1

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 Si r 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 Sy stems ( s UAS ) equipped to conduct commercial training of sUAS pilots in the vital interest of safety and videograph y and photograph y of real estate propert y for the purpose of constructing virtual tours, hereb y petitions to be exempt from current Federal Aviation Administration ( FAA ) regulations that affect mann ed 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 b y the FAA as requ ired by Section 333. The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS may operate safel y in the national airspace s ys tem (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 ty

pes 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 securit y. 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 fl yi ng corporate aircraft for over fort y ye ars. He holds a FAA issued Airline T ransport Pilot’s license along with a Certified Flight Instructor Airplane, Multi

- engine L and 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 o f this exemption request will provide immediate benefit to both the aircraft pilot training industry

and real estate industry

by authorizing highl y controlled sUAS operations within Class G airspace, at or below 400 feet above ground level (AGL), in visual line of sight2

( V LOS) 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 stud ent pilot startups in recent ye ars, **National UAS Solutions, LLC**  believes this is one way the public could benefit b y 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 verticall y 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 securit y. In the following pages **National UAS Solutions, LLC**  will address all areas of concern to include the exceptions requested and equivalent levels of safet y. 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 **Natio nal UAS Solutions, LLC**  To follow this exemption letter and/or upon request:

 **National UAS Solutions, LLC** Operati ng Manual  **National UAS Solutions, LLC** Aircraft Inspection Program  **National UAS Solutions, LLC** Training S yl labus  **National UAS Solutions, LLC** Civi l COA  Aircraft Manufacturer’s User’s Guides3



## Professional sUAS Flight Training Serves the Public Interest
1. sUAS integration into the NAS without proper flight training is inherentl y 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 with in 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 videograph y for geographical awareness and for real estate marketing ha s 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 videograph y is cost prohibitive. 2. Only large companies or high

- end realtors or luxury homeowners can afford to absorb the expense of manned aircraft videograph y . 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 cata strophic 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 b y a small battery

. 4. **National UAS Solutions, LLC** will eli minate the above problems b y 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

.

.4



## 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 fl yi ng a seaplane for an oil company along the Louisiana Gulf C oast. He started fl yi ng 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

- AI M, a Mechanical Engineer and three Real Estate consultants. The pil ots have more than 50 ye ars of aviation management experience. 3. **National UAS Solutions, LLC** has extensive knowledge and experience in Commercial Aviation, Flight In struction and RC model aircraft. 

## NATIONAL UAS SOLUTIONS, LLC Experience As professional pi lots, **National UAS Solutions, LLC** understands and agrees with the FAA that safet y is paramount and will **ALWAYS** hold **SAFETY** ahead of any commercial endeavor. 1. Individuals within **National UAS Solutions, LLC** have onl y operated sUAS as hobbyists. To date, **National UAS Solutions, LLC** members have not engaged in an y 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 Aircr aft Inspection Program and Training S yl labus that it shall follow, should this exemption be approved. 

## NATIONAL UAS SOLUTIONS, LLC sUAS Descri **p tion**  **National UAS Solutions, LLC** intends to use and operate DJ I Phantom 2 Vision+ sUAS multirotor aircraft for the purpose of sUAS Flight Training and aerial real estate videograph y and photograph y. 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 w arnings. 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 Includ ed):**  1242g; 43.8 ounces; 2.7 pounds5

**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 D escent 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 s afe operations conducted with conventional aircraft. 

## This exemption Request is for Use of sUAS subject to **Extensive Operation al 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 (PI C) shall possess at a minimum a private pilot license and current third

- class medical certificate. i) The PI C 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 PI C 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 PI C shall have accumulated and lo gg ed, 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 . T hree take

- offs and three landings in the preceding 90 day s must be accomplished to maintain currency

. iv) Th e PI C 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 or6

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 acc omplish 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 dis tance from non

- participants in accordance with 14 CFR 91.119. B. The sUAS Safet y Observer (SO) shall meet all training requirements and be responsible for all of hi s /her duties as set forth b y **National UAS Solutions, LLC** sUAS Operating Manual. C. The PI C and SO will be designated before each flight

. D. The minimum crew for each flight operation will consist of the sUAS PI C and SO. E. The PI C and the SO shall alway s 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 PI C 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 DJIPhantom 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 shal l be equipped with Inertial Navigation Sensor (s) and Gy roscopes (IRS/IRU/Accelerometer/MEMS Gy roscopes). E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source).7

F. The sUAS shall be equipped with a Global Positioning Sy stem (GPS) guidance sy stem. 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 require d by Federal Aviation Regulations

. C. **National UAS Solutions, LLC** shall comply with all manufacturer Safet y/ Service Bulletins or equivalent pertaining to the sUAS aircraft. D. The PI C 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 s ys tems are operating per m anufacture’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 an d **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 successfull y, the sUAS can return to service b y the PIC. F. **National UAS Solutions, LLC** sha ll 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 e stablished 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.8



## 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 writt en 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 b e operating on approved privatel y 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 an y area over which flights wil l be conducted , the relationship of that area to an y nearb y 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 readil y available to the PI C any time the aircraft is in operation. These documents shall be made available to the Administrator or an y law enforcement official upon request. D. **National UAS Solutions, LLC** shall obtain an Air Traffic Organization (ATO) issue d Certificate of Waiver or Authorization (COA) prior to conducting an y 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.9



## Operations A. The sUAS shall not operate within 5 nautical miles of the geographic center of an y 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 require d 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 non

participating personnel

. i) The sUAS shall only

operate within a pre

- defined Operations Area that shall be thoroughl y inspected b y the PI C 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 meteorologic al 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 PI C. ii). SUAS operations shall not be conducted d uring 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, LL C**  ’s sUAS Operating Manual. E. The PI C shall be prohibited from operating the sUAS from any moving device or vehicle. F. The sUAS shall be operated within VL OS of the PI C. i) The PI C shall maintain VLOS without the aid of telescopes, cameras or other devices. ii) The PI C shall maintain VLOS with their own vision, which includes the use of eyeglasses or corrective lenses as specified on the PI C’s medical certificate. G. The sUAS shall remain clear and yi eld 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.10

H. **National UAS Solutions, LLC** will require the PIC and the SO to have successfully completed a qualifications process which will i nclude ground and flight training, as outlined in the **National UAS Solutions, LLC** sUAS Operating Manual. I. The PI C’s primary

responsibility

while in flight is the safe operation of the sUAS

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

## SUAS **Flight Time and Flight Durations**
A. DJIPhantom 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 are a s of the sUAS meet the level of safet y 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 propert y 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 an y business or emplo ym ent if: 1. The flight is onl y 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.11

B. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along with the ability

to phy sically

manipulate the controls of the sUAS are the critical aspects of the requested operation. **National UAS Solutions, LLC** fee ls 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 regulation s. 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 a s the PIC exceeds the present level of safet y achieved b y 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 safet y levels will be achieved as th ere 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 comman d 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 require ments, alternatives available if the planned flight cannot be completed, and an y known traffic delay s of which the pilot in command has been advised by ATC; (b) For an y flight, runway lengths at airports of intended use, and the following takeoff and land ing 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 aircra ft 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 be12

operated on an IFR flight plan or closer than 5 miles from the geographical center of an airport. B. Equivalent levels of safet y 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 an y other information deemed relevant to aircraft per formance and safet y shall be considered. C. The PI C 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 associ ated 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 an y 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 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 may not be operated closer than 500 feet to an y 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 appl y. 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 o f approved privately owned and operated property . An Operations Area within those boundaries will be established for13

each flight. These area s 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 b y 14 CFR 91.119, will be achieved. E. Granting exemption from this FAR will be in the public interest for a ll 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 nautica l miles of the aircraft; (ii) If there is no station within the area prescribed in p aragraph (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 b y the operator as the sUAS uses HAGL from its initialization/takeoff poi nt. 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 previousl y 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:14

**Aircraft Battery (Fuel) Requirements** DJIPhantom 2 Vision+

-- 25 minutes or 25% of battery life, whichever occurs first. This will allow for 6.2 minutes reserve. 1. The DJ I Phantom 2 Vision + sUAS has a second level of safety that is achieved through the use of an aircraft battery monitoring sy stem. The aircraft s ys tem will alert the operator of low battery voltage and initiate a return to its take off location before battery capacit y 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 fl y above approved privatel y owned and operated propert y 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 onl y to aircraft with an airworthiness certificate, therefore thes e 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 Recommendat ions 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, preve ntive maintenance, rebuilding and alteration will be successfull y accomplished b y trained personnel or factory authorized maintenance facilities. 3. Functional test flights will be performed b y the PI C when required. The sUAS shall only be returned to service when this functional test flight is successfull y completed. If a15

mechanical issue arises the sUAS can land safel y or be recovered within the Operations Area. An appropriate log entry shall be made in the sUAS’s Aircraft Flight L og that the aircraft has successfull y 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 functio nal test flights that are performed. 5. **National UAS Solutions, LLC** shall only operate its sUAS with all sy stems functioning per manufactures specification in a discrepancy free condition. 6. These records will be maintained at the principle base f or operation for the life of the aircraft or as required b y Federal Aviation Regulations. C. **National UAS Solutions, LLC** and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. These maintenance procedures allow for an equivalent level of safet y 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 b y a person authorized by 43.7 of this chapter, or (2) An inspection for the issuance of an air worthiness 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 b y this paragraph unless it is performed b y 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 onl y to aircraft with an airworthiness certificate therefore these sections will not apply

. B. In the absence of regulatory pro visions 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 successfull y accomplished b y trained personnel or factory authorized dealers. 3. The **National UAS Solutions LLC** sUAS Operating Manual details ho w to enter into the maintenance log all inspections that are performed. 4. A functional test flight will be performed b y the PI C 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 safel y 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. **N ational UAS Solutions, LLC**  shall only operate its sUAS with all sy stems 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 b y the Federal Aviation Regulations. C. **National UAS Solutions, LLC** and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. These maintenance inspecti ons 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 previousl y 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 airfr ame) and each engine, propeller , rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrato r) of the work performed; and (ii) The date of completion of the work performed; and17 (iii) The signature and certificate numb er 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 wh ich are required to be overhauled on a specified time b asis. (iv) The current inspection status of the aircraft, including the time since the last inspection required b y the inspection program under wh ich the aircraft and its appliances are maintained. (v) The current status of applicable airworthi ness 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 req uired. (vi) Copies of the forms prescribed b y 43.9 (d) of this c h apter 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 b y other work or for 1 ye ar 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 onl y to aircraft with an airworthiness certificate; therefore these sections will not apply

. B. In the absence of regulatory provisions dealing with sUAS m aintenance 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 thi s 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 fo r the life of the aircraft or as required b y Federal Aviation Regulations. C. **National UAS Solutions, LLC** and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. Th ese 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.