August 13, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Regarding:

Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 91.109(c); 

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2);

91.417 (a) and (b).

Dear Sir or Madam:

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

14 CFR Part 11, Aerial Innovation & Inspections which is an owner and operator of Small 

Unmanned Aircraft Systems (sUAS) equipped to conduct commercial aerial photography and 

videography for agricultural inspection, construction inspection, real estate, and other 

commercial operations hereby applies for an exemption from the listed Federal Aviation 

Regulations (FAR) to allow commercial operation of its sUAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333.

The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS 

may operate safely in the national airspace system (NAS) before completion of the FAA’s plan 

and rulemaking to integrate sUAS into the NAS. The Reform Act directs the Secretary to 

consider which types of sUAS as a result of their size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace or a threat to national security. If the Secretary 

determines that such vehicles may operate safely in the NAS, the Secretary “shall establish 

requirements for the safe operation of such aircraft.”

The granting of this exemption request will provide immediate benefit to the agricultural, 

construction and real estate industries by authorizing highly controlled sUAS operations at or 

below 200 feet above ground level (AGL), in line of sight (VLOS) of an FAA Certificated 

Airline Transport Pilot during daylight hours and above controlled privately owned and operated 

property.

Aerial Innovation & Inspection’s sUAS shall weigh less than 55 pounds including the payload. 

They will operate at no more than 42 knots (49 mph) and have the capability to hover, and move 

vertically and horizontally simultaneously. 

Operations would be conducted above privately owned and operated properties, with the consent 

of the owner/operator. Aerial Innovation & Inspection’s operations will be performed by a 
professional pilot; this pilot will insure that the sUAS will not create any hazard to users of the 

national airspace system or the public.

The grant of this exemption request is in the public interest, does not create a hazard to users of 

the NAS or the public, or pose threat to national security.

In the following pages Aerial Innovation & Inspections will address all areas of concern to 

include:

 Equivalent levels of safety

 Exemptions requested

The name and address of the applicant is:

Aerial Innovation & Inspections

ATTN: Christopher A. Sabel

Phone: (216) 406-0944

Email: aerialinnovationandinspections@gmail.com

Address: 12195 Waterfowl Lane

 Chardon, Ohio 44024

Aerial Innovation & Inspections appreciates your consideration in this application.

Best Regards,

Christopher A. Sabel

President of Aerial Innovation & Inspections

Included in this Exemption Letter:

 Operations

 Regulations for which exemptions are requested

To follow this Exemption Letter and/or on request:

 Aerial Innovation & Inspections’s Flight Operations Manual and Pilot Checklist

 A2 Flight Control System User Manual

 Spreading Wings S1000+ Aircraft Operating Manual (AOM)
Table of Contents

Operations and How They Serve the Public Interest

About Aerial Innovation & Inspections

Aerial Innovation & Inspections’s sUAS Description

Safety

Maintenance

Permissions and Permitting

Operations

Flight Time and Flight Durations

Exemptions from which Regulations
Operations and How They Serve the Public Interest 

Real Estate Photography

SUAS allow aerial video and photography of real estate property as well as other 

sectors without the use of full size aircraft. They are more efficient, less costly, and 

environmentally friendly.

Noise and emissions will be reduced, as well as imparting minimal disturbance to 

persons on the ground.

Construction Sites

Perform inspections and aerial surveys of construction sites and structures without the 

need to erect dangerous scaffolding or expensive cranes and minimize the danger to 

human life and property.

Agricultural Inspection

Through real time crop management, sUAS will help identify better crop planning and 

rotation strategies, irrigation patterns and crop stresses and allow for prompt action 

preventing permanent crop damage. Lower cost and increase flexibility over fixed wing 

aircraft will yield faster and safer results.

About Aerial Innovation & Inspections

President

 Christopher A. Sabel leads Aerial Innovation & Inspections as President and Founder. 

 Chris holds an Airline Transport Pilot (ATP) Certificate and keeps a current Class I

Medical Certificate. He is a Lead Flight Captain for a Part 91 Corporate Flight 

Department. 

 Chris has extensive experience in both commercial aviation and radio control aircraft 

operations, including helicopters and multi-copters. He is educated in the construction 

and assembly of model aircraft including sUAS, and has extensive knowledge of 

maintenance and handling requirements of such aircraft. 

 Aerial Innovation & Inspections’s sUAS will be outfitted for aerial videography and 

photography for use in Real Estate, Construction and Agricultural inspections as listed 

above.

Experience

As a professional pilot, Chris understands that safety is the number one priority in handling any 

aircraft, and will always hold safety above any commercial endeavor. Chris will operate the 

sUAS in accordance with any applicable FAR’s and local, state, and federal laws.
Aerial Innovation & Inspections will operate using a detailed operations manual should this 

operation be approved. 

Aerial Innovation & Inspections’s sUAS use and Description

Aerial Innovation & Inspections intends to operate the DJIs1000+ s UAS multi-rotor aircraft for 

the purpose of obtaining photographs and videos for Real Estate, Construction and Agricultural 

Inspection and other commercial endeavors. 

DJI s 1000+

Model DJI

s1000+

N/A

Weight (Battery Included) 6kg-11kg 13.22lbs-24.25lbs

Battery 22.2v 10000mah-32000mah

Hovering Accuracy Vertical +/-.5m 1.7 feet

Horizontal +/-2.0m 6.6 feet

Max Angular Velocity Yaw/Pitch 150deg/s

300deg/s

N/A

Max Tilt Angle 35deg N/A

Max Accent Speed 6m/s 13 mph

Max Descent Speed 6m/s 13 mph

Max Speed 22m/s 49 mph

Max Flight Time 15min 15000mah @ 20.94 

lbs Takeoff Weight

Operating Temperature Range -10C- 40C 14F-104F

Dimensions N/A 41x18x21inches
Specifications and Design:

A. All sUAS flown under this exemption will be less than 55 pounds including aircraft and 

payload. This exemption requests permission only with respect to the specific use of the 

DJI s1000+, which weighs less than 55 pounds including payload.

B. The radio frequency spectrum used for operation and control of the sUAS will comply

with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. The DJI s1000+ uses spread spectrum technology

operating in the 2.4Ghz range and is compliant with all FCC regulations as demonstrated 

in the aircraft manual. 

C. Maximum speed will be less than 42knots/49mph.

D. The sUAS is equipped with Inertial Navigation Sensor(s) and Gyroscopes 

(IRS/IRU/Accelerator/MEMS Gyroscopes). 

E. The sUAS is equipped with a compass (Magnetometer/Heading Source).

F. The sUAS is equipped with a Global Positioning System (GPS) guidance system.

The DJIs1000+ is equipped with several fail safe features. 

Multi-Rotor motor fail protection. In the event of a motor failure or loss of signal, attitude will 

be maintained and the sUAS will return to home. An intelligent landing gear function will lower 

the gear during a motor failure, a return to home or an auto land maneuver.

Should it lose communications or lose its GPS signal, it will return home or to a pre-determined 

location within the area of operations and land and be recovered by the Pilot in Command.

Safety

Aerial Innovation & Inspections proposes that the exemption requested applies to civil aircraft 

that have the characteristics and that operate with the limitations listed herein.
These limitations provide for at least an equivalent or higher level of safety to operations under 

the current regulatory structure because the proposed operations represent a safety enhancement 

to the already safe operations conducted with conventional aircraft.

This Exemption Request is for Use of sUAS subject to Extensive Operational and Safety 

Requirements

These limitations and conditions to which Aerial Innovation & Inspections agrees to be bound 

when conducting commercial operations under an FAA issued exemption at a minimum include:

A. The sUAS Pilot in Command (PIC) will possess at a minimum, a private pilot certificate 

and current third-class medical certificate.

 The PIC shall also meet the flight review requirements specified in 14 CFR 

§61.56 in an aircraft in which the PIC is rated on their pilot certificate. 

 The PIC shall be trained in the operation of the specific make and model of the 

sUAS being piloted and successfully completed all training required. 

 The PIC shall have accumulated and logged, in a manner consistent with 14 CFR 

§61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a sUAS 

pilot and at least five hours logged as a sUAS pilot with a similar sUAS type 

(multi-rotor/helicopter/airplane). Prior documented flight experience that was 

obtained in compliance with applicable regulations may satisfy this requirement. 

 For currency the PIC shall have accumulated and logged, in a manner consistent 

with 14 CFR §61.51 (b), a minimum of five hours as sUAS pilot operating the 

make and model of sUAS to be utilized for operations under the exemption and 

three takeoffs and three landings in the preceding 90 days. Flight time and number 

of takeoffs and landings will be recorded in a logbook for purposes of 

demonstrating currency.

 Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight cycles and flight 

time. 

B. During training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered non-participants, and the PIC must operate the sUAS 

with appropriate distance from non-participants in accordance with 14 CFR §91.119.

C. The PIC shall always be within visual line of sight (VLOS) of the sUAS while 

conducting operations.

D. A risk mitigation survey will be conducted prior to each flight to ensure VLOS can be 

maintained at all times, hazards are properly identified, and that all regulatory perimeters 

can be met. 
Maintenance

A. The DJI s1000+ will be maintained in accordance with the manufacturer’s user manual 

and Aerial Innovation & Inspections sUAS operating manual.

B. Aerial Innovation & Inspections will document and maintain a record of the sUAS 

maintenance, preventative maintenance, alterations, and status of replacement, overhaul 

component parts, and the total time in service of the sUAS. These records will be 

maintained at the principle base for operation for the life of the aircraft or as required by 

Federal Aviation Regulations. 

C. Aerial Innovation & Inspections will comply with all manufacturer Safety/Service 

Bulletins or equivalent pertaining to the DJI s 1000+. 

D. The PIC shall perform a preflight inspection of the sUAS, controller, and ground control 

station prior to each flight to ensure it is operational with no discrepancies. If the preflight 

inspection reveals discrepancies, repairs or maintenance shall be performed prior to flight 

and logged in the maintenance log. The sUAS will only be operated if all systems are 

operating per manufacture’s specifications and in a discrepancy free condition. 

E. Maintenance or repairs that may affect the sUAS operation or flight characteristics shall 

undergo a functional test flight when required in accordance with manufactures 

recommendations and Aerial Innovation & Inspection’s sUAS operating manual. This 

functional test flight shall be recorded in the sUAS’s records. If the functional test flight 

is completed successfully, the sUAS can be returned to service by the PIC. 

F. Aerial Innovation & Inspections shall follow the manufacturer’s sUAS maintenance, 

overhaul, replacement, inspection, and life limit requirements. When not provided by the 

manufacturer, aircraft maintenance, component overhaul, replacement, and inspection 

maintenance requirements shall be established and included in Aerial Innovation & 

Inspections’s sUAS operating manual. 

At a minimum the following regular maintenance will be met:

1. Batteries

2. Power plant(s) and Motors

3. Electronic Speed Controllers (ESC)

4. Propellers
5. Transmitters and Receivers

6. Actuators and Servos

Permissions and Permitting

A. All required permissions and permits shall be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, or other appropriate governmental 

agencies. 

B. At least three days before a scheduled operational flight, Aerial Innovation & Inspections

shall submit a written plan of activities to the local flight standards district office (FSDO) 

with jurisdiction over the area of the proposed flight. The 3-day notification may be 

waived with the concurrence of the FSDO.

The plan of activities will include at least the following:

1. Dates and times for all requested flights

2. Name and phone number of Aerial Innovation & Inspections Flight Operations

3. Name, certificate, phone number of PIC responsible

4. Make, model, and serial number of sUAS to be used

5. Statement from Aerial Innovation & Inspections that it will be operating on 

approved privately owned and operated property; the list of those who gave 

permission shall be made available to the inspector upon request.

6. Description of the flight activity, including maps or diagrams of any area over 

which flights will be conducted, the relationship of that area to any nearby city, 

town, etc., and the altitudes essential to accomplish the operation.

7. Signature of exemption-holder or representative

C. Documents required per 14 CFR §91.9 and §91.203 shall be readily available to the PIC 

any time the aircraft is in operation. These documents shall be made available to the 

Administrator or any law enforcement official upon request.
D. Aerial Innovation & Inspections shall obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations under 

this grant of exemption.

E. Aerial Innovation & Inspections shall obtain the consent of all persons involved in the 

operation and ensure that only consenting persons be allowed within 500 feet of the 

Operations Area. 

Operations

A. The sUAS shall not operate within 5 nautical miles of the geographic center of any 

airport as denoted on the current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. This letter of agreement 

with the airport management shall be made available to the Administrator upon request. 

B. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel. 

 The sUAS shall only operate within a pre-defined area of operations that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, poles, 

people, vehicles, shadows, glare, reflective surfaces, clouds, smoke, and terrain 

among other potential hazards.

C. Flights shall be conducted under day visual meteorological conditions (VMC) only.

 In addition, the sUAS shall 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.

 SUAS operations shall not be conducted at night, as defined in 14 CFR §1.1.

 Flights shall not be conducted under special visual flight rules (SVFR).

D. Flights shall be operated at an altitude at or below 200 feet AGL, as indicated by the 

procedures specified in Aerial Innovation & Inspection’s sUAS operating manual.

E. Groundspeeds will not exceed 42knots/49mph as indicated by the aircraft GPS.

F. The PIC shall be prohibited from operating the sUAS from any moving device or vehicle. 
G. The sUAS shall be operated within VLOS of the PIC.

•The PIC shall maintain VLOS without the aid of telescopes, cameras or other devices.

•The PIC will maintain VLOS with their own vision, which includes the use of 

eyeglasses or corrective lenses as specified on the PIC’s medical certificate. 

H. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc. 

I. Aerial Innovation and Inspections will require the PIC to have successfully completed a 

qualification process which will include ground and flight training.

J. The PIC’s primary responsibility while in flight is the safe operation of the sUAS.

K. Operations will be suspended within an active TFR’s (temporary flight restriction) should 

that TFR encompass the area of proposed operation.

Flight Time and Flight Durations

The PIC will commence the landing sequence when 25% battery life remains. The aircraft will 

automatically return to base when it triggers a low battery warning. 
Exemptions from which Regulations

Unless otherwise requesting an exemption, Aerial Innovation & Inspections, the PIC, and the 

sUAS shall comply with all applicable parts of 14 CFR including, but not limited to, Parts 45, 

47, 61, and 91.

Aerial Innovation & Inspections is requesting exemptions from the following Federal Aviation 

Regulations to the extent necessary to enable the requested sUAS operations for the reasons 

detailed below.

Relief sought from 14 CFR Aerial Innovation & Inspections’s Statement

21 Stated Below

61.113 (a) and (b) Stated Below

91.103 Stated Below

91.119(c ) Stated Below

91.121 Stated Below

91.151 (a) (1) Stated Below

91.405 (a) Stated Below

91.407 (a) (1) Stated Below

91.409 (a) (1) and (2) Stated Below

91.417 (a) and (b) Stated Below

14 CFR 21 – Requirements to Secure Airworthiness Certificates

1. Certificate exemptions should be given because size, weight, and operation areas of the 

sUAS meet the level of safety necessary for exemption under Section 333 of the Reform Act. 

2. FAA has the authority to exempt aircraft from airworthiness certificate requirements 

under the Act (49 U.S.C. § 44701 (f) and Section 333 of the Reform Act. 
14 CFR 61.113 (a) and (b) – Private Pilot Privileges and Limitations; Pilot in Command

1. Due to the fact that there are no standards for private or commercial sUAS operations, 

Aerial Innovation & Inspections requests to utilize at least private pilots with a third class 

medical in support of its own operations. 

2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along 

with the ability to physically manipulate the controls of the sUAS are the critical aspects of the 

requested operation. Aerial Innovation & Inspections feels this can be accomplished by a private 

pilot that has specific training on the sUAS aircraft and operates in accordance with the Aerial 

Innovation & Inspections’s sUAS Operating Manual, Federal Aviation Regulations, local, state 

and federal laws. 

3. The risks associated with the operation of a sUAS are so diminished from the level of risk 

associated with commercial aviation operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present 

level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

4. Equivalent or better safety levels will be achieved as there will be no human beings on 

board the sUAS aircraft. In addition, people will not be allowed in the area of operation.

5. FAA has authority to waive pilot requirements for commercial operations under 49 U.S.C 

§44701(f). 

14 CFR 91.103 – Preflight Action

1. The PIC shall perform a preflight inspection in accordance with the manufacturer’s 

recommendations and the Aerial Innovation & Inspection’s sUAS Operating Manual of the 

controller, ground control station and associated equipment prior to each flight to ensure it is free 

of all discrepancies. 

2. Equivalent safety levels will be met through preparation and compliance according to 

Aerial Innovation & Inspections’s sUAS Operating Manual; including but not limited to, weather 

reports, forecasts, wind, temperature, battery requirements and other information, relating to 

aircraft performance, gross weight, shall be considered. 

14 CFR 91.119(c) – Requirements for Minimum Safe Altitudes for Civil Aircraft Operation

1. The sUAS will be operated at or below 200 feet AGL. 

2. Aerial Innovation & Inspections shall obtain the consent of all persons involved in the 

operation and ensure that only consenting persons be allowed within 500 feet of the 

Operations Area. 
3. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel. 

4. Given the size, weight, speed, material, and operation of the sUAS aircraft, equivalent 

levels of safety will be achieved. 

14 CFR 91.121 – Altimeter Settings

1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out 

indication instead, so an exemption may be needed. 

2. The operator will achieve an equivalent level of safety as the sUAS uses AGL height 

from its initialization/takeoff point. 

14 CFR 91.151 (a) (1) – Fuel Requirements for Flights in VFR Conditions

1. The FAA has previously issued exemptions for fuel requirements in VFR conditions 

including Exemptions 2689F, 5745, 10673, and 10808. 

2. Aerial Innovation & Inspections feels an equivalent level of safety can be obtained by

terminating the flight prior to the following. 

Aircraft Fuel (Battery) Requirements

Based on battery capacities, no flight will commence with less than 90% battery life and must be 

returned for landing with no less than 25% battery life remaining. 

1. The DJI s1000+ has a second level of safety that is achieved through the use of an aircraft 

battery monitoring system. The aircraft system will alert the operator of low battery

voltage and return the aircraft to its take off location before battery capacity is depleted. 

All flights will terminate upon low battery warning.

2. Aerial Innovation & Inspections will not operate sUAS at night in accordance with 14 

CFR 1.1 

3. An equivalent level of safety will be achieved because these sUAS are limited in size, 

operational purposes of the sUAS, and shall only fly above approved privately owned and 

operated property at or below 200 feet AGL, it does not bear the same risks associated 

with this section’s requirements. 

14 CFR 91.405 (a) – Maintenance Required This section and Part 43 apply only to aircraft 

with an airworthiness certificate; therefore these sections will not apply.

In the absence of regulatory provisions dealing with sUAS operation for maintenance required. 

See Aerial Innovation & Inspections’s sUAS Operating Manual, Inspection Program and 

Manufactures Maintenance Recommendations for maintenance required.
1. Maintenance shall be accomplished by Aerial Innovation & Inspections, pursuant to the 

manufacturer’s recommendations and Aerial Innovation & Inspections’s sUAS Operating

Manual and Inspection Program.

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only. 

3. The Aerial Innovation & Inspections’s sUAS Operating Manual and Inspection Program 

details how to enter worked preformed in the maintenance log for scheduled, 

unscheduled maintenance or functional test flights that are performed. 

4. Aerial Innovation & Inspections shall only operate its sUAS with all systems functioning 

per manufactures specification in a discrepancy free condition. 

5. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

Aerial Innovation & Inspections and the Aircraft Manufacturer (DJI) are the most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition. This maintenance 

process allows for an equivalent level of safety to be achieved due to the limited size, scope and 

area of operations.

14 CFR 91.407 (a) (1) – Operation after Maintenance, Preventive Maintenance, Rebuilding 

or Alteration

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these 

sections will not apply.

In the absence of regulatory provisions dealing with sUAS operation after maintenance, 

preventive maintenance, rebuilding, alteration or functional test flights, Aerial Innovation & 

Inspections has developed requirements to address these topics. See Aerial Innovation & 

Inspections’s sUAS Operating Manual, Inspection Program and Manufactures User Guides.

1. Maintenance will be accomplished by Aerial Innovation & Inspections pursuant to the 

manufacturer’s recommendations and Aerial Innovation & Inspections’s sUAS Operating 

Manual and Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only.

3. Functional test flights will be performed by the PIC when required, the sUAS shall only

be returned to service when this functional test flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area. 

4. The Aerial Innovation & Inspections’s sUAS Operating Manual details how to enter in 

the maintenance log scheduled and unscheduled maintenance or functional test flights 

that are performed. 
5. Aerial Innovation & Inspections shall only operate its sUAS with all systems functioning 

per manufactures specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

Aerial Innovation & Inspections and the Aircraft Manufacturer (DJI) are the most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition. These maintenance 

procedures allow for an equivalent level of safety to be achieved due to the limited size, scope 

and area of operations.

14 CFR 91.409 (a) (1) and (2) – Inspections This section and Part 43 apply only to aircraft with 

an airworthiness certificate; therefore these sections will not apply.

In the absence of regulatory provisions dealing with sUAS inspections, Aerial Innovation & 

Inspections has developed requirements to address this topic. See Aerial Innovation & 

Inspections’s sUAS Operating Manual, Inspection Program and the Manufactures User Guides.

1. Maintenance will be accomplished by Aerial Innovation & Inspections pursuant to the 

manufacturer’s recommendations and Aerial Innovation & Inspections’s sUAS Operating 

Manual and Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully

accomplished by trained personnel only. 

3. The Aerial Innovation & Inspections’s sUAS Operating Manual details how to enter into 

the maintenance log all inspections that are performed. 

4. Functional test flight will be performed by the PIC when required after inspections, the 

sUAS shall be returned to service when the flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area. 

5. Aerial Innovation & Inspections shall only operate its sUAS with all systems functioning 

per manufactures specification in a discrepancy free condition. 

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

Aerial Innovation & Inspections and the Aircraft Manufacturer (DJI) are the most familiar with 

the aircraft and are best suited to maintain the aircraft in an airworthy condition. These 

maintenance inspections allow for an equivalent level of safety to be achieved due to the limited 

size, scope and area of operations.

14 CFR 91.417(a) and (b) – Maintenance Records This section and Part 43 apply only to 

aircraft with an airworthiness certificate; therefore these sections will not apply.
In the absence of regulatory provisions dealing with sUAS maintenance records, Aerial 

Innovation & Inspections has developed requirements to address this topic. See Aerial 

Innovation & Inspections’s sUAS Operating Manual and Inspection Program.

1. Maintenance will be accomplished by Aerial Innovation & Inspections pursuant to the 

manufacturer’s recommendations and Aerial Innovation & Inspections’s sUAS Operating 

Manual. 

2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance recording 

keeping will be performed by trained personnel and entered in the respective aircraft 

maintenance log at completion of each event. The Aerial Innovation & Inspections’s 

sUAS Operating Manual details how entries are to be made in the aircraft maintenance 

log for scheduled and unscheduled maintenance or functional test flights that are 

performed. 

3. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

Aerial Innovation & Inspections and the Aircraft Manufacturer (DJI) are the most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition. These maintenance

records allow for an equivalent level of safety to be achieved due to the limited size, scope and 

area of operations.