NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

July 16 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform

Act of 2012

Dear Sir or Madam,

This petition is being submitted on our behalf without legal counsel or consulting services.

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and

Reform Act of 201 2 (Reform Act) and 14 C.F.R. Part 11, Nevada Business Aviation Association (NVBAA ) hereby applies for an exemption from Federal Aviation Regulations (FARs) identified below, to allow commercial operations of s mall U nmanned A ircraft S ystems (sUAS)

. NVBAA is a 501(c)3 non

- profit education public charity with a focus on providing STEM Education for underrepresented and at

- risk teens by creating pathways to aviation, aerospace and UAS

.

The proposed operations include the following:

• Data Acquisition

• Education and Research • Training

As described more fully below, the requested exemption would permit the operation of sUAS under controlled conditions in airspace that is limited, predetermined, and controlled as to access. Approval of this exemption will positively impact the growth and advancement of the fields listed above, assist in educational outreach, and provide the opportunity to research solutions for current challenges in conducting safe and efficient UAS flights , thereby contributing a benefit to the general public

. NVBAA’s e ducation programs and summer internships are focused on providing practical, real

- world applications of UAS technologies through c lassroom instruction, cutting

- edge simulation training and hands

- on vehicle operations. To tha t end, NVBAA intends

to use UAS for educational research, trainin g, and data acquisition on UAS operational conc epts and safety.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

The name and address of the applicant is:

Company Name: Nevada Business Aviation Association

Contact Name: Reza Karamooz

Address: 404 S Boulder Hwy, U nit 90124

Henderson, NV 89009

Phone: 702

- 508

- 9888

Email: reza @nvbaa.org

Regulations from which the exemption is requested:

• 14 CFR Part 21, Subpart H

– Airworthiness Certificates • 14 CFR 45.23 (b)

– Aircraft Marking • 14 CFR 61.113 (a)

– Pilot in Command • 14 CFR 91.7 (a)

– Civil Aircraft Airworthiness • 14 CFR 91.9 (b) (2)

– Document/Flight Manuals

• 14 CFR 91.103

– Preflight Action

• 14 CFR 91.109

– Flight Instruction

• 14 CFR 91.119

– Minimum Safe Altitude

• 14 CFR 91.121

– Altimeter Se tting • 14 CFR 91.151 (a) (1)

– Fuel Requirements for VFR Flight • 14 CFR 91.203 (a) & (b)

– Civil Aircraft: Certifications Required • 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)

– Maintenance and Maintenance Inspections

The extent of relief fo r each section or sections of 14 CFR are outlined in Appendix A.

The requested exemption would authorize NVBAA to operate the DJI Inspire 1, DJI Ph antom 1,

DJI Phantom 2 Vision + , DJI Phantom 3, DJI S900, and DJI S1000+ for the proposed operations.

All sUAS flights utilizing the list of sUAS will be conducted over private or controlled access property with the knowledge and consent of the property owner. When persons are found in photos or videography, a reasonable effort will be made to identify and not ify persons, and their photos/footage us ed only with their consent. All operations of NVBAA will adhere to strict operating requirements and conditions to ensure an equivalent standard level of safety to currently authorized operations using manned aircraf t.

In addition, NVBAA will adhere to a modified Model Aircraft Operating Standards, outlined

below:

• The petitioner will only operate its sUAS in line

- of

- sight of a pilot and/or observer and will operate at sites that are ‘sufficient distance’ from p opulated areas within the sterile area described in the Flight Operations Procedure Manual. Such operations will ensure that the sUAS will “not create a hazard to users of the national airspace system or the public.”NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

• When flying the sUAS within three ( 3) miles of an airport, airport operators will be notified and the operator will give the right

- of

- way to avoid flying in the proximity of full

scale aircraft.

• Maximum flight time for each operation will be 60 minutes.

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the sUAS.

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400

feet AGL.

• Minimum crew for each operation shall consist of a sUAS pilot and a visual sUAS

observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including all payload (e.g., sensors, camera, lens, and stabilized gimbal).

• The sUAS will operate at speeds of no more than 87 knots (100 mph), can ho ver, and can simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which it will operate, NVBAA’s operations adhere to the Reform Act’s safety requirements.

Due to their small size and the fact that they carry no fuel, all models of the DJI UAS proposed

for this exemption request pose a very low risk of damage to persons or structures on the ground. Because these sUAS are electric powered, they create no harmful emissions and ma ke very little noise (compared to traditional aircraft).

Under the requested exemption, NVBAA will ensure all operators have completed sUAS education and training programs including all applicable regu lations and guidance documents; aeronautical backgroun d information such as Charts, NOTAMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic sUAS Aerodynamics; Weather factors; Airmanship and Decision

- making and Safe Operations

Procedures. NVBAA will e nsure the Operator in Command (OIC) has a minimum of a FAA

Private Pilot License.

We respectively request exemption under Section 333 to enable NVBAA to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

Summary the FAA may publish in the Federal Register

NVBAA seeks an exemption from the following Regulations: 14 CFR Part 21, Subpart H; 14 CFR 45.23 (b); 14 CF R 61.113 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) and 14 CFR 91.417 (a) & (b) to

utiliz e small unmanned aircraft systems to support a variety of industry and business applications, to include, but not limited to, Data Acquisition

, Education and Research , and Training

. NVBAA will provide education and training opportunities that will accelerate the spread of knowledge about safe UAS operations in the n ational a irspace s ystem

. Grantin g NVBAA’s request for exemption will reduce current risk levels and thereby enhance safety.

Further, NVBAA sUAS will operate at lower altitudes (up to 400 feet AGL) in predetermined and controlled airspace, weigh less than 55 pounds, and will travel at speeds less than 87 knots (100 mph). The use of these parameters will provide at least an equivalent level of safe ty as that achieved under current Federal Aviation Regulations.

NVBAA respectfully requests that the Federal Aviation Administration (FAA) grant its exemption request without delay. The FAA has the authority to issue the exemption sought by

NVBAA pursuan t to the Federal Aviation Act, 85 P.L.726 (1958).

Sincerely Requested,

Reza Karamooz

President & Founder

Nevada Business Aviation Association

404 S Boulder Hwy

, Unit 90124 Henderson, NV 89009 reza@NVBAA.org

702

- 879

- 8796

Document prepared by:

Stephen Hong Daniel Wang

UAS Committee Chair UAS & Education Committee Member

Nevada Business Aviation Association Nevada Business Aviation Association stephen @ NVBAA.org daniel@ NVBAA.org

702

- 879

- 5525 702

- 879

- 8835NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

APPENDIX A: Justification of Requested Exemptions in Title 14 CFR

14 CFR Part 21, Subpart H

– Airworthiness Certificates

The procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 91.203 (a) (1).

Given the small size of the sUAS, the contr olled operating areas, limitations and conditions,

NVBAA will adhere to during flight operations, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the “Reform Act” with consideration “of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS.”

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

co nsideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated are less than 55 lbs. fully loaded, carry neither a pilot nor passenger, carry no explosive materials or flammable liquid fuels, and will operate exclusively within a secured and designated area. Unlike other civil aircraft, operations under th is exemption will be tightly controlled and monitored by the operator pursuant to the Manual’s requirements. The FAA will have advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the UAS,

due to its siz e, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

14 CFR 45.23 (b)

– Aircraft Marking

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.

An exemption will 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 may 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.”

14 CFR 61.113 (a)

– Pilot in Command

(a) Except as provided in paragra phs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have only a private pilot’s license rat her than a commercial pilot’s license to operate a sUAS. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial

activities outlined in 14 CFR 61.

14 CFR 91.7 (a)

– Civil Aircraft Airworthiness

(a) No pers on may operate a civil aircraft unless it is in an airworthy condition.

Inasmuch as there will be no airworthiness certificate issued for the UAS, NVBAA seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy cond ition to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. See Grant of Exemption to Astraeus Aerial, Docket No. FAA

- 2014

- 0352 at 13

- 14, 22 . Accordingly, Petitioner requests that the requirements for § 91.7(a) be treated in accordance with Section V(A), supra. D. 1NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

14 CFR 91.9 (b) (2)

– Document/Flight Manuals

(b) 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.

Given the small size and configuration of the UAS, it would be impossible to keep airworthiness documents and other aircraft manuals on board the UAS, because there is simply no room and the UAS has no cabin or cockpit.

14 CFR 91.103

– Preflight Action

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and fo recasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the follow ing takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For c ivil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and w ind and temperature.

NVBAA seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA

approved Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely conduct the flight, an exemption is requested to the extent that an FAA

approved Flight Manual is required.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

14 CFR 91.109

– Flight Instruction

(a) 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. However, instrument flight instruction may be given in an airplane that is equippe d with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when

— (1) The instructor has determined that the flight can be conducted safely; and (2) The person manipulating the controls ha s at least a private pilot certificate with appropriate category and class ratings. (b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check required by §61.57 when

— (1) The airplane is equipped with operable rudder pedals at both pilot stations; ( 2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight; (3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has lo gged at least 25 hours of pilot

- in

- command flight time in the make and model of airplane; and (4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless

— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. (2) The safety pilot has adequate vision forward and to eac h side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and (3) Except in the case of lighter

- than

- air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulat ed instrument flight may be conducted in a single

- engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when

— (i) The safety pilot has determined that the flight can be conducted safely;

and (ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. (d) No person may operate a civil aircraft that is being used for a flight test for an airline

transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

NVBAA seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that "[n]o 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 control s." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished through the use of a device that communicates with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

14 CFR 91.119

– Minimum Safe Altitude

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhere . An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (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 1,0 00 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (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 ma y not be operated closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft . If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopte r may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parach ute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

NVBAA requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 91.119 prescribes the minimu m safe altitudes under which aircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, or

structure in non

- congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at l ess than those minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA." An exemption is required because in order to perform the intended operations, the UAS will need to be operated lower than 400 feet AGL. Further, due to the nature of the proposed operations, persons involved in the flight may be closer than 500 feet.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

14 CFR 91.121

– Altimeter Setting

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— ( i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of a n appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92′′ Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

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." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Checklist, confirming the

altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151 (a) (1)

– Fuel Requirements for VFR Flight

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 that for at least 30 minutes; ...

Here, the technological limitations on UAS battery power means that no meaningful flight operations can be conducted while still maintaining a 30

- minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required

.

14 CFR 91.203 (a) & (b)

– Civil Aircraft: Certifications Required

(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. Each U.S. airw orthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of the applicable operations specifications issued under §21.197(c) of this chapter, appropriate sections of the air carrier manual required by parts 121 an d 135 of this chapter containing that portion of the operations specifications issued under §21.197(c), or an authorization under §91.611) must have on it the registration number assigned to the aircraft under part 47 of this chapter. However, the airworth iness certificate need not have on it an assigned special identification number before 10 days after that number is first affixed to the aircraft. A revised airworthiness certificate having on it an assigned special identification number, that has been aff ixed to an aircraft, may only be obtained upon application to an FAA Flight Standards district office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registrati on Application as provided for in §47.31(c), or a registration certification issued under the laws of a foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888

Sections 91.203(a) and (b) requires all civil aircraft to have within them an appropriate and

current airworthiness certif icate and an effective U.S. registration certificate issued to its owner, which are displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The size of the UAS would not permit carrying these documents, nor does the UAS have a cockpit or cabin. Should the exemption to 14 C.F.R. § 91.7(a) (Airworthiness Requirement) above, be granted, the display of an airworthiness certificate would become moot.

An equivalent level of safety will be achieved by keeping these documents at th e ground control point where the operator flying the UAS will have immediate access to them; to the extent they are applicable to the UAS.

14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b)

– Maintenance and Maintenance Inspections

91. 405(a) Each ow ner or operator of an aircraft shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of t his chapter

91.407(a) No person may operate any aircraft that 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 this chapter

91.409(a) (1)E

xcept as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had 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) Except as provided in paragraph (c) of this section, 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.

91.417(a)Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this sectio n: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, r otor, 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 of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information:NVBAA | 404 S Boulder Hwy, Unit 90124, Henderson, NV 89009 | NVBAA.org | 702

- 508

- 9888 (i) The total time in service of the airframe, each engine, each propeller,

and each rotor. (ii) The current status of life

- limited parts o f each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of c ompliance, 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 alte ration to the airframe and currently installed engines, rotors, propellers, and appliances.

91.417 (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 other work or for 1 year 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 sol d. (3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b) only apply to aircraft with an airworthiness certificate, NVBAA requests relief from these Sections because the UAS does not require an airworthiness certificate. The UAS meets the conditions of Section 333 for operation without an airworthiness certificate. Accordingly, NVBAA will use its trained

technicians

, or other factory

- authorized technicians when available

, to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer's maintenance manual and as accomplished in the current COAs. Furthermore, NVBAA will document and maintain all maintenance records for the UAS.

NVBAA is requesting relief from these sections, Section 91.203 (a) and (b), 45.23 (b), 21.185 and 91.9(b) also would not apply.