Appendix A

1 of 4 EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Advanced Aviation Solutions LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the 3D Robotics
AeroM:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. Due to the size of the aircraft and FAA proposals for small UAS, we request relief from the requirement for
an airworthiness certificate. The PIC will maintain the small UAS in condition for safe operation and prior to flight must inspect the UAS to ensure that it is in a condition for safe operation.

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

The regulation provides that an airworthiness certificate, with the registration number 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 t o passengers or crew." At 6.8 lbs, the AeroM 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 docume nts deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the registration number be affixed to the airc raft as large as practical.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number. Each aircraft will be registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

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

This regul ation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the ai rcraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the
documentation would not be available to the crew.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose th at a current, approved Airplane Flight Manual (appendix E) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133
Commerc ial pilot privileges and limitations.

The regulation provides that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) TheAppendix A

2 of 4 flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

We propose that t he Pilot in Command (PIC) must possess at least a private pilot certificate and at
least a current third

- class medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. Since t here are currently no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license. 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 conduct a business.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation provides that over sparsely populated areas the aircraft ca nnot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 500 feet AGL, we cannot comply with this requirement.

To provide an equivalent level of safety we will only fly over private property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. We maint ain that due to the small size of the AeroM, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption.

Flight operations will be conducted at least 500 feet from all n onparticipating persons, vessels, vehicles, and structures unless:

a. b arriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipat ing 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 within 500 feet will cease immediately and/or;

b. the aircraft is operated near vess els, vehicles or structures where the land owner/controller has granted permission 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, and

c. operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

14 CFR 91.121 Altimeter settings.

The regulation provides that aircraft shall maintain cruising altitudes by referen ce to an altimeter setting available within 100 nautical miles of the aircraft. The aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de

- conflict with other aircraft. As such, an appropriate a ltimeter measurement presented to the pilot should be Above Ground Level and should be based on the barometric pressure at the point of launch. To provide an equivalent level of safety, the UAS's AGL altimeter will be set to zero on the ground prior to ev ery flight. Since the aircraft will fly no more than 60 minutes, even rapid changes in barometric pressure will have limited affect on the safety of the flight.Appendix A

3 of 4 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 unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide a reserve o f energy as a safety buffer for go

- arounds and other delays to landing.

The AeroM is battery operated and the maximum duration of flight from a single battery charge
is 60 minutes. The PIC will not begin a flight unless (considering wind and forecast weat her conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power remaining.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, and
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 that 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 PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service."

As provided in the at tached Maintenance Procedures (appendix D), the PIC will ensure that the aircraft is in an airworthy condition prior to flight and conduct detailed inspections after every 10 hours. Maintenance performed by the PIC is limited to repairing small cracks, re placing a propeller, and updating software and firmware. All other maintenance will be performed by the manufacturer. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircr aft, the PIC can ensure an equivalent level of safety.

14 CFR 91.7(a)

- Civil aircraft airworthiness

The regulation provides the aircraft require airworthiness certification. Due to the size of the aircraft and FAA proposals for small UAS, we request reli ef from the requirement for an
airworthiness certificate. The PIC will maintain the small UAS in condition for safe operation and prior to flight must inspect the UAS to ensure that it is in a condition for safe operation.