### September 17, 2015

Exemption No. 12908 Regulatory Docket No. FAA

− 20 15

− 2700

Mr. Chuck Stephan KOA Corporation 1100 Corporate Center Drive, Suite 201 Monterey Park, CA 91754

Dear Mr. Stephan :

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 June 4, 2015 , you petitioned the Federal Aviation Administration (FAA) on

behalf of KOA Corporation ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial photography for infrastructure and construction purposes

.

See Appendix A for the petition submitted to the FAA des cribing 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 a DJI Phantom 2 Vision Plus

.

### 2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic 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

meets the conditions of Section 333. Therefore, the FAA fi nds that the requested relief from

14 CFR part 21

, C ertification 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 Decis ion

You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 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 Lab s , 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. 11 062, 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, KOA Corporation is granted an exempt ion 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

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 (part iculate measurement, etc.), or any other gathering of data by

instruments aboard the UA.

### 3

the extent necessary to allow the petitioner to operate a UA S to perform aerial data collection

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

Conditions and Limitations

In this grant of exemption, KOA Corporation is hereafter referred to as the operator.

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 DJI Phantom 2

Vision Plus when weighing less tha n 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 mus t 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 ;

e lectronic 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 refer red to as the operating documents. The operating

### 4

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 do cuments. It is the operator’s responsibility to track such revisions and present updated and revised 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. T he FA A’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.

, re placement 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 peop le. 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 inspec tion 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 m anufacturer’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 Col u mbia, Puert o Rico, a territory, a possession, or the Federal

### 5

government. The PIC must also meet the flight revi ew 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, vessel s, 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 operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and de termining 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 traini ng sessions. During

traini ng, 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 1 4 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 symbo l as denoted on the current

FAA

- published aerona utical 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 sign a l, the UA must return to a

pre

- determined location within the pr ivate 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 win d 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 Organizat ion (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The

### 6

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.

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 a nd 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, v ehicles, 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 protectio n. 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 t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative.

P ermission 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 FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be

### 7

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.

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 a rea 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 th e 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 invol ved 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 operati on.

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.

### 8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/ s/

John S. Duncan Director, Flight Standards Service

Enclosures1 1 100 Corporate Center Drive, Suite 201

Monterey Park, CA 91754

t: 323.260.4703 f: 323.260.4705

w ww.koacorporation.com

June 4 , 2015

U. S. Department of Transportation , Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave. SE Washington, DC 20590

Subject: R EQUEST FOR E XEMPTI ON P ER S ECTION 333 OF THE FAA R EFORM A CT

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part

11, K OA Corporation , Inc. (KOA ), a C alifornia based C orporation providing civil engineering services

, hereby applies for exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography for various industries and public
agencies

, commercially in airspace regulated by the Federal Aviation Administration (FAA)

, so long as such operations are conducted with and under the conditions outlined herein a nd as established by the FAA

, as required by Section 333.

The p roposed exemption w ill permit K OA to pursue its commercial interests in providing services to consumers

interested in aerial data capture using a small advanced sUAS in the following areas:

• A erial imagery for use in planning and design of public inf ras tructure, including streets and pipelines

• A nalysis and assessment of existing public inf ras tructure, including streets and pipelines

• P lanning and design of development projects

• D ocumentation of public infrastructu re construction activiti es

• Urgent i nspection of faciliti es and infrastructure s in the event of an earthquake or other emergency requiring engineering response and assessment.

K OA ’ s chief sUAS operator holds an FAA Private Pilot License . All KOA operator ’ s will be trained to understand the proper roles of an operator, observer, communication procedures, preflight planning and area observation,

checklists, conflict avoidance, separation from ut ilities and structures, proper visual scan techniques, equipment

care , inspection and maintenance, and FAA Section 333 requirements

.

KOA is requesting exemption from :
14 C.F.R. Part 21 14 C.F.R. 91.121 14 C.F.R. 45.23 (b) 14 C.F.R. 91.151(a) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.215

14 C.F.R. 91.109 14 C.F.R. (91.401

- 91.417)

14 C.F.R . 91.119

sUAS are a feasible method to obtain information regarding existing and proposed public infrastruct ures. Some
existing infrastructure

, such as busy railroad yards , steep flood control channels, piers, and hillside drainage

structures are f

airly inaccessible. sUAS allow ready and safe access to such sites while reducing pers onal risk of2 1 100 Corporate Center Drive, Suite 201

Monterey Park, CA 91754

t: 323.260.4703 f: 323.260.4705

w ww.koacorporation.com

injury from climbing and falls. Large projects encompassing several acres, or miles, of infrastructure are best

viewed and un d erstood f rom an aerial persepective captured by a sUAS camera. After an earthquake or other

disaster, an sUAS wil l allow ready and safe access to damaged or q uestionable sites for engineering i nspection and

assessment

.

We are petitioning for exemption to enable K OA to operate a DJI Phantom 2 Vision Plus multi

- rotor equipped

wit h a three

- axis gimbaled camera . Th is sUAS weigh s less than 25 lbs

, has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. T he system has a failsafe return function. When communication
between the Main Controller and the transmitter is lost, the s UAS will automatically r eturn to the starting

location and land safely. T he DJI Phantom 2 Vision Plus consists of a battery

- powered unmanned aircraft unit with camera, and a ground

- based controller with communications device operated by the Pilot in Command (operator). Radio commun ications are compliant with Federal Communications Commission requirements.

KOA ’ s operati ons will include the following requirements:

• The petitioner will operat e its sUAS in line of sight of the operator and/or observer . Such operations will be

conducted to e nsure that the sUAS will not create a hazard to users of the national airspace system or the public.

• Maximum flight time for ea ch operational flight will be 20 minutes. Multiple flights may be conducted. • Flights will be terminated at 25% battery power reserve should that occur prior to the 2 0 minute limit. • The sUAS operated by the petitioner weighs less than 55 pounds, inc luding the payload (i.e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 55 knots.

Under the requested exemption K OA ensures that all operators have completed a small unmanned aircraft

systems sUAS education and training program including applicable regulations and gui dance documents ; Basic Small UAS Aerodynamics; Weather factors; Flight Planning; Preflight Assessment; Incident Avoidance; Airmanship

and Decisio n making and Safe Operating Procedures.

We respectfully request exemption und er Section 333 to enable K OA to operat e safe, low

- risk commercial sUA S operations for the activities stated. K OA at a ll times will respect the space and privacy of citizens and pr operty

whil e keeping our skies safe.

Sincerely, KOA Corporation

Chuck Stephan, P.E.

V ice President3 1 100 Corporate Center Drive, Suite 201

Monterey Park, CA 91754

t: 323.260.4703 f: 323.260.4705

w ww.koacorporation.com

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

K OA Corporation , Inc. (KOA ), requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of a Small Unmanned Aircraft System ( sUA S) :

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to

work to deve lop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Phantom 2 Vision plus, under either or both of the following provisions:

21.191 Experimental certif icates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b ) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales

demonstrations, and customer crew t raining, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's lig ht weight, being constructed primarily of foam, carbon fiber, and/or plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certifica te is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 D isplay of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in let ters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We

propose to achiev e an equivalent level of safety by including the word "EXPERIMENTAL" on the top of the

aircraft , We will also i nclude the KOA name and contact information on the aircraft for identification purposes.

14 CFR 61.113 Private pilot privileges and limitations:

Pilot in Command and 61.133 Commercial pilot privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircra ft for compensation or hire.4 1 100 Corporate Center Drive, Suite 201

Monterey Park, CA 91754

t: 323.260.4703 f: 323.260.4705

w ww.koacorporation.com

Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Our proposed operations require that the operator must be duly train ed and capable of operating the sUAS safely and in conformance with all regulations and requirements.

Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to a ugment our business s ervices

.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate.

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the

aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry

documentation, the documentat ion would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual

, and equipment manufacturer ’ s information, w ill be available to the crew at the ground station anytime the air craft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless

that aircraft has fully functioning dual controls." The sUAS System ground

- based control station consists of a small

hand

- held radio transmitter and while it does not offer a second set of "controls", both a student and instructor

can, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The r egulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of o ur sUAS would be photography or
inspection of s tructures and infrastructure facilities , it will be necessary to operate closer than the 500 feet

limitation. Our o perations will only be c onducted over property or persons where permission has been obtained and careful pre

- planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared

to ma nned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.5 1 100 Corporate Center Drive, Suite 201

Monterey Park, CA 91754

t: 323.260.4703 f: 323.260.4705

w ww.koacorporation.com

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available

within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need to main tain cruising

altitudes to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board computer to th e display screen held by the operator, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unle ss there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. The sUAS are battery oper ated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft will n ot fly more than 2 ,000 feet from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve wil l be to fly the mission to the point of intended landing w ith at le ast a 20% battery reserve

.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration nu mber assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. "

T he sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be colocated with the o perator at the ground

control station and available for ins pection upo n request . T o identify the aircraft, we propose that the info rmation found on airworthiness and registration certificates be perm anently affixed to the aircraft

.

14 CFR 45.23. 14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require tha t the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our

intention that the o perator perform maintenance and inspection of the aircraft and "be authorized to approve the

aircraft for return to service." The o perator will ensure that the aircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections before and after e ach flight. Maintenance performed by

the o perator is limited to repairing small cracks, rep lacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed by the manufacturer or their designated repair facility. The o perator will document work performed in accor dance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the o perator can ensure an equivalent level of safety.