Exemption No. 11204

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATIO N

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

BUILD IMAGERY

, LLC

for an exemption from §§ 61.113 (a) and (b), 91.103, 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of T itle 14, Code of

Federal Regulations Regulatory Docket No. FAA

– 20 14

– 0 886

GRANT OF EXEMPTION

By letter dated October 23, 2014 1

, Daniel Ursitti, Executive Producer, Build Imagery

, LLC (hereinafter Petitioner or Operator), 11870 Santa Monica Boulevard, Wes t Los Angeles, California 90025, petitioned the Federal Aviation Administration (FAA) for an exemption

from §§ 61.113 (a) and (b), 91.103, 91.119(c), 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Feder al Regulations (14 CFR). The exemption would allow the petitioner to operate the 3d Robotics Iris+ and the DJI Inspire 1 unmanned aircraft system s (UAS) for aerial photography for the architectural, engineering,

and construction industry site s

. 2 and in mot ion picture and television operations

.

The petitioner supports its request with the following information:

See Appendix A for the petition submitted to the FAA describing the proposed operations, including the regulations that the petitioner seeks an exe mption

.

The petitioner has provided the following information to support its request for an exemption:

1 By email dated February 8, 2015, the petitioner responded to the FAA’s request fo r information.

2 The petitioner originally proposed to operate its UAS for motion picture and television operations. By email dated February 26, 2015, the petitioner notified the FAA that it would focus its operations in the architectural, engineering, and construction industry

.2

1) Build Imagery Aircraft S pecification 2) Build Imagery Unmanned Aerial Systems Operations Manual 3) Build Imagery Flight Ch eck list 4) Iris + Operations Manual 5) Iris+ Flight Checklist

The petition and the document above are hereinafter referred to as the operating documents.

The FAA evaluated the petition and determined it was not precedent

- setting. Therefore, a summary of the petition was not published in the F ederal Register for public comment.

The FAA ’ s analysis is as follows :

The FAA has organized its analysis into four sections: (1) UAS, (2) the UAS pilot in command (PIC), (3) the UAS operating parameters, and (4) the public interest.

Unmanned Aircraft Sy stem (UAS)

In accordance with the statutory criteria provided in Section 333 of P.L. 112

- 95 in reference to 49 USC § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Sec retary of Transportation has determined

that this aircraft meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 14 CFR parts 21, and any associated noise certification and testing requirements of part 36, is not nece ssary.

The petitioner has proposed to operate two UAS; the 3d Robotics Iris+ and the DJI Inspire 1

. However, based on the information provided by the petitioner in its operating documents, this grant of exemption applies only to the 3d Robotics Iris+.

M anned aircraft conducting aerial photography operations can weigh thousands of pounds or

more , are operated by an onboard pilot and may carry other onboard crewmembers, as well as

carry large quantities of fuel. The petitioner’s unmanned aircraft ( UA ) weig hs approximately

4 pounds. The pilot and crew will be remotely located from the aircraft. The limited weight and construction reduces the potential for harm to persons or damage to property in the event of an incident or accident. The risk to an onboard pi lot and crew during an incident or accident is eliminated with the use of a UAS for the proposed operation.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The

UA carries no fuel and therefore the risk of fir e following an incident or accident due to fuel spillage is eliminated.

The petitioner’s UAS has the capability to operate safely after experiencing certain in

- flight contingencies or failures and uses an auto

- pilot system to maintain UAS stability and c ontrol. The UAS is also able to respond to a loss of global positioning system ( GPS ) or a lost

- link event with a pre

- coordinated, predictable, automated flight maneuver. These safety features3

provide an equivalent level of safety compared to a manned air craft holding a restricted airworthiness certificate performing a similar operation.

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405(a) Maintenance required

, 9 1.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, o r alteration

, 91.409(a)(2) Inspections , and 91.417(a) and (b) Maintenance records , the FAA has evaluated the petitioner’s request and determined that an exemption to these requirements is warranted

. The FAA notes that the petitioner’s operating documents contain preflight and post flight

checks for the UAS. The FAA has also determined that relief from § 91.409(a)(1) is also necessary because it is an alternate inspection requirement of § 91.409(a)(2). The FAA finds that adherence to the operating documents , as required by the conditions and limitations below, is sufficient to ensure that safety is not adversely affected.

UAS Pilot in Command (PIC)

Regarding the petitioner’s requested relief from 14 CFR § 61.113(a) and (b), Private pilot privileges and lim itations , t he petitioner requested to operate its UAS with a PIC hold ing at
least a private pilot’s certificate and a current third

- class medical certificate. Under current regulations, civil operations for compensation or hire require a PIC holding a comm ercial pilot certificate per 14 CFR part 61. Based on the private pilot limitations in accordance with pertinent parts of 14 CFR § 61.113(a), a pilot holding a private pilot certificate cannot act as a PIC of an aircraft for compensation or hire. However, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus) ( see Docket No. FAA

- 2014

- 0352), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground.

The FAA has analyzed the petitioner’s proposed operation and has determined that it does not differ significantly from the situation described in Grant of Exemption No. 11062. The petitioner plans to operate in uncontro lled airspace and over private property with controlled access. Given: 1) the similar nature of the petitioner’s proposed operating environment to that of Astraeus, 2) the parallel nature of private pilot aeronautical knowledge requirements to

those of com mercial requirements as discussed in Exemption No. 11062, and 3) the limited airmanship skills necessary to operate the UAS, the FAA finds that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the

airm anship skills necessary for the petitioner’s specific proposed operations.

W ith re g ar d to the a i r m a nship skills n ece ss a r y to op era te the UA S , the p e t i tion e r did not specify a training program, stating that the PIC will enroll in appropriate training for fixed wing aircraft . The conditions and limitations below require the petitioner to ensure the PIC

h a s d e monst ra t e d the a b ili t y to s a fe l y op e r a te the UAS in a m a nn e r c onsist e nt with how the

UAS will be op era t e d und e r this e x e mption, i n c luding e v a sive a nd e m e r g e n c y m a n e uv er s

a nd m a int a ining a p p r op r i a te dist a n ce s fr om p e opl e , v e s s e ls, v e h i c l e s, a nd st r u c tu re s.

In conclusion, t he FAA finds that a PIC holding a private pilot certificate and a third

- class airman medical certificate, and who has demonstrated the ability to safely operate the UAS in4

a manner consistent with how the UAS will be operated under this exemption per the

conditions and limitations , can conduct the proposed UAS operations without adversely affecting the safety of the NAS. Upon considerati on of the overall safety case presented by the petitioner, the FAA finds that relief from 14 CFR § 61.113(a) is granted, with the

conditions and limitations outlined below. The FAA also finds that relief from 14 CFR § 61.113(b) is not necessary.

The peti tioner indicated it will supplement its proposed operation(s) with a visual observer (VO). In Grant of Exemption No. 11062, the FAA agreed with the petitioner’s proposed use of a VO and required a VO to be used in all UAS operations. T he UA must never be operated beyond the actual visual capabilities of the VO, and the VO and PIC must have the ability to maintain VLOS with the UA at all times. It is the responsibility of the PIC to be aware of the VO’s visual limitations and limit operations of the UA to d istances within the visual capabilities of both the PIC and VO. Moreover, the VO will not be operating the aircraft. Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not consider a medical certificate necessary for the VO.

The FAA considers the PIC to be designated f or the duration of the flight. Therefore, per the conditions and limitations below, the PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight

.

UAS Operating P arameters

While the petitioner did not request relief from 14 CFR § 91.7(a) Civil aircraft airworthiness

, the FAA finds that relief from § 91.7(a) is necessary. Although the petitioner’s UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H, the FAA considers the petitioner’s compliance with its operating documents to be a sufficient means for determining an airworthy condition. Therefore, relief from § 91.7(a) is granted. The petitioner is still required to ensure that its aircraft is in an airworthy condition

– based on compliance with the operating documents prior to every flight, and as stated in the conditions

and limitations below.

Additionally, in accordance with 14 CFR § 91.7(b), the PIC is responsible for determining whether the UA is in a condition for safe flight. The FAA, as in grant of Exemption No. 11062 to Astraeus, has determined that the operating documents include procedures to be used prior to each flight that can ensure compliance with § 91.7(b) . The petitioner is required to ensure that its aircraft is in a condition for safe flight

– based on compliance with the operating documents

– prior to every flight.

Regarding the petitioner’s requested relief from 14 CFR § 91.103 Preflight Action , the

p etitioner requires each PIC to take certain actions before flight to ensure the safety of the flight. The petitioner states the exemption is needed because “ FAA approved rotorcraft flight manuals will not be provided for the aircraft.” Although there will be no approved Airplane or Rotorcraft Flight Manual available, the FAA believes that the petitioner can comply with the other applicable requirements in § 91.103. The procedures outlined in the operating5

documents address the FAA’s concerns regarding comp liance with § 91.103. The PIC will take all actions including reviewing weather, flight battery requirements, landings, and takeoff distances and aircraft performance data before initiation of flight. The FAA has imposed stricter requirements with regard to visibility and distance from clouds; this is to both keep the UA from departing the VLOS. The FAA also notes the risks associated with sun glare; the FAA believes the that PIC’s and VO’s ability to still see other air traffic, combined with the

PIC’s ability to initiate a return

- to

- home sequence, are sufficient mitigations in this respect.

The PIC will also account for all relevant site

- specific conditions in their preflight procedures. Therefore, the FAA finds that exemption for 14 CFR § 91.103 is n ot necessary.

Regarding the petitioner’s requested relief from 14 CFR § 91.119(c) Minimum safe altitudes

, the petitioner states that relief from § 91.119(c) is necessary because it proposes to operate below 500 feet above ground level. Section 91.119(c) s tates that no person may operate an aircraft below the following altitudes; 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 clo ser than 500 feet to any person, vessel, vehicle, or structure. The petitioner states that it will operate pursuant to the following, self

- imposed, restrictions related to § 91.119(c):

• Pet itioner will ensure aircraft operations remain within VLOS of the PIC and will be visually monitored at all times ;

• All operations will avoid congested or populated areas ;

• All operations will be conducted within a confined sterile area with the permission of the property owners or local officials;

• All operations will be conducted at or below 400 feet AGL ;

• Petitioner will obtain consent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation ;

• A briefing will be conducted for planned UAS operatio ns prior to each day’s flight

.

Regarding stand

- off distances from persons, vessels, vehicles and structures,

14 CFR § 91.119(c) requires that aircraft operate no closer than 500 feet to these persons or objects. As discussed in Exemption No. 11109 (Clayc o, Inc.), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. Therefore, the FAA is requiring that prior to conducting UAS operations, all persons not essential to flight operations (nonparticipating persons) must remain at appropriate distances. In open areas, this requires the UA to remain 500 feet from all persons other than essential flight personnel (i.e. PIC, VO, operator trainees or essential persons).

The FAA has also considered the UA’s maximum gross weight of approximately 4 pounds. If barriers or structures are present that can sufficiently protect nonparticipating persons from

the UA or debris i n the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must also ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons le ave such6

protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the FAA finds that ope rations may be conducted closer than 500 feet to vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or structures grants permission for the operation and the PIC makes a safety assessment of the risk of operating close r to those objects and determines that it does not present an undue hazard.

Thus, the FAA finds that relief from § 91.119(c) is warranted provided adherence to the procedures in the operating documents and the FAA’s additional conditions and limitations

o utlined below.

Regarding the petitioner’s requested relief from 14 CFR § 91.121 Altimeter Settings , the UAS will not have a typical barometric altimeter onboard the aircraft . I t uses information generated from GPS to transmit altitude information to th e PIC. As stated in the conditions and limitations below, the FAA requires any altitude reported to Air Traffic Control ( ATC )

to be in feet above ground level ( AGL ) . The petitioner may choose to set the GPS altitude

indicator to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations, relief from 14 CFR § 91.121 is granted to the extent necessary to comply with the applicable conditions and

limitations stated below.

Regarding the petitioner’s requested relief from § 91.151(a) Fuel requirements for flight in

VFR conditions , prior relief has been granted for manned aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. I n addition, similar

UAS

- specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The petitioner proposes to land the UAS after 10 minutes in flight or prior to

2 5 % battery power remaining. The operating documents indicate that the UAS will return to the launch point and land when the battery reaches 25% of capacity. These factors provide the FAA with sufficient reason to grant the relief from 14 CFR § 91.151(a) in accordance with the

conditions and limitations bel ow. The PIC would be prohibited from beginning a f l i g ht unless ( c onsid e ring wind a nd f o r e ca st w ea ther c ondi t ions) the r e is enou g h power t o fly to the

in t e nd e d landing point at norm a l c r uis i ng spe e d and land the UA with 2 5 % battery power remaining.

The FAA Air Traffic Organization (ATO) reviews all proposed UAS operations and evaluates the safety of these operations relative to the requested airspace through the existing Certificate of Waiver or Authorization (COA) process. The majority of current UAS oper ations occurring in the NAS are being coordinated through Air Traffic Control (ATC) by the

issuance of a COA. This process not only makes local ATC facilities aware of UAS operations, but also provides ATC the ability to consider airspace issues that are unique to UAS operations. The COA will require the operator to request a NOTAM, which is the mechanism for alerting other users of the NAS to the UAS activities being conducted. The conditions and limitations below prescribe the requirement for the petit ioner to obtain an

ATO

- issued COA.7

Public Interest

The F AA f inds th a t this g ra nt of e x e mption is in the public int ere st. The e nh a n ce d s afe ty

ac hi e v e d using a UA with the sp ec i f i ca tions d e s cr ib e d by the p e tition e r a nd carr y ing no

p a ss e n g er s or cre w, ra th e r th a n a m a nn e d a i rcraf t of si g ni f i ca ntly g rea t e r p r opo r tions carr y ing

cre w in a ddition to f l a mm a ble f u e l, g iv e s the F AA g ood ca use to f ind th a t the UAS op era tion

e n a bl e d by this e x e mption is in the public int ere st.

The following table summarizes the FAA ’s determinations regarding regulatory relief :

Relief considered (14 CFR) FAA determination (14 CFR)

61.113(a) and (b) Relief from 61.113(a) is g ranted with

conditions and limitations ; relief from 61.113(b) not necessary

91.7(a) Relief granted with con ditions and

limitations

91.103 Relief n ot necessary

91.119 (c) Relief granted with conditions and

limitations

91.121 Relief granted with conditions and

limitations

91.151(a) Relief granted for paragraph (a)(1), day,

with conditions and limitations

91 .405(a) Relief granted with conditions and

limitations

91.407(a)(1) Relief granted with conditions and

limitations

91.409(a)(1) and (2) Relief granted with conditions and

limitations

91.417(a) and (b) Relief granted with conditions and

limitations

The FAA’s 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, Build Imagery

, LLC is granted an exemption from

14 CFR §§ 61.113(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); 91.417(a) and (b) to the extent necessary to allow the petitioner to operate a UAS for the purpose of conducting aeri al photography on construction sites. This exemption is subject to the conditions and limitations listed below.8

Conditions and Limitations

Relative to this grant of exemption, Build Imagery LLC is hereafter referred to as

the operator.

The petition an d the following supporting documentation are hereinafter referred to as the
operating documents:

1) Build Imagery Aircraft Specification 2) Build Imagery Unmanned Aerial Systems Operations Manual 3) Build Imagery Flight Check list 4) Iris + Operations Manual 5) Iris+ Fl ight Checklist

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.

Failure to comply with any of the conditions and limitations of this gran t 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 following aircraft described in the operating documents which is a n Iris +

, four rotor quad copt er, weighing less than 4 pounds. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2) UAS operations under this exemption are limited to conducting operations for the purpose of aerial photography on con struction site s

.

3) The UA may not be flown at a ground speed exceeding 3 0 knots.

4) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All

altitudes re ported to ATC must be 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.

6) All operations must utilize a visual observer (VO). 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 or9

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.

7) The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

8) The operating documents and this grant of exemption 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 b e followed. Otherwise, the operator must follow the procedures as outlined in its operating 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 d ocuments to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis upon which the FAA granted th is exemption, then the operator must petition for amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating

documents.

9) Prior to each flight the PIC must ins pect the UAS to ensure it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

10) 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 in accordance with the operating documents. The PIC who conducts the functional test flight must make an entry in t he UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operating documents.

11) The preflight inspection section in the operating documents must be amended to

include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operating documents.

12) The operator must follow the man ufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the

manufacturer’s manuals.10

13) The operator must carry out t heir maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized UAS technician returning the UAS to service.

14) Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

15) The authorized person must make a record entry in the aircraft record of the

correctiv e action taken against discrepancies discovered between inspections.

16) The PIC must possess at least a private pilot certificate and a third

- class airman medical certificate for all of petitioner’s flight operations. The PIC must also meet the flight revie w requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

17) The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and 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 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). The PIC must ensure that the VO is trained appropriately in order to fulfill her or her duties. A record of training must be documented and made available upon request by the Administrator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) are permitted under the terms of this exemption. However, training 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 § 91.1 19.

18) 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.

19) The UA may not operate w ithin 5 nautical miles of an airport reference point as

denoted on a 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. The letter of agreement with the airport management must be made available to the Administrator

upon request.11

20) 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.

21) 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 and land or be recovered in accordance with the operating doc uments.

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.

23) The PIC will be prohibited from beginning a flight unless (considering wind and

forecast weather conditions) there is e nough power to fly at normal cruising speed to the intended landing point and land the UA with 25 % battery power remaining in accordance with the operating documents.

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. Al l operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

25) All aircraft operated in accordance with this exemption must be identified b y serial number, registered in accordance with 14 CFR part 47, and have identification (N

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

26) Before conducting operations, the radio frequency spectrum u sed for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

27) The 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.

28) The UA must remain clear and yield the right of way to all other aviation opera tions

and activities at all times.

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

30) The UA may not be operated over congested or densely populated areas.

31) The UA m a y not be o p e r a t e d fr om a n e l e v a t e d pl a t f o r m.12

32) Flight operations m ust be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC or VO), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the eve nt 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 a nd/or;

b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and;

c. Operations near the PIC or VO do not present an undue hazard to the PIC or VO per § 91.119(a).

33) 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/controll er or authorized representative will be obtained prior to the beginning of every flight.

34) 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 repo rted 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

.

Unless othe rwise specified in this grant of exemption, the unmanned aircraft system (UAS), pilot in command (PIC), and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on Marc h 31 , 2017 , unless sooner superseded or rescinded.

Issued in Washington, DC, on March 11, 2015.

/s/ John Barbagallo Acting Deputy Director, Flight Standards Service