September 3, 2015

Exemption No. 12377A

Regulatory Docket No. FAA–2015–1784

Mr. Christopher Starnes

Starnes Aviation LLC

280 Virginia Avenue Northeast Suite 106

Norton, VA 24273

Dear Mr. Starnes:

This letter is to inform you that we have granted your petition for an amendment. It explains 

the basis for our decision, describes its effect, and lists any changes to the original conditions 

and limitations.

By letter dated April 25, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Starnes Aviation LLC (hereinafter petitioner or operator) for an exemption. The 

petitioner requested to operate an unmanned aircraft system (UAS) to conduct photography 

and video education, training1, and demonstration. In the August 6, 2015 decision letter, the 

FAA was unable to approve the Team Black Sheep Discovery Pro and Lumenier QAV500.

The FAA is now prepared to act on that request.

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

in the Federal Register because the requested amendment to the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner. The 

unmanned aircraft authorized in the original grant are comparable in type, size, weight, speed 

and operating capabilities to those in this petition.

 

1 The petitioner also requested authority to conduct UAS training. At this time, the FAA is unable to authorize 

UAS operations for training until a further assessment is completed. When the FAA completes its review, we 

will proceed accordingly and no further action will be required by the petitioner. However, the petitioner is 

permitted to train its own pilot in commands and visual observers in accordance with condition no. 14 and the 

other conditions and limitations in this exemption.
2

Airworthiness Certification

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 12377 

remains valid and is in the public interest. Therefore, under the authority contained 

in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, the operator is 

granted an amendment to add new aircraft to its UAS operations.

The operator shall add this amendment to its original exemption.

 

Conditions and Limitations

All conditions and limitations within Grant of Exemption No. 12377 remain in effect except 

as follows. Condition No. 1 has been updated to reflect the additional aircraft. 

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

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1, 

Team Black Sheep Discovery Pro, and Lumenier QAV500 when weighing less than 

55 pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption.

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Date: April25, 2015 

Starnes Aviation LLC 

280 Virginia Ave NE Ste 1 06 

Norton, VA 24273 

Phone# 276-365-8071 

Email: chris@starnesav.com 

Christopher Starnes MD - FAA Senior AME 0 1190 

Re: Exemption Request Pursuant to Section 333 ofthe FMRA and Part 11 ofthe 

Federal Aviation Regulations, Seeking Exemption from: 

14 C.F .R. Part 21 Subpart H 

14 C.F.R. § 21.191(a) 

14 C.F.R. § 45.23(b) 

14 C.F.R. § 45.27 

14 C.F.R. §§ 61.113(a) and (b) 

14 C.F.R. § 91.119(c) 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151(a) 

14 C.F.R. § 91.405(a) 

14 C.F.R. § 91.407(a) (1) 

14 C.F.R. §§ 91.409(a) (1) and (2) 

14 C.F.R. §§ 91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 

C.F.R. Part 11, Starnes Aviation LLC (SALLC) hereby applies for an exemption from the listed 

Federal Aviation Regulations(" FARs") and any other necessary to allow operation of its small 

Unmanned Aircraft Systems ("UAS") for commercial photography and video Education, 

Training and Demonstration for Emergency First Responders to intergrade UAS into certain 

Departments of Government. Second is to educate UAS to the Public and The Americans with 

Disabilities Act (ADA). SALLC will share knowledge with the community that prohibits 

discrimination against people with disabilities in employment, transportation, public 

accommodation, communications, and governmental activities. SALLC is opening this door for 

future opportunities, employment, and business development. Respectful, responsible and safe 

UAS flying is of the highest priority of our company. UAS operations are conducted under the 

conditions outlined herein. 

Description of Petitioner 

Dr. Chris Starnes is a Senior FAA Medical Examiner and Commercial Instrument Rated Pilot. 

Dr. Starnes writes for The Twin Cessna Flyer and my short story below. 

Starnes Aviation was established in 2006 to hold ownership and operation of a part 91 Piper 

Aztec. C I used the aircraft and business to help me get from rural Virginia to medical meetings 

and teaching venues. In 2008 I became ill with Leukemia and needed a bone marrow transplant 

in 2009. I resigned to leave aviation and put my beloved Aztec up for sale. I knew that my life 
might be over and my aviation dreams would remain just that. Under the pressure oflocal peers 

and a recognized need for a local AME I had requested the FAA allow me to complete AME 

training in 2007. Today, I spend my time as the Administrator of my wife's Dermatology 

practice. My practice of being an AME is contained within her office. I practice walking at 

work but if you see me I'm the guy in the wheelchair with carbon fiber legs. I work every day to 

get back into the left seat. I work every day to make Cutting Edge Dermatology the best it can 

be. Coming in for a medical is an emotionally challenging event. I want to do everything I can 

to educate the community on health or disease and how it relates to aerospace medicine. 

SALLC is evolving and opening an exciting new fun venture. Being in a wheelchair I have 

gotten into flying quad rotors or "drones" for fun. This has given my family and me a new lease 

on life. Having had the experience of a being a pilot and going thm what I went through was 

depressing that I would not be able to fly again. UAS has given me that happiness again and a 

new direction in sharing my knowledge to educate the present to change the future for UAS 

safety in national air space. Being a writer for a publication in aviation, this will allow SALLC to 

share UAS safety article's to a larger community. 

Aircraft 

Starnes Aviation LLC will operate 1: Team Black Sheep Discovery pro with aerial mob arm 

extensions which allow 15.5"props. 400kv motors, 6s batteries 2-3 batteries with 4000mwh 

each. This allows 45-55 min flight time. Dji naza m v2, 5.8ghz video tbs (team black sheep) 

500 mw transmitter, ir distro camera and tbs 59 fpv camera, mountable gopro, ground station 

hooked to ipad and projector to large white screen for public education. 2.4 ghz ground station 

for programming, with rc control on 2.4 or ez uhf from immersion rc - frsky tarranis controller. 

Weight of aircraft 4.4lb. 

2: lumenier qav500 with 540mm arms for 12" props. Tmotor u3 motors, beechwood tmotor 12" 

props, dji naza m v2, lightbridge, 900mhz ground station dji, 2.4 ghz frsky trannis control or 

ezuhf, dji zenmuse gh3 gimbal with gopro or ir distro. 4s battery- 4000, 5200 and 8000 mwh 

battery options. 4.4 lb aircraft weight 

3: DJI Inspire 1, Model T600, with a total weight of2935g or 6.47lbs. The dimensions are 

438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85 inches. Under still air the 

Maximum speed is no more than 22m/s or 49mph with a cmising speed of 11m/s or 25mph. The 

DJI Inspire 1 has the ability to hover and move along a vertical and horizontal plane 

simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, powered by a 6-cell 

4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, Propeller Model DJI 

1345, in use. The DJI Inspire 1 will be controlled with the C1 remote controller with an 

operating frequency of2.400GHz - 2.483GHz. The live video feed will have an operating 

frequency of 5.728GHz- 5.850GHz. DJI Inspire 1 has a program to limit height it will be set to 

200ft AGL. 

See link: http://team-blacksheep.com/products/prod:discopro 

http://www.lumenier.com/products/multirotors/qav500 http://www.dji.com/product/inspirel/spec 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY. 

The UAS will weigh less than 55 lbs. 

The UAS will have a maximum operating speed of no more than 50mph. 

Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO). 

Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time whichever occurs first. 

Flights will be operated at an altitude of no more than 200 feet Above Ground Level (AGL) and 

remain in the line of sight. 

Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and 

may include but not limited to a Camera Operator. 

The UAS pilot will be a designated Pilot in Command (PIC). 

A briefing will be performed regarding the planned UAS operations prior to each day's flight. 

The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP) of a tower controlled or uncontrolled airpmi. 

If operations will be within a 5 mile radius of the geographic center/ Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them ofthe estimated flight time, flight duration, elevation of flight and other pertinent 

information. 

The PIC and VO will have been trained in operation ofUAS and receive up-to-date information 

for the particular UAS to be operated. 

The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will 

have the capability to return to a pre-determined location within a designated location and land 

autonomously. 

The UAS will have the capability to abmi a flight in case ofunpredicted obstacles, weather, or 

emergenctes. 

UAS has in its program to limit height and distance from PIC. 

I. The Extent of Relief Starnes Aviation LLC Seeks and the Reason It Seeks Such Relief: 

Starnes Aviation LLC submits this application in accordance with the Reform Act, 112 P.L. 95 

§§331- 334, seeking relief from any currently applicable federal aviation regulations PARs 

pertaining to UASs (unmanned aircraft systems) and operating to prevent Starnes Aviation LLC 

contemplated commercial photography, Photographic mapping, and other flight operations 

within the U.S. national airspace system. 

The Reform Act in §332 provides for such integration of civil UASs into our national airspace 

system as it is in the public's interest to do so. Starnes Aviation LLC lightweight UASs meet the 

definition of "small unmam1ed aircraft" as set forth in §331 and combined with a sterling safety 

record in similar industries, Starnes Aviation LLC light duty UASs are ideal recipients of 

exemption by the intent of the Reform Act. 

Considerations for relief include a combination of sUAS physical characteristics, safety features, 

and safe practices identified in §333: 

• sUAS weight, • sUAS overall size, • sUAS speed over ground, • sUAS flight zone 

characteristics, 

-Non-operation near airports (civilian or military), 

- Tightly controlled operation in populated areas, 
I 

--~-------------~--~- ~~~----~---------------~ 

D:-- ·?8' ~c..:...,_~~::,.~·,.·~~"'>"";:>'.:-· 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act oj2012 

• Operation of the UAS by VLOS. • Coordination by a minimum of2 persons, 2 staff members 

of SALLC and one safety official from 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, 

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements 

of an equivalent level of safety under Part 11 and §333 of the Reform Act. llle Federal Aviation 

Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act both authorize the FAA to exempt 

aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

vveight, speed, operational capability, and proximity to airports and populated areas of the 

particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) 

operating with an airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated by SALLC is less than 10 lb. with maximal payload consisting of 

remote sensing instrumentation, carries neither no persons, carries no explosive or flammable 

materials including combustible fuels, and operates exclusively within a secured area. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the pilot (PIC), 'spotter' role designated to act as both the remote sensing controller and 

secondary monitor for safety issues, and a teclmician, which assists in matters related to 

maintaining the sUAS and also monitors for safety concerns and liaisons to 

the on-site safety officials. These enhancements to current safety practices and regulations, 

which already apply to civil aircraft, provide a greater degree of safety to the public and property 

owners than conventional aircraft operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no intrinsic credible threat to national security posed by the UAS, due to its size, speed of 

operation, location of operation, lack of intrinsic explosive materials or flammable liquid fuels, 

and inability to carry a substantial extemalload. 

14 C.F.R. §45.23 (b). Marking of the Aircraft The regulation requires: When marks include only 

the Roman capital letter "N" and the registration number is displayed on limited, restricted or 

light-sport category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words "limited;' "restricted;' "lightsport;' "experimental;' or "provisional;' as applicable. 

Even though the s UAS will have no airworthiness certificate, an exemption may be needed as the 

sUAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUAS, two-inch lettering will be impossible. 

The word "Experimental" will be placed on the frame in compliance with §45.29 (f) at a size 

suitable for the available space. 

' 
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Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act oj2012 

14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

§61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring a ground crew member to have a private pilot's license rather 

than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries 

the pilot and passengers, the sUAS is remotely controlled 1vith no persons on board. The area of 

operation is controlled and restricted, and all flights are planned and coordinated in advance. The 

risks associated with the operation of the sUAS are so diminished from the level of risk 

associated with commercial operations contemplated by Part 61 when drafted, that allowing 

operations as requested with a private pilot in the ground crew exceeds the present level of safety 

achieved by 14 C.P.R. §61.1 13 (a) & (b). 

14 C.P.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may 

operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft 

and the requirements contained in the Manual for maintenance and use of safety check lists prior 

to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent 

level of safety will be provided. 

14 C.P.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. §91.9 (b) (2) provides: No 

person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or Rotorcraft 

Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a 

current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability to carry a physical flight manual on 

the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the s U AS will have immediate access to it. The FAA 

has issued the following exemptions to 

this regulation: Exemption Nos. 8607,8737,8738,9299, 9299A, 9565,95658, 10167, 10167A, 

10602,32827, and 10700. 

14 C.P.R. §91.1 03: Preflight action this regulation requires each PIC to take certain actions 

before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. Further, we have proprietary manuals created 

with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding 

insurer and continue to work with these organizations to ensure best safe practices are adhered 

to. 

l 

14 C.P.R. §91.1 09: Flight instruction §91.1 03 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has 

fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have 

fully functional dual controls. Flight control is accomplished through the use of a control box 

that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft and 

for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. 
~-~--~··-----·-~---

The equivalent level of safety provided by the fact that neither a pilot nor passengers will be 

carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is the 

technology inherent in the remote controls utilizing digital communications which is paired to 

the sUAS making it nearly impossible to unintentionally or intentionally have the control 

communications interrupted. 

14 C.F.R §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation of 

civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior of a 

helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an 

exemption may be needed to allow such operations. As set forth herein, the UAS will never 

operate at higher than 400 AGL or beyond unaided visual line of sight, whichever is closer. It 

·will however be operated in a restricted area with security officials tasked with ensuring public 

safety, and where buildings and people will not be exposed to operations without their preobtained consent and training. 

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well 

as the location where it is operated. No flight operation will be taken without the permission of 

the property owner in the case of private property or local officials i the case of public property 

or private property with public interests. Because of the advance notice to the property owner 

and participants in the remote sensing activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maximum 10 lb of SALLC sUASs proposed herein and the lack of flammable 

fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of 

the sUAS will ensure separation between these small- UAS operations and the operations of 

conventional aircraft that must comply with §91.119. 

14 C.F.R §91. 121 Altimeter Settings §91.121 requires each person operating an aircraft to 

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

departure airport or an appropriate altimeter setting available before departure." As the sUAS 

may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. An equivalent level of safety will be achieved by the operator, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. The PIC and Technician will 

also ensure effective pairing with multiple GPS sources to guarantee accurate detection of height. 

14 C.F.R §9 1.151 (a): Fuel Requirements for Flight in VFR Conditions §91.151 (a) prohibits an 

individual from beginning "a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes:' The battery powering the sUAS 

provides approximately 15 minutes of powered flight in hover mode \vithout payload. SALLC 

sUAS will not be able to meet the 30 minute reserve requirement in 14 CPR §91.151. Operating 

the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 3 0 minutes of reserve 

power, does not engender the type ofrisks that Section 9l.l5l(a) was intended to alleviate given 

the size and speed of the small UAS. SALLC believes that an equivalent level of safety can be 
~----------------------------------------------------

achieved by limiting flights to» 10 minutes or 25% of battery power whichever happens first. 

This restriction would be more than adequate to return the sUAS toils planned landing zone from 

anywhere in its limited operating area. Similar exemptions have been granted to other operations, 

including Exemptions 2689F, 5745, 10673, and 

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act oj2012 

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

provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following: (1) an appropriate and current airworthiness certificate ... 

(b) 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. 

The sUAS fully loaded weighs no more than 10 lb and is operated without an onboard pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at 

the ground control point where the pilot flying the sUAS will have immediate access to them, to 

the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 

9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.P.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections These 

regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter ... ;' and others shall inspect or maintain the aircraft in compliance with Part 43. Given that 

these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the 

flight manual. An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the U AS can land immediately and will be operating 

from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order 

prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to 

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

An exemption granted to SALLC would permit its operation of lightweight, unmanned, remotely 

controlled, sUASs in a tightly controlled environment with limited airspace. SALLC utilizes 

local business' safety officers in specifically determined areas (designed flight zone) to mitigate 

injury and property damage vvhile fulfilling clients' goals. Technical enhancements to current 

safety controls will allow SALLC to operate exceeding current safety specifications, and stay 

ahead of, or meet, new ones being implemented by the FAA and Department of Transportation. 

Further, SALLC conducts its operations in compliance with protocols described herein or as 

otherwise established by the FAA. 
-·~---------~-

Summary the FAA may publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and alike. 14 

C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). 

The size, weight and enclosed operational area of SALLC permit exemption from Part 21 

because SALLC meet an equivalent level of safety pursuant to Section 333 of the Reform Act. 

The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under 

both the Act (49 U.S. C.§ 44701(£)) and A. Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in 

consideration of the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. SALLC meet or exceed each of the elements. 

14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As 

no such certificate will be applicable in the form contemplated by the F ARs, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level 

of safety will be achieved by maintaining a Flight log. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as SALLC UAS's utilize 

electronic global positioning systems and internal gyroscopes to provide spatial coordination. 

Also preprogram height and distance. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety vvill be achieved by maintaining such information buy flight log at the SALLC Office. 

14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. SALLC are, by definition, unmanned. 

They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such small aircraft. 

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. PIC Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. SALLC can achieve an 

equivalent level of safety as achieved by current Regulations because SALLC do not carry any 

pilots or passengers. 

Further, while helpful, a pilot license will not ensure remote control piloting skills, though 

SALLC pilot vetting and training pro grams (based upon completion of an FAA Approved 

Ground School and a self-administered UAS flight training program and internal procedures 

will. All Further, the risks attendant to the operation of SALLC is far less than the risk levels 

inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C. F. R. § 91.119 prescribes safe altitudes for the 

operation of civil aircraft. It allows Helicopters to be operated at lower altitudes in certain 

conditions. SALLC will never operate at an altitude greater than 200 AGL. SALLC will, 

however, operate its UAS's in sectioned off areas with security perimeters, providing a level of 

safety at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of SALLC, an equivalent level of safety will be achieved. 

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

"have [the] aircraft inspected as prescribed in subpart E of this part and shall between required 
inspections, except as provided in paragraph C of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter." These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to SALLC should its requested 

exemption be granted. SALLC maintenance program will be to send UAS to a certified repair 

shop that involves regular software updates and constant inspection for assessment of any 

damaged hardware. Therefore, an equivalent level of safety will be achieved. 

Summary 

Starnes Aviation LLC seeks an exemption from the following Regulations: 14 C.F.R. 

21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 

(a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 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) and (b); 

14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.P.R.§ 91.409 (a)(2); 14 

C.P.R. § 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to operate its fleet for commercial 

photograph/video with education /demonstration to Emergency Services, Community education 

and ADA program's. SALLC will offer education to change the present and change the future. 

America's NAS and economic future is bright if SALLC is granted the opportunity to educate 

our state and neighboring states to be respectful and responsible operators as hobbyist and future 

professionals ofUAS. Granting SALLC request for exemption will reduce current risk levels and 

thereby enhance safety. Further, SALLC operates at lower altitudes and in controlled airspace. 

SALLC owner have strong ties to its aviation community to affect change if exemption is 

granted. UAS's and therefore the likelihood of death or serious bodily injury are significantly 

limited. 

SALLC respectfully requests that the FAA grants its exemption request without delay. The FAA 

has the authority to issue the exemption sought by Starnes Aviation LLC pursuant to the Federal 

Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Sincerely, 

Christopher Starnes MD F ACP AME