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	Modernization	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	UAS and is	familiar	with	the	operations and	the

maintenance	of	the	hardware	and	software	updates	for	these systems.	

Operations	will	involve	collection	of	aerial	imaging	and	sensor	data	to	enable	

inspections and	assessments 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	use	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	aircraft,	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,	accurately,	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	multi-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	planes 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	as	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	like	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 utilizes 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	

the	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	exemption	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	delay.
Regulations	For	Exemption	Request

Eagle	Drone	Imaging, LLC respectfully	requests	the	grant	of	an	exemption	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	detailed	request	for	regulation	exemptions is provided	in	Appendix	A	below.

Operational	Risk	Management:	Conditions	and	Limitations

The	following	are	our	proposed	procedures	and	limitations	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	daytime	hours.

2. Flights	will	be	operated	in	the	visual	line-of-sight	(VLOS) of	the	operator	

(PIC)	and	the	visual	observer (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	recommendations and the	

PIC’s	experience. Operations	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	associated	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	than 55	lbs.	with	speeds	well	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	within	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	remain	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	determined	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	vicinity	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	system	problem.		

The auto-return	function	will	be	checked	and	verified	for	proper	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	operator,	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	traditional	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	states	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	companies

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 respectfully	requests	the	FAA	grant	its	exemption	

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	the	size,	weight	and	defined	

area	of	operations	for	Eagle	Drone	

Imaging, LLC UAS	flights	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	Section	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	operated	are	less	than	

55	lbs. fully	loaded,	carry neither	

pilot	nor passenger,	carry 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	than	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	entrance	to	the	

cabin,	cockpit	or	pilot	station	on	

which	the	word	Experimental”	can	

be	placed.	Given	the	size	of	the	UAS,	

two-inch	lettering	will	not be	

possible.	The	word	“Experimental”	

will	be	placed	on	the	fuselage	in	

compliance	with	§45.29	(f).	The	

equivalent	level	of	safety	will	be	

provided	by	having	the	UAS marked	

on	its	fuselage	as	required	by	§45.29	

(f)	where	the	pilot,	observer	and	

others	working	with	the	UAS will	see	

the	identification	of	the	UAS	as	

“Experimental.”	The	FAA	has	issued	

the	following	exemptions	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	the	
Worthiness person	may	operate	a	civil	aircraft	

unless	it	is	in	airworthy condition.	

As	there	will	be	no	airworthiness	

certificate	issued	for	the	aircraft,	

should	this exemption	be	granted,	

no	FAA	regulatory	standard	will	

exist	for	determining	airworthiness.

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,	approved	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	

no	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	following	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	for	the	aircraft	

an	exemption	will	be	needed.	

Flight	information	such	as	runway	

distances	and	flight	performance	are	

not	relevant	to	the	operation	of	UAS.	

The	equivalent	action	is	that	the	PIC	

will	review airspace	considerations,

weather,	flight	battery	requirements,	

land	and	property	boundaries	with	

respect	to	takeoff	and	landing	

locations.		Manuals	for	the	UAS will	

present	on	site	of	all	operations.	

14	CFR	§91.109 Flight	

instruction;	

Simulated	

instrument	

flight	and	

certain	flight	

tests

This	section	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	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	functional	dual	

controls	for	a	number	of	aircraft	and	

for	flight	instruction	in	experimental	

aircraft.	See	Exemption	Nos.5778K	&	

9862A.	The	equivalent	level	of	safety	

can	be	achieved	as	neither	a	pilot	

nor	passengers	will	be	carried	in	the	

aircraft	in	addition	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	prescribed,	

provided	the	person	operating	the	

This	exemption	is	for	a	UAS	that	is	a	

RC	multi-prop	helicopter	with the	

exemption	requesting authority	to	

operate	at	altitudes	up	to	400	AGL.		

The	equivalent	level	of	safety	will	be	

achieved	given	the	size,	weight,	and	
helicopter	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	owner	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	

and	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	aircraft,	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	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	approximately	20	minutes	

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	operations	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	to	
authorization	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	maintain	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	

maintenance	log.

References Part	91	

General	

Operating	

and	Flight	

Rules

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Part	45	

Identification	

and	

Registration	

Marking

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Petitioning	

for	

Exemption	

Under	

Section	333	

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