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February 5, 2015

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140 Electronically Submitted

1200 New Jersey Avenue, SE via www.regulations.gov

Washington, DC 20590

Regarding:

Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 and Part 11 

of the Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 

91.109(c); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 

91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization Reform Act of 2012 (Reform Act) and 14 

CFR Part 11, National UAS Solutions, LLC which is an owner and operator of Small 

Unmanned Aerial Systems (sUAS) equipped to conduct commercial training of sUAS pilots in 

the vital interest of safety and videography and photography of real estate property for the 

purpose of constructing virtual tours, hereby petitions to be exempt from current Federal 

Aviation Administration (FAA) regulations that affect manned aircraft but is not applicable to 

unmanned aircraft. National UAS Solutions, LLC feels this exemption should be granted as 

long as such operations are conducted within the scope and conditions outlined herein or as may 

be established by the FAA as required by Section 333.

The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS 

may operate safely in the national airspace system (NAS) before completion of the FAA’s plan 

and rulemaking to integrate sUAS into the NAS. The Reform Act directs the Secretary to 

consider which types of sUAS as a result of their size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation with visual line of sight do not create a 

hazard to users of the NAS or a threat to national security.

The founder of National UAS Solutions, LLC is Charles Ray O’Neal, Jr. Mr. O’Neal is a 

commercial jet pilot that has made his living flying corporate aircraft for over forty years. He 

holds a FAA issued Airline Transport Pilot’s license along with a Certified Flight Instructor 

Airplane, Multi-engine Land Instructor and Instrument Instructor ratings and has accumalated 

over 12,600 hours of pilot in command time. Recognizing the need for sUAS pilots to possess 

the same knowledge of the NAS as FAA licensed airplane pilots, National UAS Solutions, LLC 

and founder Charles Ray O’Neal, Jr. agree with the FAA that training must take place in the 

interest of public safety for this integration to take place.

The granting of this exemption request will provide immediate benefit to both the aircraft pilot 

training industry and real estate industry by authorizing highly controlled sUAS operations 

within Class G airspace, at or below 400 feet above ground level (AGL), in visual line of sight 
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(VLOS) of an FAA Certified Private Pilot holding at least a Class 3 medical certificate during 

daylight hours and above controlled privately owned and operated property. Recognizing the 

pilot shortage today and the decreasing amount of student pilot startups in recent years, National 

UAS Solutions, LLC believes this is one way the public could benefit by motivating them to 

start their new adventure into the exciting world of aviation.

National UAS Solutions, LLC will operate sUAS that will weigh less than 55 pounds including 

the payload. They will operate at no more than 50 knots and have the capability to hover and 

move vertically and horizontally at the same time. Operations would be conducted above 

privately owned and operated properties, with the consent of the owner/operator. All National 

UAS Solutions, LLC operations will be performed by highly trained professional FAA licensed 

pilots thereby insuring that the sUAS will “not create a hazard to users of the national airspace 

system or the public.”

The granting of this exemption request is in the public interest, does not create a hazard to users 

of the NAS or the public, or pose a threat to national security.

In the following pages National UAS Solutions, LLC will address all areas of concern to 

include the exceptions requested and equivalent levels of safety.

The name and address of the applicant is:

National UAS Solutions, LLC

Attention: Charles R. O’Neal, Jr.

Phone: (337) 288-1793

Email: coneal1976@hotmail.com

Address: 104 Raphael Drive

Lafayette, Louisiana 70508

National UAS Solutions, LLC appreciates your consideration in this matter.

Best regards,

Charles R. O’Neal, Jr.

President

National UAS Solutions, LLC

To follow this exemption letter and/or upon request:

 National UAS Solutions, LLC Operating Manual

 National UAS Solutions, LLC Aircraft Inspection Program

 National UAS Solutions, LLC Training Syllabus

 National UAS Solutions, LLC Civil COA

 Aircraft Manufacturer’s User’s Guides
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Professional sUAS Flight Training Serves the Public Interest

1. sUAS integration into the NAS without proper flight training is inherently dangerous.

2. sUAS pilot flight training and experience can only be obtained as a “hobbyist”. 

There is no professional mechanism where FAA pilots can receive sUAS aircraft 

flight training and compensation within the United States of America under current 

rules and regulations.

3. Providing an avenue of professional flight training for sUAS pilots in a controlled 

environment, by professional FAA Certified Flight Instructors is crucial to the safe 

integration of sUAS into the NAS.

4. Training in rural areas, within Class G airspace, at or below 400 feet AGL, away from 

any non-participating personnel provides for an increased level of safety and is 

therefore in the public interest.

Real Estate Videography/Photography by sUAS serves the 

Public Interest

1. Aerial videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small 

budget real estate companies and average homeowners the expense of such aerial 

videography is cost prohibitive.

2. Only large companies or high-end realtors or luxury homeowners can afford to absorb the 

expense of manned aircraft videography. This deprives small budget real estate 

companies and the average homeowner of a very valuable marketing tool.

3. Manned aircraft pose a threat to the public through potential catastrophic loss or crash of 

a large aircraft. Loaded with explosive hydrocarbon based fuel, a much larger risk is 

imposed on the general public than a small, less than 55 pounds, sUAS that is powered by 

a small battery.

4. National UAS Solutions, LLC will eliminate the above problems by offering the use of 

a small, ultra-light weight sUAS that is powered by a no emission battery and is very

inexpensive to operate and own as compared to a large manned aircraft. This serves the 

public interest by making such operations safer and much more affordable.

. 
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NATIONAL UAS SOLUTIONS, LLC

1. National UAS Solutions LLC is led by Charles R. O’Neal, Jr. who is a lifelong

corporate pilot that started his training in 1970 at the age of 15. He had his first corporate 

flying job in 1974 flying a seaplane for an oil company along the Louisiana Gulf Coast. 

He started flying remote control (RC) model aircraft in 1987.

2. National UAS Solutions, LLC team’s expertise consist of two Airline Transport Pilots, a 

Certified Flight Instructor-AIM, a Mechanical Engineer and three Real Estate 

consultants. The pilots have more than 50 years of aviation management experience.

3. National UAS Solutions, LLC has extensive knowledge and experience in Commercial 

Aviation, Flight Instruction and RC model aircraft.

NATIONAL UAS SOLUTIONS, LLC Experience

As professional pilots, National UAS Solutions, LLC understands and agrees with the FAA that 

safety is paramount and will ALWAYS hold SAFETY ahead of any commercial endeavor.

1. Individuals within National UAS Solutions, LLC have only operated sUAS as 

hobbyists. To date, National UAS Solutions, LLC members have not engaged in any 

commercial activity to ensure it is in compliance with any applicable FARs, local, state 

and federal laws.

2. National UAS Solutions, LLC has a detailed sUAS Operating Manual which includes 

an Aircraft Inspection Program and Training Syllabus that it shall follow, should this 

exemption be approved.

NATIONAL UAS SOLUTIONS, LLC sUAS Description

National UAS Solutions, LLC intends to use and operate DJI Phantom 2 Vision+ sUAS 

multirotor aircraft for the purpose of sUAS Flight Training and aerial real estate videography and 

photography.

These aircraft have fail safe features that include, but are not limited to, geo fencing and lost link 

return to home capability. In addition, there are low voltage warning lights on the aircraft, and a 

low voltage warning and telemetry visual and audio warnings. There are low voltage warnings 

on the Wi-Fi range extender on screen and both visual and audio warning of low voltage on the

remote control itself.

National UAS Solutions’ sUAS SPECIFICATIONS:

Model: Phantom 2 Vision+

Weight (Battery Included): 1242g; 43.8 ounces; 2.7 pounds
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Hovering Accuracy Vertical: 0.5 m 1.6 feet

Hovering Accuracy Horizontal: 2.5 m 8.2 feet

Max Angular Velocity – Yaw: 200 degrees/second

Max Tilt Angle: 35 degrees

Max Ascent Speed: 6 m/s 19.7 feet/sec

Max Descent Speed: 2 m/s 6.7 feet/sec

Max Speed: 22 m/s 49.2 feet/sec

Max Flight Time: 25 minutes

Operating Temperature Range: -10 to +40 degrees C

Dimensions: 350mm X 350mm 14 X 14 inches

Aircraft and an Equivalent Level of Safety

National UAS Solutions, LLC proposes that the exemption requested applies to civil aircraft 

that have the characteristics and that operate with the limitations listed herein.

These limitations provide for at least an equivalent or higher level of safety to operations under 

the current regulatory structure because the proposed operations represent a safety enhancement 

to the already safe operations conducted with conventional aircraft.

This exemption Request is for Use of sUAS subject to 

Extensive Operational and Safety Requirements.

These limitations and conditions to which National UAS Solutions, LLC agrees to be bound 

when conducting commercial operations under a FAA issued exemption at a minimum include:

Safety

A. The sUAS Pilot in Command (PIC) shall possess at a minimum a private pilot license and 

current third-class medical certificate.

i) The PIC shall also meet the flight review requirements specified in 14 CFR 61.56 in an 

aircraft in which the PIC is rated on their pilot certificate.

ii) The PIC shall be trained in the operation of the specific make and model of the sUAS 

being piloted and successfully completed all training required.

iii) The PIC shall have accumulated and logged, in a manner consistent with 14 CFR 

61.51 (b), a minimum of five hours as sUAS pilot operating the make and model of sUAS 

to be utilized for operations under the exemption. Three take-offs and three landings in 

the preceding 90 days must be accomplished to maintain currency.

iv) The PIC shall have accumulated and logged, in a manner consistent with 14 CFR 

61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft 

pilot and at least five hours logged as a sUAS pilot with a similar sUAS (multi rotor or 
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helicopter). Prior documented flight experience that was obtained in compliance with 

applicable regulations may satisfy this requirement.

v) Training, proficiency, and experience-building flights can also be conducted under this 

grant of exemption to accomplish the required flight cycles and flight time.

1. During training, proficiency and experience-building flights, all persons not 

essential for flight operations are considered non-participants, and the PIC must 

operate the sUAS with appropriate distance from non-participants in accordance 

with 14 CFR 91.119.

B. The sUAS Safety Observer (SO) shall meet all training requirements and be responsible 

for all of his/her duties as set forth by National UAS Solutions, LLC sUAS Operating 

Manual.

C. The PIC and SO will be designated before each flight.

D. The minimum crew for each flight operation will consist of the sUAS PIC and SO.

E. The PIC and the SO shall always be within visual line of sight (VLOS) of each other and 

in direct verbal communications at all times.

F. Safety Briefings shall be conducted before each day’s activities to include, but not limited 

to:

i) Designated roles of the PIC and SO.

ii) Risk Management and Mitigation.

sUAS Specifications and Design:

A. All sUAS flown under this exemption shall be less than 55 pounds including aircraft and 

payload. This exemption requests permission only with respect to the specific use of the 

DJI Phantom 2 Vision+ sUAS which weigh less than 10 pounds including payload.

B. The radio frequency spectrum used for operation and control of the sUAS shall comply

with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

C. Maximum speed shall be less than 50 knots.

D. The sUAS shall be equipped with Inertial Navigation Sensor (s) and Gyroscopes 

(IRS/IRU/Accelerometer/MEMS Gyroscopes).

E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source).
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F. The sUAS shall be equipped with a Global Positioning System (GPS) guidance system.

G. The sUAS shall be designed, should it lose communications or lose its GPS signal, to 

return to a pre-determined location within the Operations Area and land or be recovered 

in accordance with National UAS Solutions, LLC’s sUAS Operating Manual.

sUAS Maintenance

A. sUAS shall be maintained in accordance with the manufacturer’s recommendations and 

National UAS Solutions, LLC sUAS Operating Manual and Inspection Program.

B. National UAS Solutions, LLC will document and maintain a record of the sUAS 

maintenance, preventative maintenance, alterations, and status of replacement, overhaul 

component parts, and the total time in service of the sUAS. These records will be 

maintained at the principle base of operations for the life of the aircraft or as required by

Federal Aviation Regulations

.

C. National UAS Solutions, LLC shall comply with all manufacturer Safety/Service 

Bulletins or equivalent pertaining to the sUAS aircraft.

D. The PIC shall perform a preflight inspection of the sUAS, controller and ground station 

prior to each flight to ensure it is operational with no discrepancies. If the preflight 

inspection reveals discrepancies, repairs or maintenance shall be performed prior to 

flight. The sUAS will only be operated if all systems are operating per manufacture’s 

specifications and in a discrepancies free condition.

E. Maintenance or repairs that may affect the sUAS operation or flight characteristics shall 

undergo a functional test flight when required in accordance with manufacture’s 

recommendations and National UAS Solutions, LLC sUAS Operating Manual. This 

functional test flight shall be recorded in the sUAS’s records. If the functional test flight 

is completed successfully, the sUAS can return to service by the PIC.

F. National UAS Solutions, LLC shall follow the manufacturer’s sUAS maintenance, 

overhaul, replacement, inspection, and life limit requirements. When not provided by the 

manufacturer aircraft maintenance, component, overhaul, replacement, and inspection 

maintenance requirements shall be established and included in National UAS Solutions, 

LLC sUAS Operating Manual and Inspection Program.

G. All sUAS shall be identified by serial number, registered in accordance with 14 CFR Part 

47, and have identification (N-Number) markings in accordance with 14 CFR Part 45, 

Subpart C, except with respect to the size of the markings. Markings shall be as large as 

practical.
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Permissions and Permitting

A. All required permissions and permits shall be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement or other appropriate governmental 

agencies.

B. At least three days before a scheduled operational flight, National UAS Solutions, LLC 

shall submit a written plan of activities to the local flight standards district office (FSDO) 

with jurisdiction over the area of the proposed flight. The 3 day notification may be 

waived with the concurrence of the FSDO.

i) The plan of activities shall include at least the following:

1. Dates and times for all requested flights.

2. Name and phone number of National UAS Solutions, LLC sUAS Flight 

Operations.

3. Name, certificate and phone number of PIC responsible.

4. Make, model and N-Number of sUAS to be used

5. Statement from National UAS Solutions, LLC that it will be operating on 

approved privately owned and operated property; the list of those who gave 

permission shall be made available to the inspector upon request.

6. Description of flight activity, including maps or diagrams of any area over 

which flights will be conducted, the relationship of that area to any nearby city, 

town, etc., and the altitudes essential to accomplish the operation.

7. Signature of the exemption-holder or representative

C. Documents required under 14 CFR 91.9 and 91.203 shall be readily available to the PIC 

anytime the aircraft is in operation. These documents shall be made available to the 

Administrator or any law enforcement official upon request.

D. National UAS Solutions, LLC shall obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations under 

this grant of exemption.

E. National UAS Solutions, LLC shall also request a Notice to Airman (NOTAM) not 

more than 72 hours in advance, but not less than 48 hours prior to the operation.

F. National UAS Solutions, LLC shall obtain the consent of all persons involved in the 

operation and ensure that only consenting persons be allowed within 500 feet of the 

Operations Area.
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Operations

A. The sUAS shall not operate within 5 nautical miles of the geographic center of any 

airport as denoted on the current FAA published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. This letter of agreement 

with the airport management shall be made available to the Administrator upon request.

B. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel.

i) The sUAS shall only operate within a pre-defined Operations Area that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, poles, people, 

vehicles, sun angle, shadows, glare, reflective surfaces, clouds, smoke, and terrain among 

other potential hazards.

C. Flights shall be conducted during day visual meteorological conditions (VMC) only.

i) In addition, the sUAS shall not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when the visibility is less 3 statute miles from the PIC.

ii). SUAS operations shall not be conducted during night, as defined in 14 CFR 1.1.

iii) Flights shall not be conducted under special visual flight rules (SVFR).

D. Flights shall be operated at an altitude at or below 400 feet AGL, as indicated by the 

procedures specified in National UAS Solutions, LLC’s sUAS Operating Manual.

E. The PIC shall be prohibited from operating the sUAS from any moving device or vehicle.

F. The sUAS shall be operated within VLOS of the PIC.

i) The PIC shall maintain VLOS without the aid of telescopes, cameras or other devices.

ii) The PIC shall maintain VLOS with their own vision, which includes the use of 

eyeglasses or corrective lenses as specified on the PIC’s medical certificate.

G. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.
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H. National UAS Solutions, LLC will require the PIC and the SO to have successfully 

completed a qualifications process which will include ground and flight training, as 

outlined in the National UAS Solutions, LLC sUAS Operating Manual.

I. The PIC’s primary responsibility while in flight is the safe operation of the sUAS

.

J. The PIC and the SO may not switch roles during the flight.

SUAS Flight Time and Flight Durations

A. DJI Phantom 2 Vision + operations shall be completed within 25 minutes flight time or 

with 25% power remaining whichever occurs first.

B. If the flight time exceeds 25% of battery life an aural warning shall sound signifying that 

the aircraft must be landed immediately.

Regulations for Which Exemptions are Requested

14 CFR 21 – Requirements to Secure Airworthiness Certificates

A. Certificate exemptions should be given because size, weight, and operation areas of the 

sUAS meet the level of safety necessary for exemption under Section 333 of the Reform 

Act

.

B. The FAA has the authority to exempt aircraft from airworthiness certificate requirements 

under the Act (49 U.S.C. 44701 (f)) and Section 333 of the Reform Act.

C. This serves the public interest for all the reasons previously stated on pages 2 and 3 of 

this petition.

14 CFR 61.113 (a) and (b) – Private Pilot Privileges and Limitations; Pilot in Command

(a) Except as provided in paragraphs (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.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if:

1. The flight is only incidental to that business or employment; and 

2. The aircraft does not carry passengers or property for compensation or hire.

A. Due to the fact that there are no standards for private or commercial sUAS operations, 

National UAS Solutions, LLC requests to utilize at least Private Pilots with a current third 

class medical in support of its own operations.
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B. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along 

with the ability to physically manipulate the controls of the sUAS are the critical aspects of 

the requested operation. National UAS Solutions, LLC feels this can be accomplished by a 

Private Pilot that has specific training on the sUAS aircraft and operates in accordance with 

the National UAS Solutions, LLC sUAS Operating Manual, Federal Aviation Regulations, 

local, state and federal laws and regulations.

C. The risks associated with the operation of a sUAS are so diminished from the level of risk 

associated with commercial aviation operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a Private Pilot as the PIC exceeds the 

present level of safety achieved by 14 CFR 61.113 (a) and (b).

D. The FAA has the authority to waive pilot requirements for commercial operations under 

49 USC 44701 (f).

E. Equivalent or better safety levels will be achieved as there will be no human beings on 

board the sUAS aircraft.

F. This serves the public interest and contributes to the greater good for all the reasons 

previously stated on pages 2 and 3 of this petition.

14 CFR 91.103 Preflight Actions

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 

forecasts, 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 following 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 civil 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 wind 

and temperature.

A. National UAS Solutions, LLC respectfully requests exemption from this regulation as it 

does not apply to its area of operation in the fact that the sUAS utilized will never be 
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operated on an IFR flight plan or closer than 5 miles from the geographical center of an 

airport.

B. Equivalent levels of safety will be met through preparation and compliance according to 

National UAS Solutions, LLC sUAS Operating Manual, including but not limited to 

weather reports, forecasts, wind speed and direction, temperature, battery requirements and 

battery charge levels, cycles remaining on the battery and any other information deemed 

relevant to aircraft performance and safety shall be considered.

C. The PIC shall perform a prefight inspection in accordance with the manufacturer’s 

recommendations and the National UAS Solutions, LLC sUAS Operating Manual of the 

aircraft, controller, ground station and associated equipment prior to each flight to ensure it is 

free of all discrepancies.

D. Granting this exemption from this particular FAR will serve the public interest and 

greater good for all the reasons previously stated on pages 2 and 3 of this petition.

14 CFR 91.119 – Minimum Safe Altitudes: General

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 1000 feet above the highest obstacle 

within a horizontal radius of 2000 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 may not be 

operated closer than 500 feet to any person, vessel, vehicle or structure.

A. National UAS Solutions, LLC respectfully requests exemption from this FAR as the 

sUAS that will be used in day to day operations will never be flown over 400 feet in altitude 

so this FAR cannot apply.

B. National UAS Solutions, LLC shall obtain the consent of all persons involved in the 

operation and ensure that only consenting persons be allowed within 150 feet of the 

Operations Area. Foldable signs with the words “Caution! Unmanned Aerial Vehicle in 

Operation! Stay back 150 feet!” will be placed at the perimeter of the Operations Area to 

warn people of an ongoing operation. See Exemption 11138 already granted to Mr. Douglass 

Trudeau of Tierra Antigua Real Estate.

C. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established for 
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each flight. These areas will be free of unnecessary hazards or risks and non-participating 

personnel.

D. Given the size, weight, construction material, speed and operation of the sUAS, National 

UAS Solutions, LLC believes that an equivalent or higher level of safety, as mandated by 14 

CFR 91.119, will be achieved.

E. Granting exemption from this FAR will be in the public interest for all of the reasons 

previously stated on pages 2 and 3 of this petition.

14 CFR 91.121 Altimeter Settings

(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 an 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.

A. National UAS Solutions, LLC’s sUAS will not have a barometric altimeter, however, 

the use of triangulation with a minimum of 6 satellites in use by its onboard GPS will be able 

to give accurate Height Above Ground Level.(HAGL) measurements.

B. National UAS Solutions, LLC believes that an equivalent level of safety can be 

achieved by the operator as the sUAS uses HAGL from its initialization/takeoff point.

C. National UAS Solutions, LLC believes granting an exemption from this FAR is in the 

public interest and serves the greater good for all the reasons previously stated on pages 2 

and 3 of this petition.

14 CFR 91.151 (a) (1) – Fuel Requirements for Flight in VFR Conditions.

(a) 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.

A. The FAA has previously issued exemptions for fuel requirements in VFR conditions for 

sUAS aircraft. See exemptions 2689F, 5745, 10673, 10808 and 11138.

B. National UAS Solutions, LLC believes an equivalent or higher level of safety can be 

obtained by terminating the flight prior to the following:
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Aircraft Battery (Fuel) Requirements

DJI Phantom 2 Vision+ -- 25 minutes or 25% of battery life, whichever occurs first. This 

will allow for 6.2 minutes reserve.

1. The DJI Phantom 2 Vision + sUAS has a second level of safety that is achieved 

through the use of an aircraft battery monitoring system. The aircraft system will alert 

the operator of low battery voltage and initiate a return to its take off location before 

battery capacity is depleted.

2. National UAS Solutions, LLC will not operate sUAS at night in accordance with 14 

CFR 1.1.

3. An equivalent level of safety will be achieved because these sUAS are limited in size, 

scope of operations, and shall only fly above approved privately owned and operated 

property at or below 400 feet HAGL, and does not bear the same risks associated with 

large manned aircraft and therefore should be exempt from this section’s requirements.

C. An exemption granted from the provisions of this FAR serves the public interest and the 

common good for all the reasons previously stated on pages 2 and 3 of this petition.

14 CFR 91.405 (a) – Maintenance Required.

Each owner or operator of an aircraft-

(a) 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 this chapter.

A. This section and Part 43 apply only to aircraft with an airworthiness certificate, therefore 

these sections will not apply.

B. In the absence of regulatory provisions dealing with sUAS operation for maintenance 

required, National UAS Solutions, LLC will establish the sUAS Operating Manual, 

Inspection Program and Manufacturers Maintenance Recommendations for maintenance 

required.

1. Maintenance will be accomplished by National UAS Solutions, LLC in accordance 

with manufacturer’s recommendations and National UAS Solutions, LLC’s sUAS 

Operating Manual and Inspection Program.

2. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished by trained personnel or factory authorized maintenance facilities.

3. Functional test flights will be performed by the PIC when required. The sUAS shall 

only be returned to service when this functional test flight is successfully completed. If a 
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mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area. An appropriate log entry shall be made in the sUAS’s Aircraft Flight Log that the 

aircraft has successfully completed a functional test flight and is authorized for return to 

service.

4. The National UAS Solutions, LLC sUAS Operating Manual details how to enter in 

the maintenance log scheduled and unscheduled maintenance or functional test flights 

that are performed.

5. National UAS Solutions, LLC shall only operate its sUAS with all systems 

functioning per manufactures specification in a discrepancy free condition.

6. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

C. National UAS Solutions, LLC and the Aircraft Manufacturer (DJI) are the most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition. These 

maintenance procedures allow for an equivalent level of safety to be achieved due to the 

limited size of the aircraft, the scope and area of operations.

D. The granting of this exemption from this FAR serves the public interest and contributes 

to the common good for all the reasons previously stated on page 2 and 3 of this petition.

14 CFR 91.409 (a) (1) and (2) – Inspections

(a) 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—

(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) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any

inspection required by this paragraph unless it is performed by a person authorized to 

perform annual inspections and is entered as an “annual” inspection in the required 

maintenance records.

A. This section and Part 43 apply only to aircraft with an airworthiness certificate therefore 

these sections will not apply.

B. In the absence of regulatory provisions dealing with sUAS inspections, National UAS 

Solutions, LLC has developed requirements to address this topic. Instructions found in the 

aUAS Operating Manual, Inspection Program and the Manufactures User Guide will be used 

in lieu of non-existent(as of the date of this petition) Federal Aviation Administration 

regulatory guidelines.
16

1. Maintenance will be accomplished by National UAS Solutions, LLC pursuant to the 

manufacturer’s recommendations and National UAS Solutions, LLC’s sUAS Operating 

Manual and Inspection Program.

2. Maintenance, preventive maintenance, rebuilding and alteration will be successfully 

accomplished by trained personnel or factory authorized dealers.

3. The National UAS Solutions LLC sUAS Operating Manual details how to enter into 

the maintenance log all inspections that are performed.

4. A functional test flight will be performed by the PIC when required after inspections. 

The sUAS shall be returned to service when the flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the Operations 

Area. An appropriate log entry shall be entered in the Aircraft Flight Log that the 

functional flight test was completed and the aircraft returned to service.

5. National UAS Solutions, LLC shall only operate its sUAS with all systems 

functioning per manufacturer’s specifications in a discrepancy free condition.

6. These records will be maintained at the principle base of operation for the life of the 

aircraft or as required by the Federal Aviation Regulations.

C. National UAS Solutions, LLC and the Aircraft Manufacturer (DJI) are the most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition. These 

maintenance inspections allow for an equivalent level of safety to be achieved due to the 

aircraft’s limited size, scope and area of operations.

D. The granting of this exemption for this FAR is in the public interest and serves the greater 

good for all the reasons previously stated on page 2 and 3 of this petition.

14 CFR 91.417 (a) and (b) – Maintenance Records

(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 

section:

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, 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 of the work performed; and
17

(iii) The signature and certificate number of the person approving the aircraft for 

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 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 compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involve 

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 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 sold.

(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.

A. This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply.

B. In the absence of regulatory provisions dealing with sUAS maintenance records, 

National UAS Solutions, LLC has developed requirements to address this topic. 
18

Instructions found in the aUAS Operating Manual, Inspection Program and the Manufactures 

User Guide will be used in lieu of non-existent(as of the date of this petition) Federal 

Aviation Administration regulatory guidelines.

1. Maintenance will be accomplished by National UAS Solutions, LLC pursuant to the 

manufacturer’s recommendations and National UAS Solutions, LLC’s sUAS Operating 

Manual.

2. Maintenance, preventive maintenance, rebuilding and alteration maintenance record 

keeping will be performed by trained personnel and entered in the respective aircraft 

maintenance log at the completion of each event. The National UAS Solutions, LLC 

sUAS Operating Manual details how entries are to be made in the aircraft maintenance 

log for scheduled and unscheduled maintenance of functional test flights that are 

performed.

3. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations.

C. National UAS Solutions, LLC and the Aircraft Manufacturer (DJI) are the most familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition. These 

maintenance records allow for an equivalent level of safety to be achieved due to the limited 

size, scope and area of operations.

D. The granting of this exemption for this FAR is in the public interest and serves the greater 

good for all the reasons previously stated on page 2 and 3 of this petition.