May 20, 2015

Administrator 

Federal Aviation Administration 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., S.E. 

Washington, DC 2059 

Re: Exemption Request under Section 333 of the FAA Reform Act

Pursuant to the FAA Modernization and Reform act of 2012, Public 

Law 112-95 (P.L. 112-95), and 14 CFR Part 11 §333, AirPix, LLC , 

hereby seeks and applies for an exemption to the Federal Aviation 

Regulations (FARs) to allow the operation of Small Unmanned Aircraft 

Systems (sUAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA) under the conditions and limitations set 

forth in this petition.

The requested exemption would permit AirPix, LLC to operate small, 

unmanned aircraft system (sUAS) for the purpose of providing an 

aerial photography and survey service to private consumers. The 

areas of use include photogrammetric surveys in the real estate, 

mining, construction, and agriculture industries.

Approval of the AirPix, LLC exemption would enhance air safety and 

fulfill the responsibility of the Secretary of Transportation to “...

establish requirements for the safe operation of such aircraft systems 

in the national airspace system”

Sincerely yours,

Peter J. Dailey, PhD

Director of Flight Operations, AirPix, LLC

304.421.1472

dr.pete@airpixus.com

Dr. Pete Dailey

140 Sunset Drive

Charleston, WV

25301

AIRPIX, LLC
AirPix, LLC 2 of 17

1. Summary of the exemptions requested 

AirPix, LLC seeks relief from specific aspects of flight regulations that 

can not reasonably be applied to small unmanned aircraft, and relief 

from commercial restrictions applied to airmen holding private or sport 

ratings engaged in flying unmanned aircraft for compensation or hire. 

2. Relief sought 

AirPix, LLC wishes to operate small Unmanned Aircraft Systems 

hereafter sUAS, for commercial purposes including, but not limited to: 

photogrammetry; visual and photographic industrial or commercial 

inspection; aerial data collection, agricultural assessments; with 

subsequent analyses.

Relief from the following rules is sought as commercial use of sUAS is 

currently prohibited by law unless that commercial use is performed 

under a grant of exemption. The relief sought addresses the 

commercial use of unmanned fixed and rotary wing aircraft under 55 

pounds gross takeoff weight. 

Application is made for exemption from or modification to the following 

rules: 

14 CFR § 45.23 (b) Display of marks; general.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally 

certificated aircraft, the operator must also display on that aircraft near each entrance to the 

cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, 

the words “limited,” “restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.
AirPix, LLC 3 of 17

AirPix, LLC seeks relief from 14 CFR § 45.23 (b) to allow sUV 

registration markings to be displayed in a size proportional to the 

size of the sUVS in an area visible from the outside of the sUV. 

14 CFR § 45 (a) and (b)1 and 3 Size of marks. 

(a) Except as provided in paragraph (f) of this section, each operator of an aircraft must 

display marks on the aircraft meeting the size requirements of this section. 

(b) Height. Except as provided in paragraph (h) of this part, the nationality and registration 

marks must be of equal height and on— 

(1) Fixed-wing aircraft, must be at least 12 inches high...

 (3) Rotorcraft, must be at least 12 inches high...

AirPix, LLC seeks relief from 14 CFR § 45 (a) and (b)1 and 3 to 

allow registration marks to be displayed on the aircraft 

proportional to the size and space available on the sUAS. 

14 CFR §61.101 e (4) (5) Recreational pilot privileges and 

limitations. 

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not 

act as pilot in command of an aircraft— 

(4) For compensation or hire; 

 (5) In furtherance of a business;

AirPix, LLC seeks an exemption from 14 CFR §61.101 e (4) and 

(5) rule to allow airmen holding recreational pilot privileges to act 

as a Pilot In Command (PIC) of an sUAS for compensation or for 

hire in furtherance of a business using small unmanned aircraft. 

14 CFR §61.113 (a) Private pilot privileges and limitations: Pilot in 

command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as pilot in command of an aircraft.
AirPix, LLC 4 of 17

AirPix, LLC seeks an relief from 14 CFR §61.113 (a) to allow a 

Pilot in Command (PIC) of an sUAS holding a private pilot 

airman’s certificate to fly an sUAS for compensation or hire. 

14 CFR §61.315(a)(c) 2, 3 What are the privileges and limits of my 

sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport aircraft, 

except as specified in paragraph (c) of this section.

(c) You may not act as pilot in command of a light-sport aircraft: 

(2) For compensation or hire. 

 (3) In furtherance of a business.

AirPix, LLC seeks an exemption from 14 CFR §61.315(a) and (c) 2 

and 3 to allow a PIC holding a sport pilot airman’s certificate to 

fly an sUAS for compensation or hire. 

14 CFR § 91.7(a) Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

14 CFR § 21 Certification procedures for products and parts, subpart H - Airworthiness 

Certificates; part 35 Airworthiness Standards: Propellers; part 36 Noise Standards; part 43 

Maintenance, Preventive Maintenance, Rebuilding and Alteration.

AirPix, LLC seeks relief from 14 CFR § 91.7(a) and 14 CFR § 21 as 

small unmanned aircraft, considering the size, weight, speed and 

limited area for their operation; and meeting the statutory criteria 

outlined in Section 333 of Public Law 112-95 in reference to 49 

USC § 44704; and that the Secretary of Transportation has 

determined that aircraft of the type to be used by AirPix, LLC 

meet the conditions of Section 333; and that this class of 

unmanned aircraft do not require associated certification and 

testing by persons qualified as described under part 43. 
AirPix, LLC 5 of 17

14 CFR § 91.103 Preflight action. 

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information:

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values 

of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

AirPix, LLC seeks an exemption from 14 CFR § 91.103(b)(2) in the 

event that an sUAS may be engaged in aerial photography on or 

around an airport, using the airport runways for conducting 

sUAS flight operations. An illustration of this occurrence would 

be similar to assessing a recent runway slope failure at Yeager 

Airport, in Charleston, West Virginia (CRW). The relief sought 

would exempt the sUAS PIC from knowledge of runway lengths, 

elevations, etc of the airport being surveyed when used for sUAS 

takeoffs and landings, as this knowledge is not relevant for sUAS 

operation. 

14 CFR § 91.109: Flight instruction; Simulated instrument flight 

and certain flight tests. 

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used 

for flight instruction unless that aircraft has fully functioning dual controls. However, instrument 

flight instruction may be given in an airplane that is equipped with a single, functioning throw 

over control wheel that controls the elevator and ailerons, in place of fixed, dual controls, 

when— 

(1) The instructor has determined that the flight can be conducted safely; and 

(2) The person manipulating the controls has at least a private pilot certificate with appropriate 

category and class ratings.
AirPix, LLC 6 of 17

AirPix, LLC seeks an exemption from 14 CFR § 91.109 requiring 

dual controls for training and instructional flights when the PIC 

conducting the training has determined that the area designated 

for training can safely accommodate the anticipated training and 

instruction. 

Relief from 14 CFR § 91.119(c); Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

AirPix, LLC seeks relief from 14 CFR § 91.119(c) minimum safe 

altitude. AirPix, LLC anticipates that flight operations shall be 

conducted over private or controlled-access property with the 

permission of the property owners or authorized representatives. 

Relief from 14 CFR § 91.121: Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating — 

(1) Below 18,000 feet MSL, to— 

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport 

or an appropriate altimeter setting available before departure; or...

AirPix, LLC seeks an exemption from 14 CFR § 91.121 as the 

anticipated sUASs perform a self-calibration and zero of the 

onboard barometer on power up, providing barometric 

measurement of altitude above ground level. Determination of 

altitudes AGL have greater applicability for maintaining the 
AirPix, LLC 7 of 17

requested 500 foot AGL flight envelop during line-of-sight flight 

flight envelope restrictions. 

Relief from 14 CFR § 91.151: Fuel requirements for flight in VFR 

conditions

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed— 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

AirPix, LLC seeks an exemption from 14 CFR § 91.151 as the use 

of sUAS are in close proximity to the launch and landing areas; 

that anticipated flight times are shorter than the margin of safety 

in § 91.151; that failsafe actions programmed into the anticipated 

class of sUAS flight controllers can provide a margin of public 

safety without excessive reserve power; that the anticipated 

class of sUAS do not carry flammable fuel in the event of a 

crash; and that unmanned aircraft by definition have no flight 

crew or passengers who's safety benefits from fuel reserves. 

Relief from 14 CFR § 91.405: Maintenance required.

Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter;

AirPix, LLC seeks relief from 14 CFR § 91.405 as sUAS pose no 

safety hazard to pilot, crew, or passengers; that maintenance and 

inspection to this class of aircraft does not require the level of 

sophistication or knowledge required of manned aircraft. 
AirPix, LLC 8 of 17

Relief from 14 CFR § 91.407: Operation after maintenance, 

preventive maintenance, rebuilding, or alteration. 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless— 

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter; and 

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter 

has been made.

AirPix, LLC seeks an relief from 14 CFR § 91.407 as the skill and 

sophistication required of person authorized under §43.7 is not 

required for sUAS; that the maintenance record for sUAS be 

limited to the requirements of §43.9 (a) 1-4 as sufficient as it is 

anticipated that the sUAS will not interact with ATC, the 

barometric system of an sUAS does not have the sophistication 

of a manned aircraft. 

Relief from 14 CFR § 91.409 : Inspections

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had— 

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter; or 

 (2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.

AirPix, LLC seeks an relief from 14 CFR § 91.409 as previously 

noted person’s authorized for part 43 inspections have a level of 

knowledge and skill not required for an sUAS due to simpler 

systems, easy access for inspection, and no requirement for 

airworthiness as specified in part 21. 

Relief from 14 CFR § 91.417: Maintenance records. 

(a) Except for work performed in accordance with §91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 
AirPix, LLC 9 of 17

(1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include— 

 (i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and

 (ii) The date of completion of the work performed; and 

 (iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

 (ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

 (iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft and its appliances 

are maintained. 

 (v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety directive number 

and revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

 (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, propellers, and 

appliances.

AirPix, LLC seeks relief from 14 CFR § 91.417 in that components 

such as propellers, motors, airframe do not have a service life 

equivalent to manned aircraft; that there is no service life data by 

which to judge mean time to failure; that these components are 

inexpensive and easily replaced obviating the need for 

maintenance details required in § 91.417. 

3. Unmanned Aircraft Systems and Procedures 

AirPic, LLC anticipates the use of the following sUAS platforms, flight 

management systems (FMS), and ground control stations (gcs) during 

flight operations.
AirPix, LLC 10 of 17

Fixed wing aircraft 

SenseFly eBee (https://www.sensefly.com/drones/ebee.html) using 

senseFLY eMotion ground control software. 

3D Robotics Aero-M (http://3drobotics.com/kb/aero-m/ ) using the 

Pixhawk flight management system (http://3drobotics.com/kb/

pixhawk/) flight management system. 

RMRC Anaconda airframe (https://dl.dropboxusercontent.com/u/

1459803/RMRC%20Anaconda%20Manual.pdf) with 3D Robotics 

Pixhawk flight management system (http://3drobotics.com/kb/

pixhawk/). 

Rotary wing aircraft 

3D Robotics Iris and Iris+ multirotor airframe. Operations manual 

(http://3drobotics.com/wp-content/uploads/2015/02/IRIS-PlusOperation-Manual-vH-web.pdf) and flight checklist (http://

3drobotics.com/wp-content/uploads/2015/04/IRIS-Plus-FlightChecklist-vB.pdf), and 3D Robotics Pixhawk flight management 

system (http://3drobotics.com/kb/pixhawk/).

3D Robotics X8 and X8+ multi rotor operations manual (http://

3drobotics.com/wp-content/uploads/2015/04/X8-Operation-ManualvC.pdf) and flight checklist (http://3drobotics.com/wp-content/

uploads/2015/04/X8-Checklist-vB.pdf), and 3D Robotics Pixhawk

flight management system (http://3drobotics.com/kb/pixhawk/).

Future airframes not covered by any grant of exemption to these rules 

will be filed by amendment and registration prior to use.

Preflight inspection will be performed following the manufacture 

provided flight manual and support materials. Flight operations and 

failsafe action will be programmed to provide for the safety of nonparticipating persons on the ground.

3D Robotics Solo using the Pixhawk flight management system 

(http://3drobotics.com/solo/ and http://3drobotics.com/kb/pixhawk/) 
AirPix, LLC 11 of 17

Payload 

Anticipated onboard photographic equipment includes, but is not 

limited to the following classes of cameras.

GoPro Hero 3 and Hero 4 series cameras (http://shop.gopro.com/

cameras), with a weight of approximately 150 grams.

Mobius Action Cam (https://www.mobius-actioncam.com/), with a

weight of approximately 40 grams.

Canon Powershot ELPH and SX series of cameras, with a weight of 

approximately 350 grams.

Ground Control Station (GCS) 

Manual Flight control 

Pre-programmed automated flight operations maybe over ridded, 

cancelled, or directed to land by the PIC from an FCC approved radio 

control link with the sUAS such as (http://www.frsky-rc.com/product/

pro.php?pro_id=137 ).

Mission Planner GSC software ( Wiki at URL http://

planner.ardupilot.com/) and/or Tower (http://3drobotics.com/kb/

tower-overview/) will be used to program and monitor flight 

operations. Data link between the sUAS and GSS will be through 

FCC approved data radio link including but not limited to the 3DR 

Radio V2 (http://3drobotics.com/wp-content/uploads/2013/10/3DRRadio-V2-doc1.pdf).

Failsafe Actions: Fixed Wing Failsafe Modes 

(Reference: http://plane.ardupilot.com/wiki/arduplane-setup/apmsfailsafe-function/)

• Throttle Failsafe

• GCS Failsafe

• Battery Failsafe
AirPix, LLC 12 of 17

Failsafe Actions: Rotary Wing Failsafe Modes 

(Reference: http://copter.ardupilot.com/wiki/common-advancedconfiguration/)

• Radio Failsafe

• Battery Failsafe

• GCS Failsafe

• GPS Failsafe

• Extended Kaman Filter (EKF) and Direction Cosine-matrix (DCM) 

Failsafe

Failsafe Actions, all sUAS 

Each sUAS FMS

4. Public benefit of the proposed commercial application of sUAS

Manned flight has a greater statistical risk to human life, for both the 

flight crew and to the public from aircraft carrying flammable fuel. 

These risks are avoided by the use of small unmanned aerial 

systems. 

a. The use of sUAS mitigates hazards to the public by reduced 

exposure and noise from manned aircraft and eliminating 

flammable and/or toxic fuels from flight operations. 

b. The use of sUASs reduces the cost of obtaining environmental, 

industrial, civil structure, and agricultural data, which benefits 

producers and consumers through increased hazard awareness 

and reduced dependance on the need for a human to be put in 

harms way to inspect civil structures or to obtain data for 

determining material volumes of aggregates, coal, or ore. 

c. Environmental impacts are reduced through eliminating sources of 

hydrocarbon emissions, volatile fuels, and physical exposure to 
AirPix, LLC 13 of 17

the relatively large number of manned aircraft performing in 

similar roles. 

d. Small Unmanned Aerial Systems are capable of operation within 

airspace unreachable by manned aircraft. Access limitations due 

to the proximity of civil structures; whether to persons on the 

ground in close proximity or exposure to hazards to the flight crew 

during operations of manned aircraft. 

e. The sUAS is of particular benefit in those areas where public 

health and welfare concerns exist and an immediate response is 

necessary to address those concerns.

Public Benefit Example Use Case

The useful benefit of unmanned aerial vehicle systems to the public 

health and welfare was a recent partial hillside failure at the end of a 

runway at Yeager Airport (CRW), included by referenced in the 

included photographs taken by a local news service. 

The mass of earth and rock continued to move after the initial failure. 

The failure created an immediate public safety concern for those with 

residences below the failed runway. the continued slope movement 

limited access for surveyors and geotechnical engineers to determine 

the quantity of mass of material movement accurately assess the 

continued threat to public safety. The unstable land mass prevented a 

survey traversing the affected area, as the instability of the slope 

would place surveyors in harms way.
AirPix, LLC 14 of 17

Addition examples of commercial aerial photography include the 

inspection of natural gas transmission lines. The NTSB has included 

natural gas pipeline safety on its 2014 Most Wanted List (http:// 

www.ntsb.gov/safety/mwl/Documents/

2014/05_MWL_PipeSafety.pdf).

The December 11, 2012, pipeline rupture that occurred west of I-77 

near Sissonville, West Virginia is a significant example of the need for 

enhanced inspection. Gas pipelines are presently inspected from 

manned rotary winged aircraft, and subject manned aircraft flying at 

low altitudes to intersecting power transmission lines and other civil 

structures. These obstructions are a constant and immediate danger 

to flight crews as described in the UPAC Safety Guide for Helicopter 

Operators (https://www.rotor.com/portals/1/committee/ 

upac_guide.pdf). 

5. Safety not adversely affected: 

AirPix, LLC will mitigate the safety provisions of the grant of exception 

through the following actions. 

a. Airframes used by AirPix, LLC will be registered and marked in 

accordance with § 47 subparts A and B 47, with reasonably sized 

markings defined by FAA in any grant of exemption requested in 

this petition. 

b. Airframes will at least comply with the maintenance and inspection 

requirements of the manufacturer in their published literature and 

at best be established for the various sub-systems based on flight 

time and component history. Flight time and maintenance records 

will be kept in a maintenance log for each registered sUAS 

aircraft.

c. All repair and maintenance work will be conducted and approved 

by AirPix director of flight operations. Qualification of personnel 

will be determined through demonstration of disassembly, 

inspection, and testing of airframe components, motor 
AirPix, LLC 15 of 17

assemblies, autopilot and navigation sensors, with reassembly 

and programming of autopilot. 

d. Each sUAS will be required to undergo a non-commercial test 

flight after: replacement of major components; after flight 

controller firmware updates; after ground station software 

updates. 

e. A successful flight test will consist of program action by the 

autopilot demonstrating: 

1. Three autonomous landings. 

2. Successful autonomous course navigation to a minimum of 

five pre-programmed waypoints in the sUAS autopilot. 

3. Successful demonstration of failsafe actions for: 

a. Loss of command radio signal. 

b. Loss of ground control station (GCS) communication. 

c. Exceeding geofence (radius and elevation) envelope. 

d. Low power. 

When required by mission task loading the PIC may, at his/her 

discretion, elect to augment flight operations with an individual acting 

as a visual observer (VO). The VO’s duties consist of maintaining 

unaided visual contact with the sUAS while scanning the immediate 

area for manned aircraft while maintain verbal communication with the 

PIC. The VO will be medically qualified to maintain unaided visual line 

of sight, by possessing minimally a government issued driver license 

or a FAA Class 2 or 3 medical certificate. 

The sUAS PIC will, in every instance, give way to manned aircraft, 

and will safely terminate sUAS flight operations upon observation of 

manned aircraft in close proximity to the sUAS operation area.
AirPix, LLC 16 of 17

Any AirPix, LLC personal operating as Pilot In Command will: 

1. Possess an Airman Certificate issued under 14 CFR § 61. 

2. Possess a government issued driver license or a Second or Third 

Class medical certificate issued under 14 CFR § 67 commiserate 

with the Airman Certificate issued under § 61 commiserate with 

the PIC’s airman rating.

3. Have accumulated a total of 30 hours of flight experience with an 

sUAS rotorcraft or fixed-wing airframe of the type and model 

described in this petition. The PIC will have demonstrated a 

minimum of 3 takeoffs and landings with a sUAS of the 

configuration and weight considered under this petition within the 

prior 90 days.

4. The AirPix, LLC PIC will ensure flight operations safety by:

a. Conducting a pre-flight inspection (including ground control 

station, if any) of the sUAS and a perform a safety risk 

assessment of the intended area of operation prior to each 

flight.

b. Conducting flight operations in daylight VFR conditions. 

c. Ensure the sUAS attains speed no greater than 87 knots (100 

mph) 

d. Ensure flight operation altitudes will be no greater than 400 feet 

above ground level.

e. Ensure flight operations do not encroach into Class B, C or D 

airspace, or published approach, SID or STAR, or take place 

within 5 nautical miles of an airport without notification and/or 

contact with the nearest Flight Standards District Office 

(FSDO). The nearest FSDO to the intended operational area 

will be notified at least 3 days prior to allow for the publication 

of a Notice To Airmen (NOTAM) stating the area and times of 
AirPix, LLC 17 of 17

sUAS flight operations from the nearest radio navigation aid 

within 10 nm of the intended flight operations. 

f. Ensure flight operation not be made near persons as required 

in 14 CFR § 91.119 and not over persons on the ground 

without prior permission.

5. During flight operations, be in possession of: 

1. Airman’s Certificate 

2. Manufacturers’ user manuals

3. Personal logbook 

4. sUAS flight and maintenance logbooks 

5. Medical certificate or driver license 

6. Copy of the FAA grant of exemption.

7. AirPix Flight Operations and Procedures Manual (FOPM) 

and Aircraft Flight Manuals (AFM). 

6. Ensure that for battery powered propulsion using Lithium Polymer 

(LiPo) batteries, flight planning will not intentionally deplete more 

than 76% of the battery’s nominal charge voltage to minimize the 

risk of battery overheating. 

7. Ensure that incidents adverse to persons or property will be 

reported to the nearest FSDO within 24 hours of occurrence.

8. Ensure observation of any applicable local FSDO requirements or 

restrictions.

9. sUAS will use FCC approved radios compliant for command & 

control of the aircraft with well-defined and tested lost data link 

procedure.