June 9, 2015

Exemption No. 11794

Regulatory Docket No. FAA–2015-0305

Mr. Tony Portelli 

ATAC Global LLC

8352 W. Warm Springs Road

Las Vegas, NV 89113

Dear Mr. Portelli:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on February 9, 2015,

1

you petitioned the Federal 

Aviation Administration (FAA) on behalf of ATAC Global LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography and inspection.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI S900.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

 

1 On May 20, 2015, the petitioner responded to the FAA’s request for information.
2

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

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

14 CFR part 21 and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, ATAC Global LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

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

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Conditions and Limitations

In this grant of exemption, ATAC Global LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI S900 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 
4

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must 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.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 
5

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
7

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

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

Sincerely,

John S. Duncan

Director, Flight Standards Service

Enclosures
ATAC	Global,	LLC FAA	Exemption	Request

Letter dated February 4, 2015, ATAC Global LLC(POC Tony Portelli) 8352 W. Warm 

Springs Rd, Las Vegas, Nevada, 89113, petitioned the Federal Aviation Administration 

(FAA) for an exemption from part 21 and §§ 45.23(b), 61.113(a) and (b), 91.7(a), 

91.9(b)(2), 91.103, 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of the Federal 

Regulations (14 CFR). The proposed exemption would allow ATAC Global to operate its 

unmanned aerial system (UAS) for aerial photography and inspection, including but not 

limited to operations: (1) over land, waterways, and oceans; (2) operation over and/or in 

nonrestricted National Parks, National Forests, and non-navigable airspace using 

nonintrusive recording devices; and (3) operation in otherwise unrestricted U.S. States 

and Territories. All proposed operations would be conducted under controlled conditions 

in airspace that is: (1) limited, (2) predetermined, and (3) access controlled 

ATAC Global requests relief from the following regulations: 

FAA rule which we seek exemption below in bold:

Part 21 prescribes the procedural requirements for issuing and changing design 

approvals, productions approvals, airworthiness certificates, and airworthiness 

approvals. 

AFS-14-373-E 

Section 45.23(b) prescribes that 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. 

ATAC Global description of the exemption we seek below:

ATAC Global UAS will have no airworthiness certificate; an exemption may be needed 

from 14 CFR § 45.23 as the UA will not have a cockpit or cabin. Given the size of the 

UAS, the 2-inch lettering will be impossible. The petitioner asserts that an equivalent 

level of safety will be provided by having the UA marked with the word “experimental” 
on the fuselage in compliance with 14 CFR § 45.29(f), in a location where the pilot, 

observer, and others working with the UA will see the identification. 

FAA rule which we seek exemption below in bold:

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a 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. 

(b) a private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

ATAC Global description of the exemption we seek below:

Given the size, weight, and speed of the UA, as well as the location where it is operated 

and the fact that the UAS will not carry a pilot or passengers on board, as a result the 

proposed operations can achieve a very high level of safety, also, additional safety 

measures are in place by requiring PIC to complete 50 hours of onsite with an additional 

10 hours of online instruction before becoming operational. Also, UAS flights will be 

limited to below 500feet AGL.

FAA rule which we seek exemption below in bold:

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a 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. 

(b) a private pilot may, for compensation or hire, act as pilot in command of an 

aircraft in connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 
Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in 

an airworthy condition. 

ATAC Global description of the exemption we seek below:

Currently, no such certificate exists in the applicable in the form contemplated by FAA 

regulations. As a result, this regulation is inapplicable 

FAA rule which we seek exemption below in bold:

Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

ATAC Global description of the exemption we seek below:

The UAS carries no pilot and given the size of the UA, carrying these documents aboard 

the UAS is not possible. However, these documents will remain at the ground control 

point where the pilot flying the UAS will have immediate access to them. 

FAA rule which we seek exemption below in bold:

Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with 

runway lengths at airports of intended use, and takeoff and landing distance 

information. 

ATAC Global description of the exemption we seek below:

UAS operator will thoroughly cover all preflight actions including reviewing weather, 

battery requirements, landing and takeoff distances, and aircraft performance data 

before initiation of flight using appropriate checklists.

FAA rule which we seek exemption below in bold:

Section 91.109(a) prescribes, in pertinent part, that 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. 

ATAC Global description of the exemption we seek below:

Flight control is accomplished through the use of a radio transmitter that communicates 

with the aircraft via a receiver in the UA Therefore, there are no dual flight controls.

Additionally, there is no pilot or passengers in the UAS and the small size and safe 

speeds are added safety measures

FAA rule which we seek exemption below in bold:
Section 91.119 prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: 

1. (a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. 

2. (b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 feet 

above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft. 

3. (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. 

4. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the 

surface—

1. (1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each 

person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and 

2. (2) A powered parachute or weight-shift-control aircraft may be 

operated at less than the minimums prescribed in paragraph (c) of 

this section. 

ATAC Global description of the exemption we seek below:

91.119 allows safe altitudes for the operation of civil aircraft, but that it allows 

helicopters to be operated at lower altitudes in certain conditions. ATAC Global will not 

operates UAS above the altitude of 500 feet above ground level (AGL) and will also only 

operate in safe areas away from the public and traffic, thus “providing a level of safety at 

least equivalent to or below those in relation to minimum safe altitudes.” Because of the

size, weight, maneuverability, and speed of the UAS, an equivalent or higher level of 

safety will be achieved. Also, No flight will be taken without the permission of the 

property owner.

FAA rule which we seek exemption below in bold:

Section 91.121 requires, in pertinent part, each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “...to the elevation 

of the departure airport or an appropriate altimeter setting available before 

departure.” 

ATAC Global description of the exemption we seek below:

Altimeter settings is inapplicable since the UAS utilizes electronic GPS with a barometric 

sensor.
FAA rule which we seek exemption below in bold:

Section 91.151(a) prescribes that 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 [emphasis 

added]. 

ATAC Global description of the exemption we seek below:

The limitations on the UAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer timeframe for flight in daylight or night 

VFR conditions is reasonable. We believe an equivalent level of safety can be achieved 

by limiting flights to 45 minutes or not less than 15 percent of battery power, whichever 

occurs first. Also, ATAC Global UAS has preprogrammed setting that enables the UAS to 

return to original take off location when signal is lost and or battery becomes too low

adding an additional safety measure

FAA rule which we seek exemption below in bold:

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil 

aircraft unless it has within it (1) an appropriate and current airworthiness 

certificate; and (2) an effective U.S. registration certificate issued to its owner or, for 

operation within the United States, the second copy of the Aircraft registration 

Application as provided for in § 47.31(c). 

ATAC Global description of the exemption we seek below:

The UAS carries no pilot and given the size of the UA, carrying these documents aboard 

the UAS is not possible. However, these documents will remain at the ground control 

point where the pilot flying the UAS will have immediate access to them. 

FAA rule which we seek exemption below in bold:

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil 

aircraft unless the airworthiness certificate or a special flight authorization issued 

under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

ATAC Global description of the exemption we seek below:

The UAS carries no pilot and given the size of the UA, carrying these documents aboard 

the UAS is not possible. However, these documents will remain at the ground control 

point where the pilot flying the UAS will have immediate access to them. 

FAA rule which we seek exemption below in bold:
Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner 

shall have that aircraft inspected as prescribed in subpart E of the same part and 

shall, between required inspections, except as provided in paragraph (c) of the same 

section, have discrepancies repaired as prescribed in part 43 of the chapter. 

ATAC Global description of the exemption we seek below:

This is only applicable to aircraft with an airworthiness certificate. ATAC Global will

keep routine and preflight maintenance records, which will be accomplished by the 

operator, who will keep a log of any performed maintenance. The operator is most 

familiar with the UAS and best suited to maintain it in an airworthy condition to provide 

an equivalent level of safety and will do so prior to each flight. Should a mechanical 

issue arises, the UAS can land immediately, and given its small size, it poses minimal risk 

to persons or property. 

FAA rule which we seek exemption below in bold:

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, preventive maintenance, rebuilding, or 

alteration unless it has been approved for return to service by a person authorized 

under § 43.7 of the same chapter. 

ATAC Global description of the exemption we seek below:

This is only applicable to aircraft with an airworthiness certificate. ATAC Global will

keep routine and preflight maintenance records, which will be accomplished by the 

operator, who will keep a log of any performed maintenance. The operator is most 

familiar with the UAS and best suited to maintain it in an airworthy condition to provide 

an equivalent level of safety and will do so prior to each flight. Should a mechanical 

issue arises, the UAS can land immediately, and given its small size, it poses minimal risk 

to persons or property. 

FAA rule which we seek exemption below in bold:

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had an inspection 

for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter. 

ATAC Global description of the exemption we seek below:

This is only applicable to aircraft with an airworthiness certificate. ATAC Global will

keep routine and preflight maintenance records, which will be accomplished by the 

operator, who will keep a log of any performed maintenance. The operator is most 

familiar with the UAS and best suited to maintain it in an airworthy condition to provide 

an equivalent level of safety and will do so prior to each flight. Should a mechanical 
issue arises, the UAS can land immediately, and given its small size, it poses minimal risk 

to persons or property. 

FAA rule which we seek exemption below in bold:

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section: 

(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. 
(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under

§ 43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

ATAC Global description of the exemption we seek below:

The above is only applicable to aircraft with an airworthiness certificate. Prior to each 

flight, the UAS will undergo a routine preflight maintenance, which will be carried out by 

the pilot in command, who will keep a log of any performed maintenance to be certain 

that the UAV is airworthy. The operator is most familiar with the UAS and best suited to 

maintain it in an airworthy condition to provide an equivalent level of safety. 

Additionally, if a mechanical issue arises, the UA can land immediately, and given its 

small size, it poses minimal risk to persons or property. 

ATAC Global Conclusion

Public Interest

Given the small size of the UAS involved and the limited environment within which it 

will operate, its proposed operation falls squarely within that zone of safety. Also,

because of the size of the UAS and the restricted areas in which the UAS will operate, the 

fact that there are no passengers, no fuel, as well as the extensive training and continuing 

education (annual) that the operator goes through prior to operations serves as additional 

safety, which will benefit the public.

Granting the requested exemptions is in the public interest because of (1) the strong 

equivalent level of safety surrounding the proposed operations, and (2) the significant 

public benefit, including enhanced safety and reduction in environmental impacts (such 

as reduced emissions associated with allowing UAS for photography and inspection 

operations). 

ATAC Global has trained many law enforcement personal and also first responders for 

over two decades. Our willingness and ability to carry out these same standards, which 
have proven tremendous success into the UAS industry can have a safe and meaningful 

initiative.