July 9 , 2015

U.S. Department of Transportation
Federal Aviation Administration Document Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

RE: Exemption Request

– Section 333 of the FAA Report Act and Part 11 of the Federal
Aviati on Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95, 126 Stat.11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, Access Geographic, LLC a nationwide pro vider of geospatial information and services and operator of Unmanned Aircraft Systems (singularly a “sUAS” or cumulatively “sUASs”) seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below, to allow commercial operation of its
sUASs.

Access Geographic, LLC , provides professional geospatial information and services to a diverse base of government and private industry sectors across North America

. Access Geographic , LLC ( AGL ) has continuously worked to expand its capability to acquire and process geospatial information, creating new opp ortunities for accessibility, application , and innovation. This

expa nsion includes orthophotography , photogrammetric and LiDAR based surface and structural modeling , precision mapping extraction, broad

- b ased spectral acquisition and analysis, real time

geograp hic data streaming, and geographic information system (GIS) s olutions

. Having completed numerous airborne geospatial projects across North America, Access Geographic,
LLC looks forward to responsibly integrating the unique potential that Unmanned Aircraft Systems offer as an acquisition technology

.

The requested exemption by Access Geographic, LLC would permit the operation of sUAS s under controlled condition s in airspace that (a) is limited, (b) is predetermined, (c) is controlled as to access, and (d) would provide safety enhancements t o project operations . Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace system.” Reform Act 333 (c).

The name and address of the applicant (“Applicant”):

Access Geographic, LLC
Robert C. Moore 3116 S. Mill Ave, Suite 193 Tempe, AZ 85282 Phone: (480) 709

- 2710 Email: rmoore@accessgeographic.comThe Applicant hereby requests exemption from the following FARs:

• 14 C.F.R. 21, subpart H

• 14 C.F.R. 61.3

• 14 C.F.R. 61.113(a)&(b)

• 14 C.F.R. 61.133(a)

• 14 C.F.R. 91.9(b)(2)

• 14 C.F .R. 91.103(b)

• 14 C.F.R. 91.105

• 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203(a) & (b)

• 14 C.F.R. 91.319(a)(1)

• 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize Access Geographic, LLC to conduct commercial operations using the senseFly eBee and DJI Phantom 3 systems for visualization, 3D modeling, mapping, inspection , videography and photography for the following applications: planning, environmental, constructio n

, engineering, mining , utilities

, forestry, agriculture, ranching

, structural assessments, historical preservation, forensic documentation

, and emergency management.

T his petition for exemption is supported by the information contained in the senseFly eB ee and
DJI Phantom 3 Published User Manuals (hereafter collectively referred to as “Manufacturer’s Operations Manuals”).

All Access Geographic, LLC UAS will be operated only by individuals who hold at least an FAA issued private, recreational, or sport pi lot certificate

.

The characteristics of the sUAS s , detailed sUAS s operator requirements, and sUAS s operating parameters given below will ensure that all Access Geographic, LLC UAS operations are carried out with an equivalent or higher level of safety than currently authorized manned aircraft operations. The details below regarding Access Geographic, LLC intended UAS applications provide clear evidence that approval of this exemption is in the public interest.

- sUAS OVERVIEW :

Both the senseFly Ebee and DJ I Phantom 3 are very lightweight sUASs weighting less than 3 pounds each . Each system is electric

- powered with onboard IMU allowing for semi

- automated flight under supervision of its operator along with option to take complete manual control of the systems if necessary.

Each sUAS operated by Access Geographic, LLC for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accor dance with 14 C.F.R. Part 45, , Subpart C, in a size as large as practical for the size of the sUA S.

All sUASs operated by Access Geographic, LLC will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the sUAS’s maintenance log. Maintenance log entries will include the date, sUAS ID number, registration number, currentsUAS flight time, a description of work performed, and the name of the individual who completed the work. Any UAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional

tes t flight, prior to use in any commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. The PIC who conducts the functional test flight must make an entry in the aircraft records. A pre

- flight inspection of the sUAS will be completed by the PIC prior to each flight operation

. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maint enance has been performed and the UAS is found to be in a condition for safe flight. All Access Geographic, LLC s UAS s will comply with all applicable manufacturer safety bulletins.

Additional information on the aircraft specifications, performance limitat ions, operating procedures, and pre

- flight inspections is contained in the attached documents. The safety and reliability of the senseFly eBee and DJI Phantom 3 sUAS s is further supported by the fact that FAA exemptions have previously been approved for th eir use in commercial operations.

UAS OPERATOR REQUIREMENTS :

All Access Geographic, LLC sUAS operators will hold at least a FAA issued private, recreational, or sport pilot certificate

. All operators will either meet the flight review requirements specif ied in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation
of the senseFly eBee and DJI Phantom 3 sUAS s

.

The ind ividual acting as PIC of a sUAS will be identified prior to any flight and will not change once the flight has begun. The PIC is the individual in operational control of the flight operation from beginning to end and is responsible for safe flight of the s UAS. All PIC flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR § 61.51(b).

In order to act as PIC, all Access Geographic, LLC sUAS operators will hold a current FAA
airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government.

UAS OPERATING PARAMETERS :

In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all Access Geographic, LLC commercial sUAS operations will be conducted in accordance with the following operating limitations and conditions :

• sUASs will weight less than 55 pounds including payload.

• The sUAS may not be operated a t a speed exceeding 87 knots (100 miles per hour). The requested exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the sUAS be operated at airspeeds greater than t he maximum sUAS operating airspeed recommended by the aircraft manufacturer.

• The sUAS must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.• The sUAS must be operated within visual line o f 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.

• All operations must utilize a visual observer (VO). The sUAS 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 ensur e that the VO can perform the duties required of the VO.

• The r equested e xemption documentation and all documents needed to operate the
sUAS s and conduct its operations in accordance with the conditions and limitations
stated in requested exemption are here inafter referred to as the operating documents. The operating documents must be accessible during sUAS operations and made
available to the FAA upon request. If a discrepancy exists between the conditions and
limitations in the requested 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 documents. Access Geographic, LLC may update or revi se its operating documents. It is Access Geographic, LLC’s responsibility to track such revisions and present updated and
revised documents to the FAA or any law enforcement official upon request. Access Geographic, LLC must also present updated and revise d documents if it petitions for
extension or amendment to th e requested grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this requested exemp tion, then Access Geographic, LLC must petiti on for an amendment to the requested 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.

• Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g., replacem ent of a flight critical component, must undergo a functional test flight prior to conducti ng further operations under the requested exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other pe ople. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

• Access Geographic, LLC is responsible for maintaining and inspecting the sUAS s to ensure that it is in a condition for safe opera tion.

• Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the sUAS 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 sUAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight.

• The operator must fol low the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

• Each sUAS operated under th e requested exemption must comply with all manufacturer safety bulletins.• A PIC m ust 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.

• Access Geographic, LLC may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the sUAS s in a manner consistent with how the
sUAS s will be operated under the requested exemption, including evasive and emergency maneuvers and maintaining appropriate distances from per sons, 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 p urposes of training Access Geographic ’s PICs and VOs (training, proficiency, and experience

- b uilding) and determining the PIC’s ability to safely operate the sUAS in a manner consistent with how
the s UAS will be operated under the requested exemption are permitted under the terms
of this requested exemption. However, training operations may only b e 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 sUAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

• sUAS 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 (SV FR) are not authorized.

• The sUAS s 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 denote d 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 requested exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

• The sUAS s 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.

• If th e sUAS loses communications or loses its GPS signal, the sUAS must return to a

pre

- determined location within the private or controlled

- access property.

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

• The PIC is prohib ited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the sUAS 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.

• Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations
shall be conducted in ac cordance with an ATO

- issued COA

.

• Documents used by Access Geographic, LLC to ensure the safe operation and flight of
the sUAS s 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 sUAS any time the aircraft isoperating. These documents must be made available to the FAA or any law enforcem ent official upon request.

• The sUAS s must remain clear and give way to all manned aviation operations and
activities at all times.

• The sUAS s may not be operated by the PIC from any moving device or vehicle.

• All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

1) Barriers or structures are present that sufficiently protect nonparticipating persons from the sUAS and/or debris in the event of an accident. Access Geographic, LLC 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 sUAS, flight operations must cease immediately in a manner ensuring th e safet y of nonparticipating persons; and

2) 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 obje cts and determined that it does not present an undue hazard.

The PIC, VO, trainees or essential persons are not considered nonparticipating persons under this requested exemption.

• All operations shall be conducted over private or controlled

- access p roperty 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.

• Any incident, accident, or flight operation t hat transgresses the lateral or v ertical 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).

APPLICATIONS AND PUBL IC INTEREST :

The requested exemption would allow Access Geographic, LLC to operate the senseFly eBee
and DJI Phantom 3 for the purposes of geospatial information acquisition, extraction, analysis, and production

. There are broad opportunities for the use o f sUAS s in the geospatial information sector from structural analysis to emergency management services . Approached responsibly, utilizing sUAS s as an alternative to ‘traditional’ airborne practice s can present safety advantages. Deplo ying lightweight elec tric sUAS s instead of ‘heavy’ fuel driven airborne system s can mitigate risk to personnel and property

. Removing long

- distance deployments, a flammable fuel source

, and risks associated with manned flights , can provide an added level of safety to airborne data acquisitions relative to local environmental conditions and project requirements

.

Also

, u tilizing a sUAS rather than non

- airborne practices for information gathering of elevated project environments can potentially improve project safety. In many in stances, rappelling equipment , ladders, and lifts are put to use in order to access elevated or otherwise inaccessible
areas for assessment

, potentially p lacing person ne l at risk. U sing a sUAS as an alternative to
these methods can help mitigate this risk.In addition, electric sUAS s typically produce less noise and emissions than conventional ‘heavy’ systems, making them l ess likel y to negatively impact local environmental and cultural ecologies during an airborne data acquisition.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER :

Pursuant with Section 333 of the FAA Modernization and Reform Act of 2012, Access Geographic, LLC requests the grant of an exemption to the following specific sections o f the Title
14 Code of federal regulations that woul d allow it to operate UAS for commercial use:

14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417

CONCL USIONS :

Access Geographic, LLC respectfully requests that the FAA grant the exemption sought in this request. Access Geographic, LLC believes that considering the small size and weight of the sUAS, along with the sUAS PIC training and certification requir ements stipulated above and the strict operating guidelines proposed herein, it is clearly demonstrated that the sUAS will be operated safely in the national air space (NAS) with an equivalent or greater level of safety compared to manned aircraft.

We are prepared to modify or amend any part of this request as deemed necessary by the FAA to satisfy the need for an equivalent level of safety. Please contact us at any time if you require
additional information or clarification.

Respectfully Submitted,

ACCE SS GEOGRAPHIC, LLC

Robert C. Moore Principal Geographer ( FAA Pilot Certification #3557232 )

Phone: (480) 709

- 2710 Email: rmoore@accessgeographic.comAttachments:

Phantom_3

_ Professional_User_Manual_v1.2_en

SenseFly

_ User

_ Manual eBee _v12

APPENDIX A : REGULATIONS REQUIRING EXEMPTION

Access Geographic, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the senseFly eBee and DJI
Phantom 3 sUAS s :

14 C.F.R. Part 2 1, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issu ance of airworthiness certificates as required by FAR § 91.203(a). Given the size of the sUAS s , their light weight, and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process unde r Part 21 Subpart H in order to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and
Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the sUAS s involved. An analysis of thes e different criteria demonstrates that
the sUAS s operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness
certificate.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may se rve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may be used.

The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if:

(1) The flight is on ly incidental to that business or employment; (2) The aircraft does not carry passengers or property for compensation or hire.Given the size, weight, speed, operational limitations, and range of the sUAS s

, Access Geographic, LLC proposes that operators o f the s UAS s should not be required to hold a commercial pilot certification. Instead, operators should be required to:

Hold at least an FAA issued private, recreational, or sport pilot certificate. All operators will either meet the flight review requirem ents specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the Phantom 3 and senseFly eBee

.

14 C.F. R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight
manual is in the aircraft.

Access Geographic, LLC proposes to provide an equival ent level of safety by maintaining a copy of all documents used by the operator to ensure the safe operation and flight of the s UAS s as well as documentation of the requested exemption and COA with the ground control station and
accessible to the PIC durin g flight operations.

14 C.F.R. § 91.103: Preflight action

This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include runway
le ngths at airports of intended use, and the following takeoff and landing distance information.

This regulation is not applicable due to the fact Access Geographic, LLC sUAS operations will not occur at an airfield. To provide an equivalent level of safety , the PIC will complete a preflight inspection as directed by the manufacturer’s manuals before any flight.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used f or flight instruction unless that aircraft has fully functioning dual controls."

The sUASs do not have fully functional dual controls, however t he equivalent level of safety will be achieved through Access Geographic’s sUAS flight training program and onl y conducting flight training within highly controlled environments.

14 C.F.R § 91.105: Flight Crewmembers at Stations

The regulation states that required crewmembers must be at their stations in the aircraft during specific portions of a flight.

This is not applicable since the sUAS s carry no crewmembers. An equivalent level of safety will be maintained by ensuring that the PIC is identified prior to any flight and that the PIC does not change during a flight. The PIC will maintain control of the UAS for the duration of the flight.

14 CFR § 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure.Since the s UA S s will be operati ng at a maximum of 500 feet AGL, these operations cannot comply with this requirement.

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS s

. Additionally

, the sUAS s will be operated in a defined and relatively small AOI. The sUASs will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

14 CFR 91.121

– Altimeter settings

This section requires that 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 below 18,000 feet MSL to:

• The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

• 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;

• 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.

To provide an equivalent level of safety, the sUAS s utilize a GPS system, barometric pressure sensors, and internal gyroscopes to calculate the altitude.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person ma y begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after
that for at least 30 minutes.

Given the limited area of operation for the s UAS s

, Access Geographic, LLC believes that an equivalent level of safety is achieved by requiring at least 75% battery power in order to begin a flight and requiring the s UA S to return to land when the battery power reaches 25%.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

• No person may operate a civil aircraft unless it has an appropriate and current airworthiness
certificate.

• No person may operate a civil aircraft unless the airworthiness certificate r equired by paragraph (a) of this section 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.

To obtain an equivalent level of safety and meet the intent of 91.203, Access Geographic, LLC proposes to maintain a copy of all documents used by the operator to ensure the safe operation and flight of the sUAS as well as documentation of an exemption and COA with the ground
control station and these will be available to the Admini strator or any law enforcement official upon request.14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

- Maintenance, Preventive Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the ai rcraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the
issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to
service.

Access Geographic, LLC proposes that the maintenance, as well as preflight i nspections of the
sUAS s will be accomplished by the PIC. All maintenance will be c onducted an d logged in accordance with the manufacturer’s specifications. An equivalent level of safety will be achieved
because the sUAS s are small in size and are not complex mechanical devices

.