the ground is the priority for operations. By 

following the above guidelines, in addition to Event 38 Operations Manual (attachment 

B), Ryan Nolin is confident an equal or greater level of safety to current manned aviation 

is achieved. 

See similar operations that have been granted exemptions: #11062, #11109, #11166, #11213, #11379, 

#11285
Appendix A

Specific Sections of 14 CFR from which Ryan Nolin Seeks Exemption

Below are the sections from which Ryan Nolin seeks exemption, with specifics on the 

extent of relief sought, reason for relief, and why exemption would not adversely affect 

safety. 

Part 21 Subpart H – Airworthiness Certification 

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate. Ryan Nolin seeks complete exemption from Part 21 Subpart H pursuant with 

Section 333, which authorizes the FAA to exempt a UAS from the requirements of an 

airworthiness certificate based on consideration of the following: size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

VLOS.

An equal level of safety will be achieved with the operational limitations established in 

this document (refer to page 3 of the Event38 Operational limitations (attachment B)) 

for all E384 flights conducted by Ryan Nolin. The E384 sUAS operates with an all up 

weight (AUW) of less than 10lbs and maximum airspeed of 30mph. All flights will occur 

within VLOS of the PIC and VO, at an altitude of 400 ft. AGL or less, and only over 

designated areas. Based on the required standards and limitations the E384 can safely 

operate without creating a hazard to any other aircraft, people, or structures on the 

ground. 

Similar aircraft is already approved for operation. See Exemption #11166

61.113 (a) – Private Pilot Privileges and Limitations; Pilot In Command: Commercial 

Pilot Privileges and Limitations

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Due to its size, weight, and operational limitations the E384 sUAS will not carry any 

persons on board. The proposed operations will not adversely affect safety by requiring 

the PIC of aircraft to have a commercial pilot certificate, as long as they

have passed, at minimum, a sport pilots certification. The safe operation of a sUAS 

benefits more from hands on experience and training in comparison to a commercial 

pilot’s license. Ryan Nolin respectfully states that, since there are no standards for 

either private or commercial UAS pilot certificates, knowledge of airspace regulations 

and dexterity in the control and operation of the UAS acquired from actual operation of 

the aircraft will
be the most important factors in establishing an equivalent level of safety. By following 

the Event38 training syllabus (attachment C) with the E384 sUAS the proper knowledge 

of airmanship can be achieved to maintain safe flight operations.

91. 121 – Altimeter Settings 

91.121 requires aircraft to maintain a cruising level or flight level in reference to a 

current reported altimeter setting. The altitude information on E384 is provided to the 

PIC via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a 

radio communication telemetry data link, which downlinks from the E384 sUAS to the 

GCS for active monitoring of the flight path. 

Also since the E384 will be operating at or below 400 ft. AGL, there is no need to 

maintain hemispherical cruising altitudes for de-confliction with manned aircraft. For 

these reasons Ryan Nolin seeks exemption from this regulation. 

During arming sequence the E384 sets a reference AGL altitude at home locations using 

GPS and barometric pressure sensors. An equal level of safety will be achieved through 

the E384’s GPS and flight control, which provides altitude and location data during flight 

to the PIC via the ground control station. The previous safety protocols are outlined in 

the Preflight checklist within the Event 38 Operations Manual. Checking the GPS readout ensures that it’s within tolerance prior to commencing flight operations. This, 

combined with the fact that the aircraft’s altitude will be visually monitored by the PIC 

and Safety Observer, ensures an equal level of safety is achieved without referencing an 

altimeter setting. Furthermore, by operating at or below 400 ft. AGL the E384 sUAS will 

not create a hazard to any manned aircraft.

91.151-Fuel Requirements for Flight in VFR Conditions

91.151 provides that no person may begin a flight in an airplane under day visual flight 

reference (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. Because the E384 sUAS is 

electric-powered, this requirement is inapplicable. Safety features on E384 prevent 

arming and take-off in “Low battery” conditions as well as “return to launch” during 

“low battery” conditions. These features, teamed with the small size and weight of the 

UAV should more than achieve an equivalent level of safety. 

14 CFR Subpart E (91.401 - 91.417): Maintenance, Preventive Maintenance, and

Alterations

91.405 (a)-States that the an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies 

repaired as prescribed in part 43 of the chapter.

91.407 (a) (1)-Specifies that no person may operate any aircraft that has undergone

maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 43.7 of this chapter.

91.409 (a) (1) (2)- Specifies, in pertinent part, that 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 and has been approved for return to

service by a person authorized by Sec. 43.7
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21.

91.417 (a) (b)-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.

Ryan Nolin seeks full exemption from sections (91.405 (a), 91.407 (a), 91.409 (a(1,2)), 

91.417 (a,b) due to the fact that these sections apply to an aircraft with an airworthiness 

certificate for which Ryan Nolin is already seeking exemption. 

An equal level of safety will be achieved by using the E384 Operations Manual 

(Reference Attachment B) and E384 Maintenance Manual (Reference Attachment A) 

which provide instructions for preventive and corrective aircraft maintenance. The PIC 

will be responsible for conducting maintenance in accordance with these procedures. 

Ryan Nolin, with the knowledge learned as a licensed Airframe and Powerplant 

mechanic (License #3474636), will ensure that all preventive and corrective 

maintenance performed on the E384 sUAS will be documented.

Summary for Federal Register

Pursuant with section 333 of the FAA Modernization and Reform Act of 2012, Ryan 

Nolin seeks exemption from the following Federal Aviation Regulations that are found 

under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 61.113 (a)&(b), 

91.151, 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), 91.417 (a)(b). Granted 

exemptions from these regulations would allow Ryan Nolin to safely and properly 

operate the E384 sUAS for the commercial purpose of precision imaging for agricultural, 

forestry, wildlife management and survey industries.

Ryan Nolin is prepared to modify or amend any part of this request to satisfy the need 

for an equivalent level of safety. Ryan Nolin can be contacted at any time (see contact 

information below) if you require additional information or clarification.

Respectfully,

Ryan Nolin

Phone: (802)-318-3456

Email: ryan@skyviewcustoms.com