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 

Aviation 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 provider 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 opportunities for accessibility, application, and innovation. This

expansion includes orthophotography, photogrammetric and LiDAR based surface and structural

modeling, precision mapping extraction, broad-based spectral acquisition and analysis, real time 

geographic data streaming, and geographic information system (GIS) solutions. 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 sUASs

under controlled conditions in airspace that (a) is limited, (b) is predetermined, (c) is controlled as 

to access, and (d) would provide safety enhancements to 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.com
The 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, construction, engineering, mining, utilities, forestry, agriculture, ranching, 

structural assessments, historical preservation, forensic documentation, and emergency 

management.

This petition for exemption is supported by the information contained in the senseFly eBee 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 pilot certificate.

The characteristics of the sUASs, detailed sUASs operator requirements, and sUASs 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 DJI 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 accordance with 14 C.F.R. Part 45, , 

Subpart C, in a size as large as practical for the size of the sUAS. 

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, current 
sUAS 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 

test 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 maintenance has been performed and the UAS is found to be 

in a condition for safe flight. All Access Geographic, LLC sUASs will comply with all applicable 

manufacturer safety bulletins. 

Additional information on the aircraft specifications, performance limitations, operating 

procedures, and pre-flight inspections is contained in the attached documents. The safety and 

reliability of the senseFly eBee and DJI Phantom 3 sUASs is further supported by the fact that 

FAA exemptions have previously been approved for their 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 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 senseFly eBee and DJI Phantom 3 sUASs. 

The individual 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 sUAS. 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 at 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 the 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 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. 

• 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 ensure that the VO can perform the duties required of the VO. 

• The requested exemption documentation and all documents needed to operate the 

sUASs and conduct its operations in accordance with the conditions and limitations 

stated in requested exemption are hereinafter 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 revise 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 revised documents if it petitions for 

extension or amendment to the requested grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted this 

requested exemption, then Access Geographic, LLC must petition 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., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting 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 people. 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 sUASs to 

ensure that it is in a condition for safe operation. 

• 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 follow the sUAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

• Each sUAS operated under the requested exemption must comply with all manufacturer 

safety bulletins. 
• 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. 

• Access Geographic, LLC may not permit any PIC to operate unless the PIC 

demonstrates the ability to safely operate the sUASs in a manner consistent with how the 

sUASs will be operated under the requested 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). Flights for the purposes of training Access 

Geographic’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability to safely operate the sUAS in a manner consistent with how 

the sUAS will be operated under the requested exemption are permitted under the terms 

of this requested 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 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 (SVFR) are not authorized. 

• The sUASs 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 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 sUASs 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 the 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 prohibited 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 accordance with an ATO-issued COA. 

• Documents used by Access Geographic, LLC to ensure the safe operation and flight of 

the sUASs 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 is 
operating. These documents must be made available to the FAA or any law enforcement 

official upon request. 

• The sUASs must remain clear and give way to all manned aviation operations and 

activities at all times. 

• The sUASs 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 the safety 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 objects 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 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. 

• 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). 

APPLICATIONS AND PUBLIC 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 of sUASs in the geospatial information 

sector from structural analysis to emergency management services. Approached responsibly, 

utilizing sUASs as an alternative to ‘traditional’ airborne practices can present safety advantages.

Deploying lightweight electric sUASs instead of ‘heavy’ fuel driven airborne systems 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, utilizing a sUAS rather than non-airborne practices for information gathering of elevated 

project environments can potentially improve project safety. In many instances, rappelling 

equipment, ladders, and lifts are put to use in order to access elevated or otherwise inaccessible 

areas for assessment, potentially placing personnel at risk. Using a sUAS as an alternative to 

these methods can help mitigate this risk. 
In addition, electric sUASs typically produce less noise and emissions than conventional ‘heavy’

systems, making them less likely 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 of the Title 

14 Code of federal regulations that would 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 

CONCLUSIONS:

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 requirements 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, 

ACCESS GEOGRAPHIC, LLC

Robert C. Moore

Principal Geographer

(FAA Pilot Certification #3557232)

Phone: (480) 709-2710

Email: rmoore@accessgeographic.com
Attachments: 

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 sUASs:

14 C.F.R. Part 21, 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 issuance of 

airworthiness certificates as required by FAR § 91.203(a). Given the size of the sUASs, their

lightweight, and the limited operating area associated with its utilization, it is unnecessary to go 

through the certificate of airworthiness process under 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 sUASs involved. An analysis of these different criteria demonstrates that 

the sUASs 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 serve 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 only 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 sUASs, Access 

Geographic, LLC proposes that operators of the sUASs 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 requirements 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 equivalent level of safety by maintaining a copy 

of all documents used by the operator to ensure the safe operation and flight of the sUASs as 

well as documentation of the requested exemption and COA with the ground control station and 

accessible to the PIC during 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 

lengths 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 for flight 

instruction unless that aircraft has fully functioning dual controls." 

The sUASs do not have fully functional dual controls, however the equivalent level of safety will 

be achieved through Access Geographic’s sUAS flight training program and only 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 sUASs 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 sUASs will be operating 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 sUASs. 

Additionally, the sUASs 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 sUASs 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 may 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 sUASs, 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 sUAS 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 required 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 Administrator 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 aircraft 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 inspections of the 

sUASs will be accomplished by the PIC. All maintenance will be conducted and logged in 

accordance with the manufacturer’s specifications. An equivalent level of safety will be achieved 

because the sUASs are small in size and are not complex mechanical devices.