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August']. 2015 

VIA FAbsiMILE IRANSMISSION 

Docket bperations, M-30 

U.S. I artment of Transportation (001) 

1200 N w Jersey Avenue, SE 

Room 12~140 

West B ilding Ground Floor 

Washin on, DC 20590-0001 

Fax: 20 .493.2251 

Garvey Environmental LLC 

an SBA HUBZone Small Business Concern 

3113 Ocean Gateway, Suite 2 

Cambridge, MD 21613 

Contact: David A. Garvey 

Email: dgarvey@garveyenvironmental.com 

Mobile: 410.443.3233 

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Re: fetition for Exemption Request Pursuant to Section 333 of the Federal Aviation 

Dear 

dministration Reform Act and Title 14, Part 11 of the Federal Aviation Regulations I 

Garvey nvironmental LLC ("Garvey Environmental'" or "Petitioner"), a Maryland limited 

Iiabili company and SBA ffiJBZone Small Business Concern based in Cambridge, Maryland,. 

respec ly submits this petition 1mderthe Federal Aviation Administration ("FAA") Reform 

Act Se ion 333 and Title 14, Part 11 of the Federal Aviation Regulations ('"FAR"') for 

exem n under the following FAR: 14 CFR Part 21 Subpart H; 14 CFR 45.23 (b); 14 CFR 

61.113 'a) & (b);l4 CFR 91.7 (a);;14 CFR 91.9 (b) (2); 14 CFR 91.103(b)(2); 14 CFR 91.105; 

14 CF 91.109; 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151 (a); 14 CFR 91.203 (a) & 

(b); 14 1 FR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (2); and 14 CFR 91.417 (a) & 

(b). I 

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As disc ed in Appendix A hereto. in its proposed commercial operation of Unmanned Aircraft 

System ('~AS")~ Petitioner cannot fully comply with these regulations (or with specific 

portionl~ereof), and therefore respectfully requests the granting of an exemption from each 

such rerr .... ation (or specific portion thereof). 

The fol~wing sets forth Garvey Environmental's proposed commercial operationofUAS. The 

present:j:ltion oftbis information is based on the format provided in "Federal Aviation 

Adm~on Public Guidance for Petitions for Exemption Filed under Section 333, rev. 

9125!2d~4 . ., 

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r.tition ~Gaivov Envi.,.....tal LLC 

Under~1 'on 333 oftheFAARefonn.Act 

and Titl 14, Part 11 ofFAR 

Page 2 o 112 pages 

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1. Pe~~oners should describe how the. proposed UAS operation will be safely conducted to 

miJJi~ risk to the NAS or to persons and property on the grourul. Specifically, petitioners 

sho~"~scrlbe the design and operational characteristics for the type(s) ofUAS they intend to 

operat~,.g. aircraft perform01'lce and performance limitations, operating procedures, and 

aircra~ loading iriformation in as much detail as possible. 

Garveyll nvironmental intends to conduct commercial flight. operations using two Urunanned 

Airc~ ("UA"')~ specifically the Altura Zenith ATX8 and the Dn Inspire 1. These operations 

will b~' onducted in a safe manner that will minimize risk to the National Airspace and to 

perso 1 and property on the ground. In addition, Petitioner will operate the UAs to remain clear 

of and ! ·:ve way to all manned aviation operations and activities at all times. 

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If the UAs lose contact with their controller and does not reacquire the control link data from 

the Gr d Control System (GCS)~ the UA will assmne that the control link is lost and the UA 

will re 1 to the home position (i.e., failsafe mode) via Global Positioning System ("GPS"), and 

will de cend to the takeoff position and shutdown. 

By utiljbg UAS to perfonn aerial acquisitions~ the risks to persons and property both in the air 

and on he ground usually associated with standard manned aircraft flight operations will be 

subs "ally reduced or completely eliminated. In addition to the absence of flight crew 

memb onboard the aircraft. these UAs (weighing approximately 6 pounds 8 ounces and 6 

pounds ounces respectively, at the:ir maximum gross weights with diagonal rotor to rotor 

len~~f26 inches and 22 inches respectively, and with no fuel on board) have less physical 

potenti l for collateral injury or damage to persons or property on the ground and in the air, 

com, to the manned aircraft that typically conduct similar operations. 

The pe 1 ormance, performance limitations, operating procedures, and loading information for the 

two U S that Gatvey Environmental intends to operate are as follows: 

Motors 

SizeD gonal 

Maxim Flight Time 

Max C ise Speed 

Contro er 

Contro er :frequency 

Altura Zenith A1X8 

6 pounds, 8 olUlCes 

8 

26, 

35 minutes 

38 knots 

Controllertrablet 

2.4GHz . 

DHimpire 1 

6 pounds~ 4 otmces 

4 

22" 

18 minutes 

42 knots 

Controller/tablet 

2.4GHz 
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Petition Garvey Envirownental LLC 

Under Se ·on 333 ofthe FAA Reform Act 

and Title ~4, Part 11 of FAR 

Page 3 o 12 pages 

2. Peti ·oners should describe any procedures they would implement, such as pre-flight 

inspectiwns, maintenance, and repair, to ensure that zhe UAS is in a condition for safe flight. 

Prior toEh UAS operation, the PIC will conduct a pre-flight inspection and determine the UAS 

is in a c ndition for safe flight. The pre-flight inspection will account for all potential 

detrime tal conditions, e.g., inoperable components, items, or equipment. If the pre-flight 

inspecti1 n reveals a condition that could be detrimental to the safe operation of the UAS, the PIC 

will not perate the UA until the necessary maintenance has been perfonned and the UAS is 

deemed, by the PIC to be m a condition for safe flight. Garvey Environmental will follow each 

UAS mfufacturer's maintenance> overhaul, replacement> inspection, and life limit requirements 

for the A and UA components, and comply with each manufacturer safety bulletins. 

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3. The j;etitione'f' should describe the Radio Frequency (RF) spectrum med for control of the 

UAS an~ associated equipment that is part of the UAS (i.e., sensors, cameras. etc.), and whether 

it comp~·es with Federal Commwtications Commission (FCC) or other appropriate government 

oversig, t agency requirements . . I . 

The RFI~sed to control both the Altura Zenith ATX8 and the DJI Inspire 1 is 2.4GHz. I, 

RegardJhg the Unmanned Aircraft PIC 

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4. Peti oners should describe the qualifications required of any PIC{s) who will be directly 

respo ble for the operation of the UA.S, including information such as: the level of airman 

certific te held; any applicable training related to the operation; and any minimum hours of 

flight e erience required by the PJC(s) 1 both total flight time and the time with the particular 

UAS. I: the operation would use visual observers, petitioners should describe their roles and 

qualifi tions. 

employed by Garvey Environmental will need to have, at minimum. a private pilot's 

e and training relating to the particular UAS in operation. The PIC will be designated 

ch flight. 

Each V ual Observer CVO") employed by Petitioner will have working knowledge of the UAV 

and its haracteristics. Each VO will be trained to be cognizant of nearby structmes. wildlife, 

and oth potential hazards. Each VO will be of sound mind and body at the time of the flight 

in which the VO is participating, or will be forbidden from participating in such 

s. 

Each P 1 will first demonstrate the ability to safely operate the UAS in a manner consistent with 

how th UAS will be operated under this exemption~ including evasive and emergency 

manemf~rs and maintaining appropriate distances :from persons, vessels, vehicles and structures. 

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Petition Garvey Enviromnentall.LC 

UndEt S ·on333 ofthe FAARefonnAct 

and Title . 4, Part 11 ofFAR 

Page 4 12 pages 

PIC qJification flight hours and currency will be logged in writing. 

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Garvey !Environmental will conduct dedicated training flights for PICs and VOs to establish and 

main · proficiency in operations and to determine the PIC"s continuing ability to safely operate 

the UA . During dedicated training flights. all persons not essential for flight operations will be 

conside nonparticipants, such that the PIC will operate the UA an appropriate distance away 

from n rparticipants. ' ' 

S. PetiJ~oners should describe the medical standards and certification of the PIC(s) directly 

re.qJO~fbl~ for the operaJion of the UAS. !I 

Petitiodtrr's primary PIC. David A. Garvey~ has a current 3Jd class medical certificate issued by 

the F~.. . Mr. Garvey has over 300 hours of flight time as a Private Pilot (certification 

#31468 0). Airplane Single Engine Land Instrument Airplane, with PIC-Complex Airplane and 

PIC-Hi Performance ratings. 

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Regar<lli,Ig the Operation of the Unmanned Aircraft 

6. Pet~~oners should fully describe their intended UAS operation(s). Petitioners should 

describ~ how the proposed operation(s) wOJdd not adversely a.ffe.ct safety, or how they would 

provi~ja level of safety at least equivalent to that provided by the rule from which exemption is 

sought~ letitioners should address any plans to implement clearly defined operational borders 

and pr4 edures to er~sure public safety, which includes persons and property both in the air and 

on the und. 

Garveyl~nvttonmental will only conduct flight operations under Visual Meteorological 

Condit' ns (VMC) only, and will not conduct any flight operations at night or under special 

visual ight rules (SVFR). All flights will be conducted in visual line of sight (''VLOS"). 

I . All fli t operations will be conducted at least 500' from all nonparticipating persons (the PIC(s), 

VO(s). d other personnel deemed essential by Garvey Environmental) are not considered to be 

non cipating persons). vessels, vehicles. and structures, unless barriers or structures are 

present ~hat sufficiently protect nonparticipating persons from the UA and/or debris in the event 

of an ! ident_ The PIC will undertake reasonable efforts to ensure that nonparticipating persons 

remain der such protection. If a situation arises where nonparticipating persons leave such 

protec nand are witlrin 500' of the UA, the PIC will terminate flight operations right away in a 

manne ensuring the safety of nonparticipating persons. 

In addi~ on~ Petitioner may conduct flight operations within 500 of nonparticipating persons, 

vesse~~i vehicles~ and structures if the owner/controller of any vessels, vehicles. or structures has 

grant, permission to the PIC for operating closer to those objects and the PIC has made a safety 

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Petition Garvey Environmental LLC 

Under Se ·on 333 of the FAA Reform Act 

and Title · 4, :Pan 11 ofFAR 

Page 5 12 pages 

asses~F. of the risk of operating closer to those objects and determined that it does not present 

an undue hazard. I' 

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All fli1 operations will be conducted over private or controlled-access property with 

permis on from the owner or controller of such property or the authorized representative of such 

owner t controller. Garvey Environmental's authorized representative will obtain permission 

from th 1 property owner~ controller~ or authorized representative for each flight to be conducted. 

I . Petition,ier will obtain advanced written and/or verbal permission and permits from appropriate 

levels ot go"Venunent, including law enforcement, fire depaitments. or other appropriate 

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The PI~ and VO will be trained in the operation of each UAS operated by Ganrey 

Enviro~ental~ and will receive routine updates on the operations of each UAS. 

The PI 1 and VO will be able to cmmmmicate with each other by voice clearly without 

interru -

If eith UAS loses communications with t:Ite remote controller or loses GPS signal, the UAS 

will ha: the capability of returning to a pre-determined location within a designated location 

and Ian ing autonomously. 

will have the capability to abort a flight in case ofunpredicted obstacles, weather, or 

emerg 1 cies. 

ln addiJ.on to conducting UAS flights on a contract basis to assist in emergency response to 

natural ~d man-made disasters, Garvey Enviromnental intends to conduct commercial flights in 

the S~ and Territories of the United States~ using UAS for the monitoring. inspection, and/or 

mappi ·of: 

Ce ular telephone towers 

w· turbine towers 

S kestacks and chimneys 

A- pollutantemissions 

W ands 

Sh · eline, beaches, and littoral zones 

Ins itutional controls at hazardous waste sites and conservation easement properties 

N "onal Pollutant Discharge Elimination System and State Pollutant Discharge Elimination 

S em permit discharges 

~-JJ water point sources and non-point sources 

• ..,icultural crops 

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Peti1ion II Gsrvoy Euviroomoota1 LLC 

Under s

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ton 333 of the FAA Reform Act 

and Title ~4, Part 11 ofF AR 

Page 6 

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12 pages 

El~trical transmission lines and towers 

R~troad corridoiS~. including.cate~ towers 

Roofs of commercial and res1dent1al structures 

7. Peti~onera should spec!/Y 1M pro~ mmimum operating speed and altitude, and lkscribe 

mini~ flight visibility and distance from clouds for their intended operation(s). Petinoners 

should 4escribe potential hazards and safety mitigations associated with these proposed 

condi~~-11 . 

G~ nviromncnlal will typically conduct its UAS flight operations in hover mode up to 500' 

above und level {"AGL) while visually inspecting structural features of towers such as guy 

wire mQbts, antenna motmts, and antenna wiring. Petitioner will conduct flights over wetlands, r. 

agricult)llnd crops~ and hazardous sites at no greater than 200' AGL, with groundspeed not to 

exceed *0 knots. All flight operations will be conducted via VLOS. 

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Garvey /~nvironmental will not operate any UA at less than 500' below or less than 2,000' 

horizontlly from a cloud or when visibility is less than three (3) statute miles from the PIC. 

If the ~hs loses communications or loses its GPS signal, the UA is designed and manufactured • I I~ • 1. .. • 1 .. • • • • .1 I fl,. • • --- oil • L1 I • I 

LU lt:Wl~t ~U U J .. llt:-UII;u;l.lWUlt:U lULi~UU WlUll.ll UlC J:111HU.C Ul I,;UIU.LUUCU-'"-'-'Ci)i) }JAVVti.U.J. 

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The PI will abort the flight if unpredicted obstacles or emergencies are encountered during the 

flight. I 

The PI will not begin a flight unless there is enough available on board power for the UA, 

taking · consideration wind and other weather conditions, to conduct the intended operation 

and to erate after that for at least five (5) minutes or with the reserve power recommended by 

the marlpfacturer, if such power is greater. 

8. Pe~onen should deJCrlbe 1M charocterl.Jiics ojtM area ojltrlended operalkm(•) and flu 

associaffd potential hazards, in accordance with the statutory mandate under Section 333 

regard~g proximity to populated areas. 

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Garvey· nvironmental intends to conduct flight operations in the States and Territories of the 

United tates. Petitioner's flight operations will have an emphasis on routine inspections of 

cellular d other communication towers and wind turbine towers in sparsely populated areas, 

and th will typically have little effect on the public. 

9. Peti oners should de~cribe if they intend to operate in the proximity of any airports, in 

acco with the statutory mandate under Section 333 regarding proximity to aitpot'ts. 

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Petition #£Garvey Envil'ownental LLC 

Under S~tion 333 of the FAA Reform Act 

and titl 14, Part ll ofFA.R. 

Page 7 o 12 pages I 

Garv~~Environmental will not operate a UA within five (5) nautical miles of the geographic 

center qf an uncontrolled airport or the Airport Reference Point of a controlled airport, unless a 

letter oEagreement with that airport"s management is first obtained by Petitioner or unless such 

flight 1~ otherwise permitted by a Certificate of Waiver or Authorization issued to Petitioner. 

Garvey nvironmental will make such letter of agreement with the airport management available 

to the 1 Administrator or any law enforcement official upon request 

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10. Th~ UAS must be operated within visualline-o.fsight (VLOS), in accordance with the 

statutof6; mandate under Section 333{b)(J). Petitioners should describe how they intend to 

comply[~ith this mandate. 

Each tfA.s operated by the Petitioner will be operated witlrin VLOS by the PIC assisted by aVO. 

in accoidance with the Section 333(b)(l) statutory mandate not to create a hazard to users of the 

NAS o~!the public or pose a threat to national security. f; 

11. Pr~cedures for conducting preflight sqfoty risk assessment to determine that the UAS is in a 

conditit for safe flight {14 CFR § 91. 7 (b)) and that the planned operation can be completed 

safely. II 

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The PIG or qualified operator will perform preflight safety checks of each UAS prior to each UA 

flight, i# accordance with the recommendation of the manufacturer of the specific UAS to be 

operate~. 

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12. Pro ·eduresfor conduct operations which have existing requirements to notify Flight 

Standmj District Offices (FSDOs) prior to operations. 

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The PI will provide appropriate notification to FSDOs in advance of conducting pipeline or 

powerli, e aerial mapping and/or inspections. or in advance of conducting any other flight 

operati1rs requiring notifications for FSDOs. 

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In acco~~ce with 14 CFR Part 11, the following summary is provided for publication in the 

Federa~jRegister, if the FAA determines that publication is needed: 

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r.pplicant seeb an exemption from the following Federal Aviation Regulations,J4 CFR 

Part 21 r.ubpart H; 14 CFR 45.23 (b); 14 CFR 61.113 (a) & (b); 14 CFR 91.7 (a);;l4 CFR 91.9 

(b) (2); 4 CFR 91.103(b)(2); 14 CFR 91.105; 14 CFR 91.109; 14 CFR 91.119 {c); 14 CFR 

91.121; 4 CFR 91.151 (a); 14 CFR 91.203 (a) & (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) 

(1); 14 'FR 91.409 (a) (2); and 14 CFR 91.417 (a) & (b), for the purpose of conducting 

comme ~ialflight operations utilizing small unmanned aerial vehicles ("UAs") weighing 6/bs. 8 

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Garvey nvironmental may be reached through the lUldersigned at the above mailing address and 

by emai at dgarvey@garveyenviromnental.com. Thank you for your consideration of this 

Petition1 

Respec I ly Submitted, 

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ARVEYENVIRONMENTALLLC 

y: 

David A. Garvey 

Managing Member 

Attac nt: APPENDIX A, FEDERAL AVIATION REGULATIONS FROM WHICH 

PETITI NER GARVEY ENVIRONMENTAL SEEKS EXEMPTION 

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Petition ¥Garvey Envirorunental LLC 

Under~ Stion 333 of the FAA Reform Act 

and Title 4. Part 11 ofF AR 

Page 9 12 pages I, 

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I' APPENDIX A 

FEDERAL AVIATION REGULATIONS FROM WHICH PETITIONER GARVEY 

ENVIRONMENTAL LLC SEEKS EXEMPTION 

Certification procedures f<lr 

products and parts, 

Airworthiness Certificates 

This regulation sets forth the procedural requirements 

fol' the issuance of airworthiness certificates .. Given the 

size and limited operating area associated with the 

aircraft to be operated by Petitioner, an exemption from 

this Subpart meets the requirements of an equivalent 

level of safety undeJ:" Part 1 J and Section 333 of the 

Reform Act The Federal Aviation Act (49 U.S.C. 

§44701 (t)) and Section 333 of the Reform Act both 

authorize the FAA to e:l!:.empt aircraft from the 

requirement fur an a.Uworthiness certificate, upon 

consideration of the size, weight, speed. operational 

capability, and pmxitnity to au-ports and populated a~:"eas 

of the particular UAS. In all cases, an analysis of these 

criteria demonstrates that the U AS operated without an 

airworthiness certificate:, in the restricted environment 

and under the conditions proposed will be at least as 

safe, or safer. than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The UAS to be operated by Petitioner weighs no more 

than 6 lbs. 8 oz., carries no pilot or passenger, carries no 

explosive m.atedals or flaro.mable liquid fuels, and 

operates within a secured arul designated area Unlike 

other civil aircraft, operations Wlder this exemption will 

be carefully controlled and monitx).-ed by the PlC and 

conducted in compliance with local public safety 

requirements. These sakty enhancements provide a 

greater degree of safety to the public and property 

owners than conventional operations conducted with 

airworthiness certificates. Application of these criteria 

demonstrates that there is no Cl'tdible threat to national 

security posed by the UAS. because of their size, speed, 

location of operation, lack of eXplosive materials or 

flammable liquid fuels. and inability to cany a 

substantial"''"'''"'".-~ 

An equivalent level of safety will be provided by having 

each UA marked on its fuselage as required by where 

the PIC, YO, and others with the UAS will see 

the identification of the 
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Petition< r Garvey Environmental LLC 

UnderSe1 ~ion 333 of the FAA Reform Act 

and title~ 4, Part 11 ofFAR 

Page 10 f' 12 pages 

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Part 91.9 b){2): 

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Part 91.1 ?J(b )(2) 

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Part 91.1 5 

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Part 91.1 t 

Part91.1 

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Instructors, and Ground 

Instructors 

Civil Aircraft Airworthine55 

Civil Aircraft Flight Manual 

in the Aircraft 

Preflight action 

Flight crewmembers at 

stations 

Flight instruction 

Minimum safe altitudes 

unless that PIC has demonstrated to Pe:ititioner, by 

meeting miniroum flight-hour and currency 

requirements, that such PIC is able to safely operate 

such UAS in a manner consistent with the exemption, 

including evasiYe and emergency maneuvers and 

maintaining appropriate distances from people, vessels, 

vehicles, and structures. In this manner, an equivalent 

level of safety will be maintained. 

As there will be no airworthiness certificate issued for 

the UAS, should this exemption be granted, no FAA 

regulatocy standard wHl exist for detenu.ining 

airworthiness. Because of esae of maintaining the UA 

to be operated by Petitioner and through the use of 

s:Uety check lists prior to each flight, an equivalent level 

of safe'ly will be maintained. 

The UAS, given its size and configuration is nm: capable 

of carrying such a flight manual on the aircraft or on 

the person of an on-board PIC. The equivalent level of 

safety will be maintained by keeping the flight manual 

at the ground control point whew the PIC will have it 

readily_ available. 

As FAA-approved flight manuals will not be providEd 

for the UA. Rather, the PIC will take all actions as 

stated in a Flight Operation Manual including reviewing 

weather, flight battexy requirements, landing and takeoff 

distances, and airctaft penonnance data before initiation 

of flight as well as checking the UAS for any possible 

damage that might bring about unfavorable flight 

conditions. 

Because of the size, design, and capacity of the UAs to 

be operated by Petitioner, the UA flights will not carry 

crewmembers, who will therefore not be at designated 

on-flight stations. Therefore, an exemption will be 

needed. Rather, the UA flights will be operated by a 

ground-based PIC assisted bv aVO. 

By their design and function, the UAS to be operated by 

Peititioner do not bave dual controls. Flight control is 

accomplished through the use of a controller that 

communicates with the aircraft via radio 

comrounicatlons. The equivalent level of safety will be 

provided by Petitioner in its flight operations insofar as 

neither a pilot nor passengers will be carried in the UA, 

and f)y using lightweight, slow-speed U.As. 

As this exemption is for a UAS that is a form of 

helicoptef and Petitioner requests authority to operate at 

altitudes up to 400 AGL, ao exemption may be needed 

to allow such opemtions. Petitioner vv:iii not operate its 

UAS at highet th~UJ.400 AGL. In addition, it will 

operate its UAS in a restricted area with a security 
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Petition J~i Gorvey EA.-LLC 

Under St; tion 333 of the FAA Refonn Act 

and Titleii4, Part ll ofFAR 

Page 11 ~ 12 pages 

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§ 91.203( ) & (b) 

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Altimeter setting 

Ftlel requirements for flights 

in VFR conditions 

Civil airc(Bft: Certifications 

tequired. 

perimeter, where property owners and people will not 

be exposed to operations without their prior consent 

The equivalent level of safety will be achieved given the 

size, weight, speed of the UAS as weU flS the location 

where it is operated. No flight will be taken without the 

pennission of the property owner/custodian or local 

officials. as appropriate. ln comparison to tligbt 

operations with aircraft or rotorcraft weighing fat: more 

than the maximlllll 6 lbs. 8 oz. UA weight proposed to 

be used by Petitioner. and the associated absence of 

flammable fuel, risks associated with these operations 

are far less than those presently presented with 

conventional aircraft operating at or below 400' AGL. 

In addition, the low-altitude operations of the UAS will 

ensure separation between the UAS operations and the 

operations of conventional aircraft. 

Petitioner will m:Untain an equivalent level af safety 

insofar as the altitude information of Petitioner's UAS 

w:ill be provided to the PIC via GPS equipment and a 

radio connection linking to a controller for active 

monitoring of the flight path and altitude. This altitude 

information, combined with Petitioner's operation ofthe 

UA within VLOS, at or below 400' AGL, will ensure a 

level of safety equivalent to that required by this 

regulation. The altitude information will be generated 

by GPS equipment onboard the aircraft. Prior to each 

flight, a zero altitude initiation pojnt will be 

automatically established by each UAS at ground leveL 

Petitioner will obtain an equivalent level of safety 

through: 1) the technical specifications of the UAS it 

will operate~ (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight 

operations. Accwdingly, Petitioner will ensure that it 

will safely operate each battexy·powered UAS during 

daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of ~minutes to the 

first point of intended landing and, assuming normal 

cruising speed to £ly after that for at least minutes. 

An airworthiness certificate cannot be carried on the 

UAs to be operated by Petitioner, given the 

configuration and limited payload capacity of these 

aircraft. To w:it, there is no ability or place to carry 

certification and registration documents or to display 

them on the UAS. A.n equivalent level of safety will be 

achieved by keeping relev~;~nt airworthiness certificates. 

if any are issued by the FAA for such UAs~ and relevant 

manufacturer documentation on the ground in ready 

access t(l the PIC. 
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Pedtion J Gmvey Enviromnental ILC 

Under S~~on 333 of the FAA Reform Act 

and Title ~~4, Part 11. ofF AR 

Page 12 f 12 pages 

Part91.4J S(a) Maintenance required 

Part 91.4 7(a)(l) Operation after maintenance 

Part 91.4 ,9(a)(.2) Inspections 

Part 9 L4r·) & (b) Maintenance records 

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These PaltJ, along with Part 4 3. apply only to an aircraft 

with an airworthiness certificate. Because the FAA will 

not issue an airworthiness certificate for the UAs to be 

operated by Petitioner, these Parts vvill not apply and an 

exemption should be granted. Petitioner will maintain 

the UAs according to the relevant flight manual and 

operating 'handbook. A.n equivalent level of safety will 

be achieved because the UAS ha$ a vecy limned size, 

will cany a small payload, and operate only in restricted 

areas for imited periods oftime. If mechanical issues 

arise, the UAS can land or be brougbt to land right 

avvay. FUrthermore, .it will be operating from no higher 

than 400' AGL. The PIC will ensure that the UAS is in 

worlOng ord.er prior to initiating flight, peifoim required 

maintenance, and keep a log of any maintenance 

performed. Moreover, as the person most tamiliar with 

the aircraft, the PIC is best suited to maintain the 

aircraft in an ail'WOrthy condition to pmvide an 

~:qujva.lent level of safety. An equivalent level oha:&ty 

will be achieved because maintenance ~ inspections 

will be performed in accordmce with the UAS 

manufacturer's user manual. As provided in the FOM, 

the operator will ensure that the UAS is in working 

order prior to initiating flight and petfonn required 

maintenance needed.