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A ndy Acuna Gulf Coast Helicopters 4810 Comal St. Pearland, TX 77588 281

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- 2041 3 AUG 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Wa shington, DC 20590 Re: Summary Processing: Exemption Request for Gulf Coast Helicopters , Inc. Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. §§ 61.113(a) and (b); 91.7 (a); 91.119(c); 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) and (b). Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Gulf Coast Helicopters , Inc. (“ Gulf Coast Helicopters ”) operator of Small Unmanned Aircraft Systems (“ UAS ”) equipped to conduct commercial fli ghts including but not limited to the following (hereinafter “the Purpose”) : 1. Oil and gas inspection of equipment and facilities including pipelines 2. Television productions, music video productions, advertising and news gathering 3. Marketing of residential and commercial real estate 4. Aerial Photography and Videography 5. Construction Companies Aerials to include Aerial Progressives 6. Inspection surveys i.e. agricultural land for farmers, roofing, oil & gas companies, shoreline protection for ecological concerns, land survey, forestry service, Powerline & Energy Stations, road & bridge inspections, Railway Inspection, Mining industry survey and inspection. 7. Assist first responders/ or government agency in emergency matters, over land, water

-wa ys, and oceans, disaster relief, medical supplies delivery and missing persons 8. State side virtual tours, special events 9. Public service, Aerial Data Collection 10. TrainingPg **2** of **13**

Gulf Coast helicopters here by applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UAS , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption g ranted under either Section 333. As with the approval of the Similar Exemptions, approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requ irements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. The name and address of the applicant is: Gulf Coast Helicopters Aerospace, Inc. Attn: Andy Acuna 4810 Comal St. Pearland, TX 77588 281

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Regulations from which the exemption is requested: 14 C.F.R. § 61.113(a) and (b) : Private Pilot Privileges and Limitations: Pilot in Command 14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness 14 C.F.R. § 91.109 : Flight Instruction 14 C.F.R. § 91.119 : M inimum Safe Altitude 14 C.F.R. § 91.121 : Altimeter Setting 14 C.F.R. § 91.151(a) : Fuel Requirements for Flight in VFR Conditions 14 C.F.R. § 91.203(a) & (b); Carrying Civil Aircraft Certification and Regulation 14 C.F.R. § 91.405(a): Maintenance Inspection 14 C.F.R. § 407(a)(1) : Maintenance Inspection 14 C.F.R. § 409(a)(2) : Maintenance Inspection 14 C.F.R. § 417(a) and (b): Maintenance Inspection This exemption application is expressly submitted to fulfill Congress’ goal in passing S ection 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following: • The UAS’s size, weight, speed, and operational capability; • Operation of the UAS in close proximity to airports and populated areas; and • Operation of the UAS within visual line of sight of the operator. Reform Act § 333(a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333( c) (emphasis added) 1
. The Federal Aviation Act, in addition to the authority granted by Section 333 of Reform Act, expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under § 40101 of the Act, that includes UAS , from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsect ion (a) or (b) of this section or any sections 44702

- 44716 of the Transportation Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f). See also 49 U.S.C. §§ 44711(a), 44704; 14 C.F.R. § 91.203(a)(1).

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements for approval.Pg **4** of **13**

Gulf Coast Helicopters is Pipeline Inspection & Patrol Company that has more than 40 years of safe flying history and will use the UAS to enhance our abilities for our customers a s we ll as enhancing the safety of drone operations in the United States. Gulf Coast Helicopters UAS ’s are rotorcraft and we ighting 55 or fewer lbs. including payload. They operate, under normal conditions at a speed of no more than 50 knots and have the ca pability to hover, and move in the vertical and horizontal plane simultaneously. They will operate at altitudes of no more than 400 feet, as further explained, and only in line of sight. They will operate only within the sterile areas as described in the G ulf Coast Helicopters Flight Operations Manual. Gulf Coast Helicopters will also operate a UAS’s that are fixed winged weighting 55 lbs or less, including payload. They operate, under normal conditions at a speed of no more than 100 knots. They will operat e at altitudes of no more than 400 feet, as further explained, and only in line of sight. They will operate only within the sterile areas as described in the Gulf Coast Helicopters Flight Operations Manual. In support of this application, Gulf Coast Helicopters is submitting, with a request for confidentiality as shown, the following manuals (hereinafter “the Manuals”) 2 : • Gulf Coast Helicopters, Inc., Air Carrier Certificate • Gulf Coast Helicopters, Inc., UAS Flight Operations Manual (“FOM”), Exhibit 2 (Confidential) • Gulf Coast Helicopters UAS Quadcopter Aircraft Flight Manual, (Exhibit 3) (Confidential) • Gulf Coast Helicopters UAS Quadcopter Advanced Flight Manual, (Exhibit 3) (Confidential) • Gulf C oast Helicopters UAS Checklists, (Exhibit 4) (Confidential) Operations in compliance with thes e manuals will insure that the UAS will “not create a hazard to users of the national airspace system or the public” 3 and that the aircraft will operate in compliance with the conditions set forth in this application. Given the small size of the UAS involved and the restricted environment with in which they will operate, Gulf Coast Helicopters falls within that zone of s afety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to the size of the UASs, the restricted areas in which the relevant UAS will operate a nd the fact that aircraft will be flown by pilots holding at least a FAA private pilot license, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Fede ral Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered UASs for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private pilot license, the grant of the requested exemptions is in the public interest. Accordingly, the applicant re spectfully requests that the FAA grant the requested exemption without delay.

2 Applicant submits the Manuals, marked “CONFIDENTIAL”, as they contains propriety business information that is not released to the public and is protected under the Freedom of Information Act, 5 U.S.C. § 553, etc. 3 Reform Act Section 333(b). 4 These conditions are reproduced from Similar Exemptions (11062 through 11067, 11080, 11150, 11158 11160, 11161 and 11172).Pg **5** of **13**

**AI RCRA**  **FT AN**  **D EQUIVA LENT LEVEL OF SA** **FETY** The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to ope rations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe Pipeline Inspection & Patrol, Photography, Filming, Inspecting operations conducted with our conventional aircraft. 4 Gulf Coa st Helicopters notes that a requested Certificate of Authorization (COA) not be required for flight at or below 400 feet AGL, in Class G airspace and outside of 5 nautical miles from the geographic center of airport where a letter of agreement has not been entered with the airport management. These limitations and conditions to which Gulf Coast Helicopters agrees to be bound when conducting commercial operations under an FAA issued exemption include:
1. The UAS must weigh less than 55 pounds, including energy source(s) and equipment. Opera tions will be limited to the aircraft described in the proprietary Manuals:
2. The UAS may not be flown at a speed exceeding a ground speed of 50 knots (Quad Copter, and 100 knots (Fixed W ing)

. 3. Flights must be operated at an altitude of no more than 400 feet above ground level (AGL) as indicated by the procedures specified in the Operators Manuals. All altitudes reported to ATC must be in feet AGL.
4. The UAS must be operated within visual lin e of sight (VLOS) of the PIC/VO(s) at all times. This requires the PIC/VO (s) to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued medical certificate.
5. All operations must utilize a vi sual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 6. The operator will be bound by and follow the Manuals as accepted by the FAA. Any additional requirements identified in the final conditions for this Exemption will be added to the Manuals. The Manuals will be maintained and made available to the Administrator upon request. If a discrepancy exists between the condi tions and limitations in the final exemption and the procedures outlined in the Manuals, the conditions and limitations of the Exemption will take precedence and will be followed. Otherwise, the operator will follow the procedures as outlined in its Manual s. The operator will update or revise its Manual. It will be the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator will also present updated and revised documents in its petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the operator will petition for amendment to their exemption. The operator will contact the FAA’s UAS Integration Office (AFS

- 80) with questions arising regarding updates or revisions to the Manual.Pg **6** of **13**

7. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition tha t affects the safe operation of the UAS, the aircraft will not operate until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical comp onent, must undergo a functional test flight in accordance with the Manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Manuals. 9. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. W hen unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the Manuals. At a minimum, the following must be included in the Manual:

a. Actuators / Servos b. Transmission (single rotor) c. Powerplant (motors) d. Pro pellers e. Electronic speed controller f. Batteries g. Mechanical dynamic components (single rotor) h. Remote command and control i. Ground control station (if used) j. Any other components as determined by the operator 10. The PIC will possess at le ast a private pilot certificate.
11. Prior to operations conducted for the Purpose, the PIC will have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations will be used to satisfy this requirement. Training, proficiency, and experience

- building flights may also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considere d non

- participants, and the PIC will operate the UAS with appropriate distance from non

- participants in accordance with 14 C.F.R. § 91.119.
12. Prior to operations conducted for the purpose of Pipeline Station/Valve Inspections (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 days. Training, proficiency, experience

- building, and take

- off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency,Pg **7** of **13**

experience - building, and take

- off and landing currency flights all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
1 3. Prior to any flight operations authorized by this grant of exemption, the PIC and VO must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be d eveloped and implemented by a qualified person designated at the sole discretion of the operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request. 14. Prior to operations condu cted for the Purpose, a flight demonstration, administered by an operator

- approved and

- qualified pilot will be successfully completed and documented. This documentation will be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications will be developed by the operator, and there are no established practical test standards that support a jurisdictional FAA Flight Standards District Office (FSDO) evaluation and approval of company designated examiners, t he Operator will conduct these tests in accordance with the Manual. The UAS will not be operated directly over any person, except authorized and consenting personnel necessary for the Purpose, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 15. Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a) Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b) The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission 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, and; c) Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). All operations shall be conducted over private or controlled

- access property with permission from the property ow ner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each operation to be conducted. See , Exemptions 11170, 11172 and 1117 for proposed language.Pg **8** of **13**

16. Prior to any flight , Operator will only be required to obtain an Air Traffic Organization (ATO) issued Certificate of Wa iver or Authorization (COA) for flights that are conducted at heights greater than 400 AGL; in other than Class G airspace; and closer than 5 miles from the geographic center of a non

-towered airport, without a letter of agreement with the airport manager. If requested, Operator will provide telephonic advanced notice to an ATO or file a NOTAM for any flight not requiring a COA.
17. If the UAS loses communications or loses its Global Positioning System (GPS) signal, the UAS will be programmed to return to a pre

- determined location within the security perimeter and land or be recovered in accordance with the Manual. 18. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the Manual. 19. Each UAS sortie will be completed within 45 minutes flight time or with 25% battery power remaining, whichever occurs first. 20. All aircraft operated in accorda nce with this exemption will be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, subpart C. Markings will be as large as practicable.
21. The operator will develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures will be added to t he Manual.
22. Each UAS operated under this exemption will comply with all manufacturer Safety Bulletins. 23. The operator will develop UAS technician qualification criteria. These criteria will be added to the Manual. 24. The preflight inspection section in the Manual will be amended to include the following requirement: The preflight inspection will account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspect ion sections of the Manual. 25. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 26. The docum ents required under 14 C.F.R. 91.9 and 91.203 will be available to the PIC at the ground control station of the UAS any time the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request. 27. The UAS will remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).Pg **9** of **13**

28. UAS operations will not be conducted during night, as defined in 14 C.F.R. 1.1. All operations will be conducted under visu al meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be undertaken. 29. The UAS will not be operated by the PIC from any moving device or vehicle. 30. The UAS will not be operated less than 500 feet below or l ess than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 31. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The UAS will not operate within 5 nautical miles of the geographic center of a non

towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management will be made available to the Administrator upon request. 32. Any 1) incident, 2) accident, or 3) flight operation that transgresses the late ral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the Federal Aviation Administration’s (FAA) UAS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to the National Transportation S afety Board (NTSB) per instructions contained on the NTSB We b site: www.ntsb.gov. Further flight operations will not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided. Unl ess otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 C.F.R. including, but not limited to, parts 45, 47, 61, and 91. **14 C.F.R. § 61.113(a) and (b): Private Pilot Priv ileges and Limitations: Pilot in Command.**  Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current op erations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provi ded by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operat ion of the UAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, t hat allowing operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. § 61.113(a) and (b). The FAA has granted exemptions for private pilots to conduct similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.Pg **10** of **13**

**14 C.F.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 fo r determining airworthiness. Given the size of the aircraf t and the requirements contained herein for the use of safety check lists prior to each flight, an equivalent level of safety will be provided. **14 C.F.R. § 91.109: Flight instruction:**  Section 91.103 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. UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplish ed through the use of a radio transmitter that communicates with the aircraft via a receiver in the UAS. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in exper imental 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. **14 C.F.R. § 91.119: Minimum Safe A lti**  **tudes.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 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 UAS that is a helicopter and a UAS Fixed wing and the exemption requests authority to operate at altitudes up to 400 AGL an exemption may be needed to allow such operations. 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 will be taken without the permission of the property owner, facility owner and local officials. Because of the advance notice to the property owner and participants all affected individuals will be aware of the planned flight operations as set forth in the Manual. Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55 lbs. 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 the aerial photography industry. In addition, the low

altitude operations of the UAS will ensure separation between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 11063, 110 64, 11065, 11066, 11067 and 11080.Pg **11** of **13**

**14 C.F.R. § 91.121: A ltimeter Settings.**  This regulation 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 avail able before departure.” As the UAS in at least one operating mode will not have a barometric altimeter, but instead a GPS altitude read out, an exemption will be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062, 11063 , 11064, 11065, 11066, 11067 and 11080. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions.** Section 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 UAS provides approxi mately 40 minutes of powered flight. To meet the 30 minute reserve requ irement in 14 C.F.R. § 91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UAS’s proposed f light area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable. Applicant believes that an exemption from 14 C.F.R. § 91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151(a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives who hav e signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Gulf Coast Helicopters believes that an equivalen t level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to ret urn the UAS to its planned landing zone from anywhere in its limited operating area. S imilar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.Pg **12** of **13**

**14 C.F.R. §91.203 (a) and (b): Carry ing Civil A** **ircraft 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 a ppropriate 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 o r cockpit entrance so that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. and is operated without an onboard pilot. As such, there is no ability or place to carry certification and reg istration documents or to display them on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to the UAS. 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.F.R. §§ 91.405(a); 407(a)(1); 409(a)(2); 417(a) and ( 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 sect ion, 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 and operating handbook as referenced in the Flight Operations and Procedures Manual (FOPM) attached as confidential Exhibit 2. (See) 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 areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the FOPM, 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. The FAA has granted exemptions for similar operations in Exemptions 11062, 11063, 11064, 11065, 11066, 11067 and 11080.Pg **13** of **13**