# UA V Certification, LLC

100 HaigDrive• Myrtle Beach, SC 29579• Phone: 202;459.9941 • Fax: 202.905.0337 E-Mail:john@uavcertificationllc.comWeb:**~.**uavcertificationllc.com

October28, 2015

Honorable Michael Huerta,Administrator FederalAviation Administration U.S. DepartmentofTransportation DocketManagementSystem 1200 NewJerseyAve, SE Washington, DC 20590 ,-[fi**j~** £ .J

RE: SummaryGrantRequestfor Exemptionunder Section 333ofthe FAA Reform Actand Part 11 ofthe Federal Aviation Regulations fi·om certain parts ofthe F ARs.

DearHonorable Huerta:
Pursuantto Section 333 ofthe FAA Modernization and Reform Actof2012 (the Reform Act) and 14 C.F.R. Part 11, UAV Certification, LLC, (Petitioner) a Delaware limited liabilitycompanyherebyapplies for anexemptionfi·om d1e listed FederalAviation Regulations ("FARs") to allow itto operate a small UnmannedAircraft System ("sUAS") under d1e conditions andlimitations setford1 in d1is Petition. Applicantfurd1er requests considerationfor a "SummaryGrant" as d1is petition is identical to d1e following petitions:

-In d1e matterofCraigE. Bryan, Cirrus (RegulatOiyDocketNo. FAA-2015-0160, ExemptionissuedApril20, 2015) -In d1e matterof'Douglas Trudeau, Realtor (RegulatOiyDocketNo. FAA-2014-0481, Exemption issued]anuary5, 2015) Petitionerrequests d1atthe administratorwaive the'publishinga Summmyofd1e petition in the Federal Register as d1ese issues have alreadybeencovered a11d, delays onacting ond1is petitionwould bedetrimentaJ to d1e Petitioner. Foryourconvenience, I've enclosed a DVD with all supportingdocuments as well as d1e Petition inWordformat. Please feel free to contactme ifI Callbe ofservice.

Sincerely,

John Q. Nunes ChiefPilot& DirectorofOperations UAV Certification, LLCIdentification of Petitioner Petition for Exemption (Pursuant to 14CFR Section 11.81)

This petition for exemption is submitted on behalf of UAV Certification, LLC by John Q. Nunes, (collectively referred to as "UAV CERTIFICATION"), 106 Haig Drive, Myrtle Beach, SC 29579 (via email at: john@uavcertificationllc.com).

Petition Based Upon Prior Exemption This petition is based, in part, upon prior exemption granted pursuantto In the matterofDouglas Trudeau, Realtor(RegulatoryDocketNo. FAA-2014-0481, Exemption issuedJanuary5, 2015) and, In the matterofCraig

### E. Bryan, Cirrus (RegulatoryDocketNo. FAA-2015-0160, Exemption issued Apri/20, 2015).
Request for Exemption UAV CERTIFICATION respectfully requests relief from the following regulations for the purpose of conducting commercial

..aerial work

.. flight operations (as defined by 14 CFR Section 119.1 (e)(1) Aerial photography or survey, and Section 119.1(e)(4)(vi) Power line or pipe line patrol) Unmanned Aerial Systems C'UAS

..): Part 21 prescribing the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals. (UA V CERTIFICATIONbelieves relieffrom this section is notnecessaryunderthe statutorycriteria providedin Section 333 ofPublic Law 112-95[P.L. 112-95]in reference to 49 USC Section 44794given the size, weight, speed, andlimitedoperating area associated with the proposed UAS)

Section 45.23(b) prescribing thatwhen 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,

....light-sport,

....experimental,

.. or "provisional," as applicable. (UAVCERTIFICATIONbelieves relieffrom this section is not 1necessaryas the proposed VAS is notcertificatedunderSection 21.191 andthispetition is submittedin connection with proposedoperations as a Civil VAS)

Section 61.31 (a) prescribing that a person who acts as a pilot in command of any of the following aircraft must hold a type rating for that aircraftfor other aircraft specified by the Administrator through aircrafttype certificate procedures: (1) Large aircraft (except lighter-than-air). (2) Turbojet-powered airplanes. (3) Other aircraft specified bythe Administrator through aircrafttype certificate procedures.
(UA VCERTIFICATIONbelieves relieffrom this section is notnecessaryunderthe statutorycriteria providedin Section 333 ofP.L. 112-95in reference to 49 USC Section 44794given the size, weight, speed, andlimitedoperating area associated with theproposed VAS)

Section 61.31 (c) prescribing that unless a person holds a category, class, and type rating (if a class and type rating is required)that applies to the aircraft, that person may not act as pilot in command of an aircraftthat is carrying another person, or is operated for compensation or hire. That person also may not act as pilot in command of that aircraft for compensation or hire. (UA VCERTIFICATION believes relieffrom this section is notnecessaryunderthe statutorycriteria providedin Section 333 of P.L. 112-95in reference to 49 USC Section 44794given the size, weight, speed, andlimited operating area associated with theproposed VAS)

Section 61.31 (d) prescribing thatto serve as the pilot in command of an aircraft, a person must- (1) Hold the appropriate category, class, and type rating (if a class or type rating is required) for the aircraftto be flown; or ' (2) Have received training required bythis partthat is appropriate to the pilot certification level, aircraft category, class, and type rating (if a class ortype rating is required) for the aircraftto be flown, and have received an endorsementfor solo flight in that aircraftfrom an authorized instructor. (UA

# v CERTIFICATIONbelieves relieffrom this section is notnecessaryunderthe statutorycriteria providedin Section 333 ofP. L. 112-95in reference to 49 USC Section 44794given the size, weight, 2speed, andlimitedoperating area associated with the proposed VAS or, alternatively, requests relief from this section byPilotin Command (PIC) compliance with the applicable operationaldocuments publishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Section 91.7(a) prescribing that no person may operate a civil aircraft unless it is in an airworthy condition. (UA VCERTIFICATIONrequests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Section 91.7(b) prescribing thatthe pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. (UA VCERTIFICATIONrequests relief from this section byPilotin Command (PIC) compliance with the applicable operationaldocuments publishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in .thispetition)

Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft 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. (UAVCERTIFICATIONbelieves relieffrom this section is notnecessaryas the FAA haspreviouslydeterminedreliefis notrequiredprovided the relevant materialspublishedbythe manufacturerare keptin a location accessible to the PIC in compliance with the regulations)

Section 91.103(b) prescribing that a pilot shall for anyflight, become familiar with runway lengths at airports of intended use, and takeoff and landing distance information. (UA VCERTIFICATION believes relieffrom this section is notnecessaryprovided the PIC complies with the Proposed Conditions andLimitations setforth in thispetition)

Section 91.109(a) prescribing, in pertinent part, 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. (UA VCERTIFICATIONbelieves relieffrom this section is notnecessaryprovided the PIC complies with the Proposed Conditions andLimitations setforth in thispetition orutilizes the UAS'dualcontrol feature) 

### 3Section 91.119 prescribing that, exceptwhen necessaryfor takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unitfails, an emergency landing without undue hazard to persons or property on the surface. (UA VCERTIFICATIONbelieves relieffrom this section is notnecessaryprovidedthe Pilotin Command (PIC) complies with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions and Limitations setforth in thispetition) (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (UA VCERTIFICATIONbelieves relieffrom this section is notnecessaryprovidedthe Pilotin Command (PIC) complies with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions and Limitations setforth in thispetition) (c) Over other than congested areas. An altitude·of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, or structure. (UA VCERTIFICATION requests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions and Limitations setforth in thispetition)

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...to the elevation of the departure airport or an appropriate altimeter setting available before departure

... (UA VCERTIFICATIONbelieves relieffrom this section is notnecessaryprovided the PIC complies with the Proposed Conditions andLimitations setforth in thispetition)

Section 91.151 (a) prescribing that no person may begin 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 thatfor at least 30 minutes [emphasis added]. (UA VCERTIFICATION requests relieffrom this section byPilot



### 4in Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in 

### § 47.31 (c). (UAVCERTIFICATIONbelieves relief from this section is notnecessary, as the FAA haspreviouslydeterminedreliefis notrequired providedthe relevantmaterialspublishedbythe manufacturerandthe Proposed Conditions and Limitations are keptin a location accessible to the PIC in compliance with the regulations)

Section 91.203(b) prescribing, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate 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. (UAVCERTIFICATIONbelieves relieffrom this section is notnecessary, as the FAA haspreviously determinedreliefis notrequiredprovided the relevantmaterialspublishedbythe manufacturerand the Proposed Conditions andLimitations are keptin a location accessible to the PIC in compliance with the regulations)

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter. (UA VCERTIFICAT/ON requests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraftthat has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for return to service by a person authorized under 

### § 43.7 of the same chapter. (UA V CERTIFICATION requests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions and Limitations setforth in thispetition) 

### 5

# ---

Section 91.409(a) prescribing that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had- (1) an annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. (UA VCERTIFICATIONrequests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Section 91.417(a) and (b) prescribing, in pertinent part, that- (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records of the 1

00-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion ofthe work performed; and (iii) The signature, and certificate number of the person approving the aircraftfor return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii)The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraftwhich are required to be overhauled on a specified time basis. (iv) The current inspection status ofthe aircraft, including the time since the last Inspection required by the inspection program underwhich the aircraft and its appliances are maintained.

6(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by otherwork or for 1year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 ofthis,chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. (UA VCERTIFICATIONrequests relieffrom this section byPilotin Command (PIC) compliance with the applicable operationaldocumentspublishedbythe manufacturerandthe Proposed Conditions andLimitations setforth in thispetition)

Extent of and Reasons for Relief Sought UAV CERTIFICATION intends to operate the following commercially available UAS types:
• DJI Inspire 1
• DJI Phantom 2
• DJI Phantom 3
• Draganflyer Guardian
• Draganflyer X4-P
• Draganflyer X4-ES
• Draganflyer Commander
• Altus Delta X8
• Altus Delta LRX for the purpose of aerial work under the provisions of 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power line or pipe line patrol. UAV CERTIFICATION intends to offer commercial "aerial work" services utilizing UAS under the exemptions to 14CFR Section 135 granted under 14 CFR 119.1(e) as setforth above. Additionally, 

### 7UAV CERTIFICATION's pilot, John Q. Nunes, holds a Private Pilot Certificate (Airplane Single 

### & Multiengine Land) and a current 2nd Class Medical with an excess of 1000 hours offlight time.


### Public Interest and Benefit The above

..aerial work

.. services, normally provided in manned aircraft, may be provided with increased safety and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or replace the use of manned aircraft as a result of safety or economic considerations in certain applications where extended operational range and limited time aloft are not a factor. The proposed UAS operations will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft, minimize potential ecological affects or damage, and promote economic growth by providing data information to individuals or companies requiring aerial survey or imaging data. 

### Exemptions Provide a Level of Safety Equal to or Greaterthan the Existing Level under Current Regulations The use of UAV operated under the requested exemptions as setforth above have the capacity to operate with less risk of accident or injury and the associated loss of property or life while performing the same aerial work services offered in manned aircraft in certain situations where extended operational range and limited time aloft are not a factor.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The listed UAVs carry no fuel, and therefore the risk offire following an incident or accident due to fuel spillage is eliminated.

This petition for exemption does not propose an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology at this time. Rather the risk is mitigated by placing limits on altitude, requiring stand-off distancefrom clouds, permitting daytime operations only, and requiring that the UAVs be operated within VLOS and yield right of wayto all manned operations. Additionally, the Proposed Conditions and Limitations provide that UAV CERTIFICATION will request a notice to airmen (NOT AM) prior to operations to alert other users of the NAS.



### 8UAV CERTIFICATION's UAS' have the capability to operate safely after experiencing certain in-flight contingencies orfailures and uses an auto-pilot system to maintain UAS stability augmentation and control. The UAS is also able to respond to a loss of GPS or a lost-link event with pre-coordinated automated flight maneuvers. These safetyfeatures provide an equivalent or higher level of safety compared to a manned aircraft holding an airworthiness certificate (restricted or otherwise) performing a similar operation.



### Federal Register Summary UAV CERTIFICATION, including its pilot John Q. Nunes, seeks exemption from the following regulations for the purpose of conducting commercial

..aerial work

.. flight operations utilizing Unmanned Aerial Systems (11UAS 11 ) as setforth underthe provisions of 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol
Relief Considered (14 CFR) Part 21 45.23(b) 61.31 (a) 61.31 (c) 61.31 (d) 91.7(a) 91.7(b) 91.9(b)(2) 91.103(b) 91.109(a) 91.119 91.121 91.151(a) 91.203(a) and (b) 91.405(a) 91.407(a)(1) 91.409(a)(1) and (2) 91.417(a) and (b) FAA Consideration orAction Requested Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary (Section 333 of P.L. 112-95) *2 Relief not necessary (Section 333 of P.L. 112-95) *2 Relief not necessary (Section 333 of P.L. 112-95) *2 Relief granted in prior exemption with conditions and limitations *1 Relief not necessary pursuantto prior exemptions *1 Relief not necessary pursuantto prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief (paragraph c) granted in prior exemption with conditions and limitations *1 Relief granted in prior exemption with conditions and limitations *1 Relief (paragraph 91.151 (a)(1), day) granted in prior exemption with conditions and limitations *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1 Relief not necessary pursuant to prior exemptions *1

*1 in the matterofDouglas Trudeau, Realtor, RegulatoryDocketNo. FAA-2014-0481 *2 Relief from this section is not necessary under statutory criteria provided in Section 333 ofP.L. 112-95 in reference to 49 USC Section 44794given the size, weight, speed, and limited operating area associated with the proposed UAS 9Additional Information Offered in Support of this Petition for Exemption UAV CERTIFICATION's Chief Pilot, John 

### Q Nunes (11John

..), operated various manned aircraft, including fixed-wing aircraft since 1976. Additionally, John has operated commercially available UAS vehicles for the past 12 months for non-commercial and commercial use (under exemption #11874) in order gain flight experience and familiarity with the operating characteristics and limitations of the UAS and its videography and photography systems. Additionally, John has always contacted the local airport and/or air traffic manager and/or tower manager as a courtesy. As Standard Operating Procedure, UAV CERTIFICATION's will monitor local aircrafttraffic utilizing an iCom IC-A22 Transceiver.

As a result, it is believed there are certain aerial work situations, where the range and time aloft limitations of UAS are not a factor, whereby aerial work may be conducted with greater safety and less risk to persons or property on the ground while offering the same or improved level of aerial work product. Manned aircraft platforms such as airplanes and helicopters often subject the occupants as well as persons and property on the ground to higher levels of risk for accident or injury even while being operated pursuant to all of the applicable federal aviation regulations.

The above listed UAVs are commercially produced and a widely available aerial videography and photography platform utilizing advanced GPS enabled stability augmentation and control systems including

..failsafe

.. features allowing the operator to manuallytake control of the aircraft or initiate an automated

..return to home

.. feature in the event of adverse inflight events. The UAS also incorporates automated

..failsafe

.. features to initiate

..return to home

.. or
..auto land

.. commands in the event of loss of control signal link or diminished battery output or capacity.

The manufacturers provide comprehensive operational and safety manualsfor both UAS and all flights will be conducted in accordance with the requirements and guidance issued in these manuals.



### 10UAV CERTIFICATION statesthat§ 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. UA VCERTIFICATION's asserts thatsince there is currentlyno certificate applicable to his operation, this regulation is inapplicable.

UAV CERTIFICATION states that§ 91.9(b)(2) requires an aircraftflight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation is inapplicable. UAV CERTIFICATION further indicates an equivalent level of safetywill be achieved by maintaining a safety/flight manual with the UAS ground station.
Proposed Conditions and Limitations UAV CERTIFICATION (also hereafter referred to as the operator) proposes the following Proposed Conditions and Limitations in the form of a proposed Grant of Exemption: The following documents, including any updates or revision by the manufacturer, provided by the operator in its petition are incorporated by reference, and are hereinafter referred to as operating documents: Manuals are attached in digital mediaformat

Failure to comply with any of the conditions and limitations ofthis 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 following aircraft described in the operating documents, which are quad-rotor aircraft weighing less than 55 pounds: a) DJI Inspire 1 b) DJI Phantom 2 c) DJI Phantom 3 d) Draganflyer Guardian e) Draganflyer X4-P f) Draganflyer X4-ES g) Draganflyer Commander h) Altus Delta XB i} Altus Delta LRX 

### 11Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2) The UAS may not be flown at an indicated airspeed exceeding 87 knots.
3) The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL.
4) The UAS must be operated within visual line of sight (VLOS) ofthe Pilot in Command (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 FAAissued airman medical certificate.
5) All operations commercial "aerial work

...flight operations [as defined by 14 CFR Section 119.1 (e)(1) Aerial photography or survey, and Section 119.1(e)(4)(vi) Power line or pipe line patrol] must utilize a visual observer (VO). The UAS must be operated within the visual line of sight (VLOS) of the VO at all times. The VO may be used to satisfythe VLOS requirement as long asthe PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 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 functions prescribed in the operating documents.
6) The operating documents and this grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator mustfollow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The 

### 12operator must also present updated and revised documents if he petitions for extension or amendmentto this grant of exemption. If the operator determines that any update or revision would affectthe basis upon which the FAA granted this exemption, then the operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents.
7) Prior to each flight, the PIC must inspectthe UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.
8) Any UAS maintenance or alterationsthat affectthe UAS operation orflight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional testflight must make an entry in the aircraft records.
9) The pre-flight inspection section in the operating documents must accountfor all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

10) The operator mustfollow the UAS manufacturer's aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.



### 1312) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins.
13) The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
14) UAS operations must be conducted by a PIC possessing at least a sport pilot certificate and at least a current third-class medical certificate. The PIC must also meet the flight review requirements specified in 14CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
15) Priorto operations conducted for the purpose of flight instruction or aerial work as defined by 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power line or pipe line patrol, the PIC must have accumulated and logged, in a manner consistent with 14CFR 61.51 (b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted underthis grant of exemption to accomplish the required flight time. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14CFR 91.119.
16) Priorto operations conducted for the purpose of aerial work as defined by 14CFR, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e}(4)(vi) Power line or pipe line patrol, the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), a minimum of 5 hours as UAS pilot operating the make and model of the UAS to be used in operations underthe exemption; 5 hours make and model time may be included in the 10 hours of multi-rotortime prescribed above. The PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, experience-building, and take

### 14off and landing currency flights can be conducted underthis grant of exemption to accomplish the required flight time and 90 day currency. However, said training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience-building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14 CFR 91.119.
17) The operator may not permitthe PIC to operate the UAS for the purpose of aerial work as defined by 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power line or pipeline patrol, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51 (b), the ability to safely operate the UAS in a manner consistent with howthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.
18) UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All operations must be conducted undervisual meteorological conditions (VMC).
19) The UAS may notoperate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless, priorto such operation, the PIC coordinates and obtains authorization and airspace clearance from any National Airspace System (NAS) controlling authority having jurisdiction overthe affected airspace and establishes and maintains continuous verbal communication or contact with said authority (ATC) through radio or telephonic methods for the duration offlight.
20) The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontallyfrom a cloud orwhen visibility is less than 3 statute miles from the PIC.
21) If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.


### 1522)The PIC must abortthe flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.
23) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough powerto fly at normal cruising speed to the intended landing point and land the UAS with 30% battery power remaining.
24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations underthis grant of exemption. This COAwill also require the operatorto request a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.
25) All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.
26) Before conducting operations, the radio frequency spectrum used for operation and control of the UAS mustcomply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.
27) The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC atthe Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
28) The UAS must remain clear and yield the right of way to all manned aviation operations and activities at all times
29) The UAS may not be operated bythe PIC from any moving device or vehicle.



### 1630) The UAS may not be operated over congested or densely populated areas.
31) Flight operations must be conducted at least500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that non-participating persons remain under such protection. If a situation arises where non-participating persons leave such protection and are within 500 feet of the UAS, 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, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a).
32) All operations shall be conducted over private or controlled-access propertywith permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33) Any incident, accident, orflight 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) per instructions contained on the NTSB Web site: www.ntsb.gov

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.



### 17Respectfully submitted, 

### UAV Certification, LLC

# ~-- Chief Pilot 

### &Director of Operations



### 18