Appendix I 

14 CFR Part 21 regarding aircraft certification requirements and procedures is designed for 

manned aircraft and is not suitable for off the shelf sUASs. 

14 CFR 45.23 (b) requiring aircraft to be marked in 2” to 6” lettering is impractical; there is not 

sufficient space on the sUAS. 

14 CFR 61.113 (a) & (b) limiting pilots to non-commercial operations, referring to the PIC. The 

sUASs will not carry a pilot, a passenger, or cargo for compensation or hire. The operators 

training from the manufacturers manual creates a higher level of safety for the public as a 

Commercial Pilot’s certificate in no way provides specific safe operational training of a remote 

controlled sUAS tethered to the operator on the ground. 

14 CFR 61.3 requiring a pilot certification. Pilot certification is designed for manned aircraft, The 

operators training from the manufacturers manual creates a higher level of safety for the public as 

a Pilot’s certificate in no way provides specific safe operational training of a remote controlled 

sUAS tethered to the operator on the ground. A description of our training for sUAS operators 

included in this document and petition far exceeds the minimal safety provided by a pilot 

certification when applied to sUASs. 

14 CFR 91.7 (a) Civil Aircraft Airworthiness requirements. No airworthiness certificate is 

available for this aircraft. The sUASs will not be modified and will be inspected prior to any 

flight as outlined in this petition. 

14 CFR 91.9 (b) (2) requires that the flight manual be available in the aircraft. Given the size and 

the fact that the aircraft is unmanned this rule cannot apply in its current language. 

14 CFR 91.103 preflight action requirements for crew on board aircraft. While this is important to 

the safe flying of the sUAS it does not apply given its current language. 

14 CFR 91.109 requiring that no person shall operate a civil aircraft for flight instruction unless 

the aircraft has fully functioning dual controls. SUASs and Remote controlled aircraft by design 

do not have dual controls, to do so on a radio controlled aircraft would lower the ability to safely 

operate the sUAS. This section cannot reasonably apply. 

14 CFR 91.119 designating minimum safe altitudes. The sUASs operated by the Tulalip Tribes 

Communications Department will not exceed an altitude of 400 feet AGL. This is below the 

altitude designated in this section. Also given the size, weight, and speed of the sUAS, the line of 

sight rule when operating, and the overall safeguards and restrictions in flight outlined in this 

petition maintain a higher level of safety to the public. 

14 CFR 91.121 regarding altimeter settings. A barometric altimeter is not provided on any sUAS. 

However a GPS altitude indicator is displayed to the operator at all times during flight. While an 

exemption to this regulation is requested a modification to meet the current technology of the 

sUASs would be acceptable. 
14 CFR 91.151 (a) Fuel requirements for flight. The maximum flight time under ideal conditions 

is under 30 minutes with the current manufacturers battery pack. The proposed rule under the 

Operation and Safety guidelines in this petition requiring the sUAS to return to its point of launch 

if its battery reaches a low level provides a higher standard of safety when applied to sUASs. 

14 CFR 91.203(a) & (b) requiring that a civil aircraft certificate and registration be displayed at 

the cockpit entrance cannot apply to sUASs, there is no cockpit and the size limitations prevent 

this. 

14 CFR 91.205 refers to cockpit instruments and cannot reasonably apply to sUASs as there is no 

cockpit. 

14CFR 91.215 requiring a transponder cannot reasonably apply to sUASs operated by the Tulalip 

Tribes Communications Department because they will be operated below ATC radar capabilities 

as outlined in this exemption request. 

14 CFR 91.405, 14 CFR 407 (a) (1) (2), 14 CFR 409 (a) (2), 14 CFR 417 (a) & (b) referring to 

maintenance, preventive maintenance, and alterations to the sUAS. The operator will provide 

minor maintenance and inspection to the sUAS, documented as outlined in the operational and 

safety guidelines. Given the size and simplicity of the sUAS combined with the operational and 

safety guidelines outlined in this petition the operator can maintain or exceed the required level of 

safety.