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 Moder nization 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 Sy stems (sUAS) equipped to conduct commercial aerial photography and videograph y for agricultural ins pection, construction inspection, real estate, and other commercial operations hereb y 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 an d under the conditions outlined herein or as may be established by

the FAA as required b y S ection 333. The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS may operate safel y in the national airspace s ys tem (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 t ypes of sUAS as a result of their size, weight, speed, operational capability, proximity to airports and populated ar eas, 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 safel y i n the NAS, the Secretary “shall establish requireme nts for the safe operation of such aircraft.” The granting of this exemption request will p rovide immediate benefit to the agricultural, construction and real estate industries by authorizing highl y controlled sUAS operations at or below 200 feet above gro und level (AGL), in line of sight (VLOS) of an FAA Certificated Airline Transport Pilot during daylight hours and above controlled privately owned and operated propert y. Aerial Innovation & Inspection’s sUAS shall weigh less than 55 pounds including the payl oad. They will operate at no more than 42 knots (49 mph) and have the capability to hover, and move verticall y and horizontally simultaneousl y. Operations would be conducted above privatel y owned and operated properties, with the consent of the owner/op erator. Aerial Innovation & Inspection’s operations will be performed b y aprofessional pilot; th is pilot will insure that the sUAS will not create any hazard to users of the

national airspace s ys tem 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: aerialinnovationandi nspections@gmail.com Address: 12195 Waterfowl L ane

Chardon, Ohio 44024 Aerial Innovation & Inspections appreciates your consideration in this application. Best Regards, Christopher A. Sabel President of Aerial Innovation & Inspections
In cluded in this Exemption L etter:

 Operations  Regulations for which exemptions are requested To follow this Exemption L etter and/or on request:

 Aerial Innovation & Inspections ’s Flight Operations Manual and Pilot Checklist  A2 Flight Control Sy stem 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 photograph y of real estate propert y as well as other sectors without the use of full size aircraft. They are more efficient, less costly , and environmentally

friendl y. Noise and emissions will be reduced, as well as imparting minimal disturbance to persons on the ground.
**Construction Sites** Perform inspections and aerial survey s of construction sites and structures without the need to erect dangerous scaffolding or expensive cranes and mi nimize the danger to human life and property. **Agricultural Inspection** Through real time crop management, sUAS will help identify better crop planning and rotation strategies, irrig ation 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 assembl y 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 an y aircraft, and will alway s hold safet y above an y commercial endeavor. Chris will operate the sUAS in accordance with any applicable FAR’s and local, state , an d 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 DJ Is 1000 + s UAS multi

- rotor aircraft for the purpose of obtaining photograph s and videos for Real Estate, Construction and Agricultural In spection and other commercial endeavors. **DJI s 1000+** Model DJI s1000+ N/A Weight (Battery

Included) 6kg

- 11k g 13.22lbs

- 24.25lbs Battery 22.2v 10000mah

- 32 000mah 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 41x18x21 inches**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 DJIs1000+, which weighs less than 55 pounds including payload.
B. The radio frequency

spe ctrum used for operation and control of the sUAS will comply w ith the Federal Communi cations Commis s ion (FCC) or other appropriate government oversight agenc y requirements. The DJ I 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 Gy roscopes (IRS/IRU/Accelerator/MEMS Gy roscopes).
E. The sUAS is equipped with a compass (Magnetometer/Heading Source).
F. The sUAS is equipped with a Global Positioning Sy stem (GPS) guidance sy stem.
The DJ Is 1000+ is equipped with several fail safe features. Multi

- Rotor motor fail protection. In the event of a moto r 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. S hould it lose communications or lose it s GPS signal, it will return home or to a pre - determined location within the area of oper ations 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 curr ent regulatory

structure because the proposed operations represent a safety enhancement to the already s afe 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 (PI C) will pos s ess at a minimum, a private pilot certificate and current third

- class medical certificate.

 The PI C shall also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PI C is rated on their pilot certificate.  The PI C shall be trained in the operatio n of the specific make and model of the sUAS being piloted and successfull y completed all training required.  The PI C 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 tim e as a sUAS pilot and at least five hours logged as a sUAS pilot with a similar sUAS ty pe (multi

- rotor/helicopter/airplane). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement.  For c urrency

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 day s. 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 PI C must operate the sUAS with appropriate distance from non

- participants in accordance with 14 CFR §91.119. C. The PI C shall alway s 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 mai ntained at all times, hazards are properl y identified, and that all regulatory perimeters can be met.

### Maintenance

A. The DJ I s1000+ will be maintained in acc ordance 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 re cords will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. C. Aerial Innovation & Inspections will comply with all manufacturer Safet y/ Service Bulletins or equivalent pertaining to the DJIs 1000+. D. The PI C shall perform a preflight inspection of the sUAS, controller, and ground control station prior to each flight to ensure it is operationa l 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 sy stems are operating per manufacture’s specifications and in a discrepanc y 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 successfull y, the sUAS can be r eturned to service b y the PI C. 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 & Inspection s’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. Propellers5. Transmitters and Receivers 6. Actuators and Servos 

### Permissi **ons and Permitting**
A. All required permissions and permits shall be obtained from territorial, state, county or city jurisdictions, including local law enforcement, or other appr opriate governmental agencies. B. At least three days before a schedul ed operatio nal 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, c ertificate , phone number of PI C 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 privatel y owned and operated property; the list of those who gave permission shall be made available to the inspector upo n 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 nearb y city , town, etc., and the altitudes essential to accomplish the operation.

7. Signature o f exemption

- holder or representative

C. Documents required per 14 CFR §91.9 and §91.203 shall be readil y available to the PI C any time the aircraft is in operation. These documents shall be made available to the Administrator or an y 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 obtai n the consent of all persons involved in the operation and ensure that only consenting persons be allowed within 50 0 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 an d non

participating personnel.

 The sUAS shall only

operate within a pre

- defined area of operatio ns that shall be thoroughl y inspected b y the PI C 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 visu al 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 PI C.  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 p rocedures specified in Aerial Innovation & Insp ection’s sUAS operating manual. E. Groun dspeeds will not exceed 42knots/49mph as indicated b y the aircraft GPS. F. The PI C shall be prohibited from operating the sUAS from any moving device or vehicle.G. The sUAS shall be operated within VL OS of the PI C.

•T he PI C shall maintain VLOS without the aid of telescopes, cameras or other devices. •The PI C will maintain VLOS with their own vision, which includes the use of eyeglasses or corrective lenses as specified on the PI C’s medical certificate. H. The sUAS s hall remain clear and yi eld 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. Ae rial Innovation and Inspections will requ ire the PI C to have successfull y completed a qualification process which will include ground and flight trai ning. J. The PI C’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 PI C will commence the landing sequence when 25% battery life remains. The aircraft will automatically

return to base when it trig gers a low battery warning.

### Exemptions from which Regulations

Unless otherwise re questing an exemption, Aerial Innovation & Inspection s , the PI C, 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 & Inspection s 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 & Inspection**  **s ’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 exemp tion 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 an d 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 phy sically

manipulate the controls of the sUAS are the critical aspects of the requested operation. Aerial Innovation & Inspectio ns 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 & Inspection s ’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 op eration. 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 PI C shall perform a preflight inspection in accordance with the manufacturer’s recommendations and the Aerial Innovation & In spection’s sUAS Operating Manual of the controller, ground control station and associated equipment prior to each flight to ens ure 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 we ight, 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 non

participating personnel. 4. Given the size, weight, sp eed, 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 b e needed. 2. The operator will achieve an equivalent level of safety as the sUAS uses AGLheight from its initialization/takeoff point. **14 CFR 91.151 (a) (1)**

**– Fuel Requirement**  **s for Flights in VFR Conditions** 1. The FAA has previously issued exemptions fo r 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. **Aircr aft 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 DJ I s1000+ has a second level of safety that is achieved through the us e of an aircraft battery monitoring s ys tem. The aircraft s ys tem 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 priv ately 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 onl y to aircraft with an airworthiness certifi cate; therefore these sections will not apply
. In the absence of regulatory provisions dealing with sUAS operation for mai ntenance required. See Aerial Innovation & Inspections’s sUAS Operating Manual, Inspection Program and Manufactures Maintenance Recomm endations for maintenance required.1. Maintenance shall be accomplish ed 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 accomplis hed b y trained personnel onl y. 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 te st 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 b y Federal Aviation Regulations. Aerial Innovation & Inspections and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and be st 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, Preve**  **ntive Mainte nance, Rebuilding**  **or Alteration** This section and Part 43 apply onl y to aircraft with an airworthiness certificate; therefore these sections will not apply
. In the absence of regulatory provisions dealing with sUAS operation after maintenance, p reventive 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 U ser 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 b y trained personnel onl y.
3. Functional test flights will be performed b y 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 safel y 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 f unctional 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 ba se for operation for the life of the aircraft or as required b y Federal Aviation Regulations. Aerial Innovation & Inspections and the Aircraft Manufacturer (DJ I) 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 91.40 9 (a) (1) and (2)** 

**– Inspections**  This section and Part 43 apply onl y to aircraft with an air worthiness 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 b y trained personnel onl y. 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 b y the PIC when required after inspections, the sUAS shall be returned to service when the flight is successfull y completed. If a mechanical issue ari ses the sUAS can land safel y or be recovered within the Operations Area. 5. Aerial Innovation & Insp ections 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 b y Federal Aviation Regulations. Aerial Innovation & Inspections and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and are best suited to maintain the aircraft in an airworth y 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 onl y 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 th is 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 O perating 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 Innovat ion & 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 b y Federal Aviation Regulations. Aerial Innovation & Inspections and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. These maintenance records allow for an equivalent level of safety to be achieved due to the limited size, scope and area of operations.