## Eagle	Drone	Imaging,	LLC

Contact:	David	E

. Altobelli

11	Ascot	Park Nashua,	NH	03063

Email Daltobelli1@mac.com Phone	(603)	305

- 7705

June	25,	2015

U

. S

. Department	Of	Transportation Docket	Operations West	Building Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Avenue,	SE.,	Washington,	DC	20590

Re:	Exemption	Request	Under	Section	333	of	the	FAA	Reform	Act	and	Part	11

of	the	Federal	Aviation	Regulations

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernizat ion	and	Reform	Act	of	2012 (the reform	act)	and	14	CFR	Part	11, Eagle	Drone	Imaging

, LLC

, a	company	that	owns	and operates	Small	Unmanned	Aircraft	Systems	(UAS),	requests	to	be	exempted	from the	Federal	Aviation	Regulations	(FAR)	listed	below	so	that Eagle Drone	Imaging,

LLC may	operate	UAS	commercially	in	airspace	regulated	by	the	FAA,	as	long	as	such operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	as maybe	established	by	the	FAA	as	required	by	Section	333.

Company	Background and	Planned	Operations Eagle	Drone	Imaging,	LLC is	a	New	Hampshire	company	owned	by	David	E.	Altobelli.

Mr.	Altobelli is	a	commercially	rated helicopter pilot,	with	a	current	medical certificate	and	flight	review,	and	nearly	320	hours	as	PIC.	He	also	has an	estimated 25	hours	of	experience	flying	UA S and is	familiar	with	the	operations and	the

maintenance of	the	hardware	and	software updates	for	the se systems. Operations	will	involve	collection	of	aerial	imaging	and	sensor	data	to	enable inspections and a ssessments of	industrial	structures

, agricultural	management	and surveys,	and	photography	and	videography	( e.g. land	and	water	based	venues	for imaging	real

- estate,	natural/scenic	settings,	outings,	functions	and	events).

Equivalent	Level	of	Safety

The requested	exception	would	permit	the	operation	of	a	lightweight	(less	than	55 lbs.	total	takeoff	weight) UAS	under	controlled	conditions	for	commercial	u se	by	a certified	commercial	helicopter pilot	thereby	enhancing	safety	and	fulfilling	the Secretary	of Transportation’s ( the	FAA	Administrator’s)	responsibility	to”	establish requirements	for	safe	operation	of	such	aircraft	systems	in	national	airspace

### systems”

, Section	333(c)	of	the	Reform	Act .		The	enhanced	safety	using	a UAS	in comparison	to	a	manned	air craft,	including helicopters of	significantly	greater proportion	and	carrying	a	crew	with	flammable	fuel	is	self

- evident	and	beneficial	to the	public’s	interest,	while	being	able	to	provide	commercially	beneficial information	and	data	more	quickly,	accurat ely,	safely	and	economically	with	greatly reduced	environmental	impact.	All	operations	will	be	conducted	from	safe	and appropriate	distances	for	the	specific	operation. All	operations	will	be	performed with	the	public’s	safety	and	right	to	privacy safeguarded	at	all	times.

UAS Devices Eagle	Drone	Imaging ’s UAS ( s ) are battery

- powered, weighing	well	less	than	55 pounds	including	payload.		Our UAS	fleet	will	include	the	DJI	Phantom Series ,	the	DJI Inspire Series ,	and	the	Spreading	Wings	Series	of	RC	m ulti

- prop	helicopters.		The specific UAS (s) to	be initially included	in	our	fleet:

Parameter DJI	Phantom	2

Vision	Plus DJI	Inspire	1 Spreading	Wings

S1000+
Type 4	Prop	RC	helicopter 4	Prop	RC	helicopter 8	Prop	RC	helicopter Weight 2.7	lbs

. 6.47	lbs

. 24.2	lbs

. max Flight	Speed	(max) 29 knots 42 knots 42	knots Flight	Time 20	min

. 18	min

. 15	min

. Camera Integrated Integrated DSLR	camera



### They	operate	at	speeds	well	less	than	87	knots	and	have	the	capability	to	hover	and

move	in	the	vertical	and horizontal	plane s simultaneously	in	a	precisely	controlled manner.	Our	primary	intent	is	to	utilize	them	at	much	slower	speeds	for	our	imaging and	data	collection	applications.		As	upgrades	become	available,	we	would	like	to	be

able	to incorporate	the more advanced	systems	in	each	series into our	operations after	we	have	thoroughly	reviewed	new	documentation	and	have	trained	to	be capable	and	comfortable	with	their	flying	characteristics.

Statutory	Authority	for	Exemptions Eagle	Drone	Imaging

, LLC submits this	application	in	accordance	with	the	Reform
Act	, 112	P.L.	95	331

- 334,	seeking	relief	from	any	currently	applicable	FAR’S operating	to	prevent Eagle	Drone	Imaging

, LLC from	future	commercial	use	of	small UAS	to	operate	in	the	national	airspace	system	a s	described	below.		The	reform	Act section	332	provides	for	such	integration	of	civil	unmanned	aircraft	into	our national	airspace	system	as	it	is	in	the	public’s	interest	to	do	so. Eagle	Drone Imaging

, LLC ’ s UAS(s)	will	meet	the	definition	of	“small	unmanned	aircraft”	as defined	in	Section	331	and	therefore	the	integration	of	these	UAS	are	expressly contemplated	by	the	Reform	Act. Eagle	Drone	Imaging

, LLC would	lik e	to	operate	its’ light	weight UAS ( s ) prior	to the	time	period	by	which	the	Reform	Act	requires	the FAA	to	promulgate	rules	governing	such	aircraft.

The	Reform	Act	directs	the	Secretary	of	Transportation	to	consider	whether	certain unmanned	aircraft	systems	may	operate	safely	in	national	airspace before completion	of	the	rule	making	required	under	Section	332	of	the	reform	Act.	In

### making	this	determination,	the	Secretary	of	Transportation	is	required	to	determine which	UAS	do	create	a	hazard	to	users	of	the	national	airspace	system	or	the	public

or pose	a	threat	to	national	security	in	light	of	the	following:

- The	UAS	size,	speed,	weight	and	operational	capability

- Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas

- Operation	of	the	UAS	within	visual	line	of sight	of	the	operator

Reform	Act	333(a).	If	the	secretary	determines	that	such	vehicles	“may	operate safely	in	National	Airspace	System,	the	secretary	shall	establish	requirements	for the	safe	operation	in	national	airspace.

Eagle	Drone	Imaging

, LLC utilize s multi

- prop RC helicopters weighing	less than	55	lbs.	that	operate	at	speeds	less	than	50	knots	and	have	the	capability

to hover	and operate	in	the	vertical	and	horizontal	plane	simultaneously	in	a precisely	controlled	manner.	The	UAS	will	operate only	within	the visual

line

- of

- sight	of	the	operator	within	a controlled flight	area	and	at	400	feet above	ground	level	( AGL ) or	less.	Most	operations	are	envisioned	at	less	than 100	feet	AGL.		These	will	not	present	a	hazard	to	the	national	airspace	nor

t he	public.

The	very	small	nature	of	these	UAS	combined	with	the risk	management presented	below,	will	allow	for	the	safe	operation	greater	than	that envisioned	by	Congress	for	the	FAA	to	establish	and	by	exemption	allowing commercial	operations	of	UAS to	commence	immediately.	Also	due	to	the size	of	UAS	and	the	controlled	areas	and	the	low	altitudes	in	which	they	will operate,	approval	of	this	exe m ption	presents	no	national	security	issues	and absolutely	minimal	safety	concerns	which	have	been	mitigated through	our risk	management	process.	Given	the	clear	direction	given	in	Section	333	of the	Reform	Act,	the	authority	contained	in	the	Federal	Aviation	Act,	as amended,	the	strong	equivalent	level	of	enhanced	safety,	reduced	emissions utilizing	UAS	verses traditional	aircraft	as	well	as	the	economic	impact	of greatly	reducing	the	cost	of	aerial	data	and	imaging	acquisition	thereby benefits	the	greater	public’s	interest.	Accordingly,	the	applicant	requests	that the	FAA	grant	the	requested	exemption	without	d elay.

### Regulations	For	Exemption	Request Eagle	Drone	Imaging

, LLC respectfully	requests	the	grant	of	an	exe m ption	to	the following	specific	sections	of	the	Title	14	Code	of	Federal	regulations	allowing	it	to operate	lightweight	UASs	for	commercial	use:

Regulation Brief	Description

14	CFR	21,	subpart	H Air	Worthiness	Certificates

14	CFR	45.23	(b) Identification	and	Registration Marking

14	CFR	91.7	(a) Civil	Aircraft	Worthiness

14	CFR	91.9	(b)	(2) Civil	aircraft	flight	manual, marking,	and	placard requirements

14	CFR	91.103	(b) Preflight	action

14	CFR	91.109 Flight	instruction;	Simulated instrument	flight	and	certain	flight

tests

14	CFR	91.119 Minimum	safe	altitudes

14	CFR	91.121 Altimeter	settings

14	CFR	91.151(a) Fuel	requirements	for	flight in	VFR

conditions

14	CFR	91.203(a)	&(b) Civil	Aircraft:		Certifications required

14	CFR	91.405(a) Maintenance	required

14	CFR	91.407(a)(1) Operation	after	maintenance, preventive	maintenance, rebuilding,	or	alteration.

14	CFR	91.409(a)&(b) Inspections



### A more	detail ed request	for	regulation	exemption s is provided i n	Appendix	A	below

.

Operational	Risk	Management: Conditions	and	Limitations

The	following	are	our	proposed	procedures	and	limita tions	for	the	flight	operations

of Eagle	Drone	Imaging

, LLC .		These	proposed	guidelines	will	be	modified	as	such

from	recommendations provided	by the	FAA	in	conjunction	with	the	submission	of this	request:

1. Flights	will	only	occur during the	day time	hours

. 2. Flights	will	be	operated	in	the	visual	line

- of

- sight	(VLOS) of	the	operator ( PIC)	and	the	visual o bserver (VO)	using	human	vision	with	no supplemental	devices	other	than	corrective	lenses

. 3. Flights	will	be	terminated	at	any	time the weather	and	wind	deteriorate	to being “unsafe	for	flight”	based on manufacturers	r ecommendations and the PIC’s	experience

. O perations	will	follow	the anticipated	guidelines	of	this

### exemption	(operations	under	visual	meteorological	conditions

- VMC,	and standard	visual	flight	rules

- VFR)

4. All	documents,	manuals	and	maintenance	logs	associate d	with	the	UAS	will be	present	on	the	site	of	operations.		In	addition,	the	credentials	of	the	PIC (pilot	certificate,	pilot	logbook with current	flight	review

, current	medical

, and	proper	identification )	will	be	available	onsite.

5. The UAS	will	be	assessed for	airworthiness by	the	PIC prior	to	each	flight session	using	a	checklist	derived	from	the	manufacturers	manual.		All necessary	calibrations	and	testing	prior	to the flight session will	be performed.

6. The	UAS	will	weigh	less	tha n 55	lbs.	with	speeds	wel l	less	than	87	knots.

7. Flights	will	be	operated	at	400	feet	AGL	or	less,	or	as	defined	from	the outcome	of	this	request	for	exemption.

8. Crew	will	be	at	a	minimum	of	the	operator	(PIC)	and	an	observer	and/or

camera	operator (VO).		The	PIC	will	be	responsible	for	flying	the	UAS	and monitoring	its	status	and	flight	dynamics,	while	maintaining	line	of	sight visualization	and	keeping	the system operations	withi n	the	specified factory	limits	( e.g. flight	range,	battery	power,	etc. ).		The	VO	will	be involved	in	monitoring	the	airspace	for	other	aircraft,	the	ground	for unintended	vehicles	and	bystanders,	and	will	also	look	for	additional hazards	that	could	compromise	safe	operations.

9. Operator	(PIC)	and	crew,	including	the	VO	will	r emain	in	voice	contact during	the entire flight	operation

10. Prior	to	operations,	weather	forecasts,	weather	radar,	and	air	traffic patterns	for	the	area	will	be	reviewed.		The	proximity	of	the	intended location	with	respect	to	airports	and	TFRs	will	be	deter mined	using Foreflight	software	on	our	iPad	or	mobile	phones.	If	operations	are anticipated	within	5	nautical	miles	of	airport	reference	points,	the	airport management	or	Air	Traffic	Control		(ATC)	tower	will	be	notified	prior	to the	operation,	identifying the	location,	anticipated	time,	and	the	intent	of flight	operations.	We	will	also	have	available	a	hand

- held	portable	radio	to enable	monitoring	of	local	air	traffic and to	establish,	if	necessary,

communication	with	the	local	tower.			When	in	the	vicinit y	of	non

- towered airports,	we	will	monitor	air	traffic	in	the	area and be	able	to inform	them of	our	operations as	needed

. 11. The UAS	PIC	will	perform	a	final	check	of	the	flight	area	and	make	certain of	the	safety	of	all	persons	present	and	property	in	the controlled	area prior	to	initiating	flight	operations.

12. All	UAS	will	have	the	capability	to	return	automatically	to	the	operator	in	a

safe	manner in	the	event	of	lost	RC	communication	or	a	sys tem	problem

. The auto

- return	function will	be checked	and	verif ied	for	p ro per	operation on	a	regular	basis

. A	starting	GPS	home

- position	will	be	established	prior to	continuing	each	new	flight.

13. The	UAS	will	have	indicators	on	the	control	and/or	displays	to	inform	the operator	of	the	UAV’s	distance	away	from	the	operat or ,	its	altitude and velocity, and	its remaining battery	power.

### 14. Written	and/or	oral	permission	from	the	relevant	property	holders	will	be

obtained when	flights	are	conducted	over	private	or	controlled	access
property

.

Benefits	to	the	Public as	a	Whole

Approval	of	these	333	exemptions	in	general	would	allow	commercial operations	of	small	UAS	to	provide	numerous	services	that	would	benefit	from aerial	imaging	and	data	collection	while	greatly	enhancing	safety	by	reducing

the	overall	risk	associated	with	t raditional	aircraft.	Traditional	aerial	imaging requires	large	aircraft ,	such	as	helicopters, with	flammable	fuel	to	fly	in	close proximity	of	populated	areas	and	people	and often in	sub

- optimal	s t ates	of their	height

- velocity	curves.	With	the	use	of	small UAS	of	55	lbs.	or	less	that are	battery	operated	and	flying	below	400	feet	AGL,	the	risk	of	injury	of	people on	the	ground	or	the	crew is greatly	minimized	in	comparison.	The	granting	of the	use	of	these	small	UAS	by Eagle	Drone	Imaging

, LLC will	allow co mpanies like	ours	to	grow	and	provide	career	opportunities	while also	enabling safe and	beneficial	free	enterprise	services	that	would	assist	other	companies	in

their	business	and also provide	enjoyment	and	information	to	the	general public.

Eagle	Drone Imaging,	LLC respectfull y	requests	the	FAA	grant	its	ex e m ption without	delay.	The	FAA	has	the	authority	to	issue	the	exemption	sought	by Eagle	Drone	Imaging

, LLC pursuant	to	the	Federal	Aviation	Act,	85	P.L.	726 (1958)	as	amended	(the	ACT).

Please	contact me	if	I	can	provide	additional	information	and	clarity	to	help expedite	the	process.

Sincerely

David	E.	Altobelli Eagle	Drone	Imaging ,	LLC
11	Ascot	Park Nashua,	NH	03063

Daltobelli1@mac.com


### Cell	603

- 305

- 7705

Commercial	Pilot	Rotorcraft

- Helicopter Certificate	Number:	3358875	(20	Nov	2010)

### Appendix	A :		Regulations	for	Requested	Exemption

Regulation Code Brief Description Regulation Description Justification	for	Regulation Exemption
14	CFR	21, subpart	H,

14	CFR § 91.203 (a)	(1) Air

Worthiness

Certificates Subpart	H,	entitled	Airworthiness Certificates,	sets	forth	requirements for	procurement	of	necessary

airworthiness certificates	in	relation

to	FAR § 91.203(a)(1). Given	t he	size,	weight	and	defined area	of	operations	for Eagle	Drone Imaging

, LLC UAS	flight s	permits exception	from	Part	21	because	they 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 USC	4470(f)	and	Secti on	333	of	the Reform	Act.	Both	pieces	of legislation	permit	the	FAA	to	exempt

UASs	from	airworthiness	certificates in	consideration	of	weight,	size, speed,	maneuverability	and proximity	to	areas	such	as	airports and	dense	populations. The	UAS	to	be	operate d	are	less	than

55 lbs. fully	loaded,	carr y neither pilot	nor passenger,	carr y no explosive	materials	or	flammable fuels,	and	operates	within	a	secured

controlled area.		Operations	under this	exemption	will	be	tightly

controlled	and	monitored	to	ensure safe	operations.

14	CFR § 45.23 (b) Marking	of

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	tha n	2	inches	nor more	than	6	inches	high,	the	words "limited,"	"restricted,"	"light

- sport," "experimental,"	or	"provisional,"	as applicable. Even	though	the	UAS	will	have	no airworthiness	certificate,	an exemption	may	be	needed	as	the

UAS	will	have	no	entra nce	to	the cabin,	cockpit	or	pilot	station	on which	the	word	Experimental”	can be	placed.	Given	the	size	of	the	UA S

, two

- inch	lettering	will not be possible.	The	word	“Experimental” will	be	placed	on	the	fuselage	in compliance	with	§45.29	(f).	The equivale nt	level	of	safety	will	be provided	by	having	the	UA S marked on	its	fuselage	as	required	by	§45.29 (f)	where	the	pilot,	observer	and others	working	with	the	UA S will	see

the	identification	of	the	UAS	as “Experimental.”	The	FAA	has	issued the	following	exem ptions	to	this regulation	to	Exemptions	Nos. 10700,	8738,	10167	and	10167A. If required,	the	N	registration	number will	also	be	displayed	on	the	fuselage in	a	font	size	appropriate	for	the

dimension	of	the	device	for identification	purposes.

14	CFR § 91. 7	(a) Civil	Aircraft The	regulation	requires	that	no Given	the	size	of	the	aircraft	and	theWorthiness 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	regul atory	standard	will exist	for	determining	airworthiness. requirements	contained	in	the Manufacturers	Operating	Manual	for maintenance	and	use	of	safety

checklists prior	to	each	flight,	an equivalent	level	of	safety	will	be provided.

14	CFR § 91.9	(b) (2) Civil	aircraft flight	manual 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,	appr oved	manual material,	markings,	and	placards,	or any	combination	thereof. The	UAS,	given	its	size	and configuration	has	no	ability	or	place to	carry	such	a	flight	manual	on	the aircraft,	not	only	because	there	is	no pilot	on	board,	but	because	there	is

n o	room	or	capacity	to	carry	such	an

item	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	UAS with

immediate	access	to	it.	The	FAA	has

issued	the	followin g	exemptions	to this	regulation:	Exemption	Nos.
8607,	8737,	8738,	9299,	9299A, 9565,	9565B,	10167,	10167A, 10602,	32827,	and	10700.

14	CFR § 91.103 (b) Preflight

action This	regulation	requires	each	pilot

in	command	become	familiar	with all	information	concerning	that flight	including	runway	distances and	takeoff	and	landing	distances, with	this	data	provide	in	FAA approved	rotorcraft	flight	manuals will	not	be	provided	f or	the	aircraft an	exemption	will	be	needed. Flight	information	such	as	runway distances	and	flight	performance	are not	relevant	to	the	operation	of	UA S

. The	equivalent	action	is	that	the	PIC

will	review airspace	considerations, weather,	flight	battery	r equirements, land	and	property	boundaries	with respect	to	takeoff	and	landing

locations.		Manuals	for	the	UA S will present	on	site	of	all	operations.

14	CFR § 91.109 Flight
instruction;

Simulated

instrument flight	and certain	flight

tests This	section	p rovides	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	are	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	fun ctional	dual

controls	for	a	number	of	aircraft	and for	flight	instruction	in	experimental aircraft.	See	Exemption	Nos.5778K	& 9862A.	The	equivalent	level	of	safety can	be	achieved	as	neither	a	pilot nor	passengers	will	be	carried	in	the

aircraft	in	additio n	to	the	small	size and	low	speed	of	the	aircraft.

14	CFR § 91.119 Minimum

safe	altitudes 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	prescrib ed, provided	the	person	operating	the T his	exemption	is	for	a	UAS	that	is	a

RC	multi

- prop helicopter with the exemption	request ing authority	to operate	at	altitudes	up	to	400	AGL. The	equivalent	level	of	safety	will	be achieved	given	the	size,	weight, andhelicopter	complies	with	any	route or	altitudes	prescribed	for helicopters	by	the	FAA. speed of	the	UAS as	well	as	the location	where	it	is	operated.	No flight	will	be	taken	without	the permission	of	the	property	own er	or local	officials.

14	CFR § 91.121 Altimeter 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	available	before	departure.” The UAS typically 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,	pursuant	to	the	Manual

an d	Safety	Check	list,	by	receiving altitude	information	via	a	digitally encoded	telemetric	data	feed,	which

downlinks	from	the	aircraft	to	a ground

- based	on

- screen	display.

This	altitude	information	will	be generated	by	equipment	installed	on

board	the	airc raft,	using	GPS triangulation,	or	digitally	encoded barometric	altimeter,	or	radio altimeter,	or	any	combination thereof.	Prior	to	each	flight,	a	zero altitude	initiation	point	will	be

established ,	recorded and	confirmed for	accuracy	by	the	pilot.

14	CFR § 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	conditio ns unless	(considering	wind	and forecast	weather	conditions)	there is	enough	fuel to	fly	to	th e	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	approximately	20	minu tes of	powered	flight.	To

meet	the	30	minute	reserve requirement	in	14	CFR	§91.151,	UAS flights	would not	be	practical .	Given

the	limitations	on	the	UAS’s proposed operations	are	within	the

“line

- of

– sight”	distances,	flight

durations	will	instead	be	determined by	remaining	battery	life. Telemetry	indicators	provide indication	of	remaining	battery	life. At	25	percent	remaining	battery	life, the	sequence	to	bring	op erations	to completion	will	be	initiated.	Similar exemptions	have	been	granted	to other	operations,	including Exemptions	2689F,	5745,	10673,

and	10808.

14	CFR § 91.203(a)	&(b) Civil	Aircraft:

Certifications required 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 The	UAS	fully	loaded	weighs	no

more	than	55 lbs. 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 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	toauthorization	issued under	§91.715 is	displayed	at	the	cabin	or	cockpit entrance	so	that	it	is	legible	to

passengers	or	crew. 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	CFR § 91.405(a) § 91.407(a)(1) § 91.409(a)&(b) Operation

after
maintenance, preventive
maintenance, rebuilding,	or

alteration. 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	part43	of	this chapter...,”	and	others	shall	inspect

or	mai ntain	the	aircraft	in compliance	with	Part	43. Given	that	these	sections	and	Part	43 apply	only	to	aircraft	with	an airworthiness	certificate,	these sections	will	not	apply	to	the applicant. The	operator	pursuant	to the	flight	manual	and	operating

handbook will	accomplish

maintenance .	Software	and	firmware

will	be	maintained	with	current

versions.	As	the	manufacturer	does not	provide	specific	maintenance instructions,	maintenance	will	be

“on	condition”	for	all	aircraft	and

each	aircraft	will	have	a

maintena nce	log.

References Part	91

General Operating and	Flight

Rules weblink

Part	45

Identification

and Registration Marking weblink

Petitioning

for Exemption

Under

Section	333 weblink