Dan M. Hagin

DnL Strategies

1018 Natural Springs Way

Leland, NC 28451

(p) (910) 547-9808

(e) danh@itscarolinagolf.com

January 20, 2016

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request pursuant to Section 333 of FAA Reform Act and Title 14, Code of 

Federal Regulations (14CFR): §§ 21 subpart H; 45.23(b); 61.113(a) and (b); 91.7(a); 

91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(b); 91.203(a) and (b); 91.405(a); 

91.407(a)(1); 91.409(a)(1) and (2); and 91.417(a) and (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“the 

FMRA”) and 14 CFR Part 11, Dan M. Hagin (DnL Stratagies), (referred to herein as 

“applicant”), PIC of small Unmanned Aircraft Systems (sUAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations to allow commercial 

operation of its sUAS, so long as such operations are conducted within and under 

the conditions stipulated herein or as may be established by the FAA as required by 

Section 333. 

Commercial operation of sUAS, as described herein, which are equipped with 

cameras and sensors, would operate in the following manner:

Public Benefits:

The requested exemption would allow us to use the UAS for aerial image acquisition 

to support analysis of golf courses (and affiliated partners in marketing). General 

maintenance, water retention, water distribution, playability would all be enhanced. 

Typical applications would include, but are not limited to: 

Aerial Photography 

Preventive maintenance of grounds

Videography/Film making 

Marketing 

Education 
The inherent ability of the UAS to capture imagery from a low altitude including 

oblique photos and video from several angles is complimentary but yet far more 

versatile than ground-based or boom based imagery for analyzing golf course and 

their maintenance, as well as redesign and educating customers on the facilities. The 

applicant intends to use unmanned systems on golf courses to enhance and market 

our products. The public will benefit as a result of this analysis through improved 

golf facilities. In addition, the golf industry is related to products, hotels, 

restaurants, theme parks, places of interest and applicate would work with these 

other industries to coordinate marketing efforts.

Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, agriculture, engineering, closed set television and 

motion picture filming, public events, residential/commercial structures, golf 

courses, and providing live video feed to assist with search and rescue operations in 

cases of an emergency or natural disaster. All are part of the golf community.

Request:

As described below, the requested exemption would permit the operation of sUAS 

under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this 

exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system.”

The name, address, phone, and email of the applicant:

Dan M. Hagin

1018 Natural Springs Way

Leland, NC 28451

(910) 547-9808

danh@itscarolinagolf.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109
14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(b)

14 CFR 91.203(a) and (b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

14 CFR 91.409(a)(1) and (2)

14 CFR 91.417(a) and (b)

The sUASs the applicant will be using are multi-rotor craft weighing no more than 

55 lbs including payload. Under normal conditions, they operate at speeds of no 

more than 45 mph or 39 knots and have the ability to hover and move along a 

vertical and horizontal plane simultaneously. They will be operated in visual line of 

sight only and in accordance with all other local and federal laws.

Given the small size of the sUAS and the controlled environment provided, the 

proposed operations will adhere to the Reform Act’s safety requirements. The 

approval of this application presents no national security issues. Regarding the level 

of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, 

the grant of the requested exemption is in the public interest. Accordingly, the 

applicant requests that the FAA grant the requested exemption with minimum 

delay. 

THE UNMANNED AIRCRAFT (UAS): 

 The UAS is lightweight (under 55lb. gross weight), battery operated multirotor copter that takes off and land vertically and has the ability to hover in 

one location during flight. 

THE UAS INCLUDES: 

 An on-board flight computer with GPS navigation and location ability that receives 

signals for flight control from a ground-based transmitter/controller. 

An on-board camera or sensor package used to document physical and/or environmental 

conditions of structures and the natural environment. 

 An on-board telemetry system that delivers flight data from the on-board flight 

computer to the radio transmitter including altitude AGL, horizontal and vertical 

speed, compass direction of flight and direction back to its launch site. 

 A 2.4GHz on-board radio transmitter that transmits live video from the on-board 

camera plus all the flight data from the telemetry system described above. 

THE GROUND STATION PART OF THE SYSTEM: 

 A Pilot in Command (PIC) in operational control of a mission from beginning to end, 

and who controls the UAS while in the air. 

 A 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while 

in flight. 
 Ground Station (computer, tablet or smart phone based app) which receives and 

displays video and system telemetry real time from the UAS. 

PILOT IN COMMAND (PIC):

The PIC will meet the requirements outlined in FAA Policy N 8900.227 Section 16 Personnel 

Qualifications. Additionally, the PIC will perform maintenance on the system and will 

complete a course of maintenance instruction as part of their initial training.

I submit that the combination of the UAS light weight, flight performance and ability, fully 

qualified flight crew and strict operation under the guidelines established in 8900.227, and 

under all of the Restrictions listed above, the FAA can have full confidence that the 

operation will be safe and in compliance.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of the persons and/or property 

using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in 

the Flight Operations Manual (FOM) include:

(Please see Exhibits I, II, III, IV, V for actual pre/post flight and flight log 

information)

1) The UA may not be operated at a speed exceeding 50 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to 

determine compliance with the 50 mph speed restriction. In no case will the UA 

be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer. 

2) 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. 

3) 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. 

4) The exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in the 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 the exemption and the procedures outlined in the 

operating documents, the conditions and limitations of the exemption take 

precedence and must be followed. Otherwise, the PIC must follow the 

procedures as outlined in its operating documents. The PIC may update or revise 

its operating documents. It is the PIC’s responsibility to track such revisions and 

present updated and revised documents to the Administrator or any law 
enforcement official upon request. The PIC must also present updated and 

revised documents if it petitions for extension or amendment to this grant of 

exemption. If the PIC determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the PIC 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. 

5) 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 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. 

6) The PIC is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

7) 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. 

8) The PIC must follow the UAS manufacturer’s maintenance; overhaul, 

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

components. 

9) Each UAS operated under the exemption must comply with all manufacturer 

safety bulletins. 

10)Under the grant of exemption. The PIC must hold a current and valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. 

11)The PIC may not operate unless the PIC demonstrates the ability to safely 

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

under the 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 14 CFR § 61.51(b). Flights for the purposes of training 

the PICs (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 the exemption are permitted under the terms of the

exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experiencebuilding 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. 
12)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. 

13)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.

14)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. 

15)For tethered UAS operations, the tether line must have colored pennants or 

streamers attached at not more than 50 foot intervals beginning at 150 feet 

above the surface of the earth and visible from at least one mile. This 

requirement for pennants or streamers is not applicable when operating 

exclusively below the top of and within 250 feet of any structure, so long as the 

UA operation does not obscure the lighting of the structure. 

16)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. 

17)The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies. 

18)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 5 minutes or 

with the reserve power recommended by the manufacturer if greater. 

19)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 enclosed COA. 

20)All aircraft operated in accordance with the 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. 

21)Documents used by the PIC 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. 

22)The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

24)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 PIC 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. 

c) The PIC, trainees, or essential persons are not considered nonparticipating 

persons under this exemption. 

25)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. 

26)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. 

27)For the purpose of closed-set motion picture and television filming and 

production, the PIC must have a motion picture and television operations 

manual (MPTOM) as documented in the grant of exemption. 

28)At least 3 days before aerial filming, the PIC of the UAS affected by the 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 PIC for the UAS aerial filming conducted 

under the 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 PIC 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. 

29)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 the 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. 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 

91.203 (a) (1). Given the size and limited operating area associated with the aircraft 

to be utilized by the applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 33 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular sUAS. In 

all cases, an analysis of these criteria demonstrates that the sUAS 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 sUAS to be operated hereunder is less than 55 pounds fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid 

fuels, and operates exclusively within a secured and designated area. Unlike other 

civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the PIC and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional operations conducted 

with airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to 

carry a substantial external load. 

14 CFR 45.23 (b) Marking of the Aircraft

The regulation requires: When marks include only the Roman capital letter “N” and 

the registration number is displayed on limited, restricted or light-sport category 

aircraft or experimental or provisionally certificated aircraft, the PIC must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches not more than 6 inches high, the words “limited,” 

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

Even though the sUAS will have no airworthiness certificate, an exemption may be 

needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on 

which the word “Experimental” can be placed. Given the size of the sUAS, two-inch 

lettering will be impossible. All aircraft will have identification (N−Number) 
markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as 

practicable.

14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR 61.113(a), no person who holds a private pilot certificate may 

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

compensation or hire. Our sUASs do not carry any pilots or passengers nor property 

therefore the applicant seeks an exemption to 14 CFR 61.113(a). The risks attendant 

to the operation of sUAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR 61. I feel the operation and limitations sets forth in the 

FOM will equate to the safe operation of the sUAS.

14 CFR 91.7(a) Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will exist for 

determining airworthiness. Given the size of the aircraft for maintenance and use of 

safety checklists prior to each flight, an equivalent level of safety will be provided. 

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in the Aircraft

Section 91.9(b)(2) provides: No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by Section 

21.5 of this chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. The sUAS, given its size and configuration has 

no ability or place to carry such a flight manual on the aircraft, not only because 

there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the 

flight manual at the ground control point where the pilot flying the sUAS will have 

immediate access to it. 

14 CFR 91.103 Preflight Action

This regulation requires each pilot in command to take certain actions before flight 

to ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff 

distances and aircraft performance data before initiation of flight. 

14 CFR 91.109 Flight Instruction

Section 91.109 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. Small UAS and remotely piloted aircraft, 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. The FAA has approved exemptions for flight training without fully 
functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety is provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft and by the size and 

speed of the aircraft. 

14 CFR 91.119 Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119(d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a 

helicopter and the exemption requests authority to operate at altitudes up to 400 

feet AGL, an exemption may be needed to allow such operations. As set forth herein, 

the sUAS will never operate at higher than 400 feet AGL without a COA specifically 

authorizing an altitude above 400 feet AGL. The equivalent level of safety will be 

achieved given the size, weight and speed of the sUAS as well as the location where 

it is operated. In addition, the low-altitude operations of the sUAS will ensure 

separation between these sUAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 CFR 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 sUAS 

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 PIC, 

pursuant to the safety check list and live flight data monitoring, confirming the 

altitude of the launch site shown on the GPS altitude indicator before each flight. 

14 CFR 91.151(b) Fuel Requirements for Flight in VFR Conditions

Section 91.151(b) requires rotorcraft pilots to plan at least a 20 minute fuel reserve. 

The battery powering the sUAS provides approximately 20 to 23 minutes of flight. 

To meet the reserve requirement in 14 CFR 91.151(b), sUAS flights would be limited 

to less than 3 minutes. Given the limitations on the sUAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time 

frame for flight in VFR conditions is reasonable. The applicant believes that an 

exemption from 14 CFR 91.151(b) falls within the scope of prior exemptions. 

Operating the sUAS in a tightly controlled area with less than 20 minutes of reserve 

fuel does not engender the type of risks that Section 91.151(b) was intended to 

alleviate given the size and speed of the small UAS. Additionally, limiting sUAS 

flights to 3 minutes would greatly reduce the utility for which the exemption will be 

granted. The applicant believes that an equivalent level of safety can be achieved by 

prohibiting the PIC from beginning a flight unless (considering wind and forecast 

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

intended operation and to operate after that for at least 5 minutes or with the 

reserve power recommended by the manufacturer if greater. 
14 CFR 91.203(a) and (b) Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operated a civil aircraft 

unless it has within it the following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew.

The sUAS fully loaded weighs no more than 55 pounds and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and 

registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to 

them, to the extent they are applicable to the sUAS. 

14 CFR 91.405(a); 407(a)(1); 409(a)(2); 417(a) and (b) Maintenance Inspections

These regulations require that an aircraft PIC or owner “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...,” and others shall inspect or 

maintain the aircraft in compliance with Par 43. Given that these sections and Part 

43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the applicant. Maintenance will be accomplished by the PIC pursuant to the 

flight manual and operating handbook. An equivalent level of safety will be achieved 

because these sUASs are very limited in size and will carry a small payload and 

operate only in restricted areas for limited periods of time. If mechanical issues 

arise, the sUAS can land immediately and will be operating from no higher than 400 

feet AGL. The PIC will ensure that the sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the PIC is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety.

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the sUAS Manufacturer’s Manual, as 

referenced in the Aircraft Operations Manual (AOM). As provided in the FOM, the

PIC will ensure that the sUAS is in working order prior to initiating flight and 

perform required maintenance needed.
Small UAS information

sUAS’s to be used are as follows but not limited to providing they are within the 

scope of the exemption granted by the FAA:

Links to service manuals and safety features

1. DJI Phantom 3 Advanced (P3A)

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Man

ual__V1.6.pdf

2. DJI Phantom 3 Pro (P3P)

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_M

anual__V1.6.pdf

See Exhibits I, II, III, IV, V