Aerial Logistics NW LLC

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1

12 February 2016

Docket Operations 

M-30, U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE. Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001

Aerial Logistics NW LLC. 

DBA Vortex Aerial Imaging

4018 157th ST NW

Gig Harbor, WA 98332

Attn: Chad Costa

Subject: Request for Exemption Under FAA Modernization and Reform Act of 2012, 

Section 333, “Special Rules for Certain Unmanned Aircraft Systems.”

To whom it may concern:

Aerial Logistics NW LLC. DBA Vortex Aerial Imaging proposes to operate Unmanned 

Aircraft Systems (UAS) safely and routinely within the United States National Airspace 

System (NAS) in the normal conduct of its business. Because of the nature of our 

aircraft and the conduct of our business, the company requests an exemption for its 

business operations under FAA Modernization and Reform Act of 2012, Section 333, 

Special Rules for Certain Unmanned Aircraft Systems.

Aerial Logistics NW is a LLC focused on providing aviation related services. The 

company headquarters is 4018 157th St NW Gig Harbor, WA. 98332. All contact and 

correspondence regarding this application should be sent to the attention of Chad Costa

at the above address, by telephone at (808) 651-6909 or by email at

kauaichoppers@yahoo.com

Sincerely,

Chad Costa

Owner
Aerial Logistics NW LLC

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Aerial Logistics NW LLC.
Aerial Logistics NW LLC

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Request for Exemption under FAA Modernization and Reform Act of 2012, 

Section 333, “Special Rules for Certain Unmanned Aircraft Systems.”

Aerial Logistics NW LLC. DBA Vortex Aerial Imaging intends to safely conduct business 

with Small Unmanned Aircraft (sUA) –Unmanned Aircraft Systems weighing less than 

55 pounds. The company seeks the exemption because some of the rules applicable to 

manned aircraft and even larger UAS cannot be practically applied in our case. Per 

guidance provided in 14 CFR § 81 the company requests relief by exemption from the 

requirements of the following regulations:

 PART 21 – “Certification and airworthiness requirements for aircraft and parts,” 

Subpart 21.H – “Certificates of airworthiness (except provisional certificates of 

airworthiness) and special flight permits”

 Part 61 Certification: Pilots, Flight Instructors, and Ground Instructors 

 Part 91 General Operating and Flight Rules

o 91.103(b)(2) Preflight action

o 91.105 Flight crewmembers at stations

o 91.109 Flight instruction

o 91.119 Minimum safe altitudes

o 91.121 Altimeter settings

o 91.151 Fuel requirements for flights in VFR conditions

o 91.405 Maintenance required

o 91.407 Operation after maintenance

o 91.409 Inspections 

o 91.417 Maintenance records

Summary for the Federal Register (if posting is required)

Aerial Logistics NW LLC. proposes to operate Unmanned Aircraft Systems (UAS) safely 

and routinely within the United States National Airspace System (NAS) in the normal 

conduct of its business. Because of the nature of our aircraft and the conduct of our 

business, the company requests an exemption for its business operations from certain 

rules contained in 14 CFR, Federal Aviation Regulations under Section 333 of Public 

Law 112-95, “Special Rules for Certain Unmanned Aircraft Systems.”

PART 21 – “Certification and airworthiness requirements for aircraft and parts,” 

Subpart 21.H – “Certificates of airworthiness (except provisional certificates of 

airworthiness) and special flight permits.”
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Reason for the request - All the regulations under Part 21, Subpart H deal with 

airworthiness certificates for aircraft other than Small Unmanned Aircraft (sUA). Currently sUA are 

not manufactured like manned aircraft under 14 CFR regulations. Consequently our sUA do not 

utilize FAA airworthiness standards or FAA Airworthiness Certificates.

Extent of relief – Aerial Logistics NW LLC requests relief from the rules of Subpart H

because they are not applicable to Small Unmanned Aircraft (sUA). There are currently no FAA 

standards of airworthiness for sUA. Specifically, §21.175 taken from Part H entitled “Certificates of 

airworthiness: classification,” summarizes our request for relief from this part (Part 21, Subpart H). 

The regulation lists aircraft eligible for special and standard certificates of airworthiness. These are:

primary, intermediate or restricted categories, limited category, and amateur-built, light sport, 

experimental and standard categories of aircraft. The standard certificate of airworthiness is issued 

for normal, utility, aerobatic, commuter or transport category, manned free balloon or a special class 

of aircraft. sUA are not included in any of these airworthiness categories listed in Part 21, Subpart H.

Equal level of safety – An airworthiness certificate is an administrative requirement for 

manned aircraft constructed under the regulations of 14 CFR. Although it is required to be aboard a 

manned aircraft it does not necessarily prove an aircraft is both safe and airworthy. Rather, proper 

maintenance, safe and careful operation as well as documentation that the FAA can track to check 

the aircraft and its operation is required for an aircraft to assure airworthiness with sUA. 

Aerial Logistics NW LLC intends to properly maintain their sUA within manufacturer’s 

standards of maintenance and operational safety. Likewise the company will carefully operate its 

aircraft within FAA standards in order to insure the safety of people and property we overfly. 

Operating safely will also help us preserve the company’s assets. In lieu of an airworthiness 

certificate the FAA already provides a means to sufficiently monitor sUA in general, and our sUA in 

particular. The existing FAA requirement to register “Unmanned Aircraft (UA) operated for nonhobby or non-recreational purposes” allows the FAA to track and monitor sUA operations. 

Aerial Logistics NW will work in concert with the FAA Aircraft Registration Branch and the

local FAA Flight Standards District Office (FSDO) in order to register our aircraft. In lieu of complying 

with the rules of Part 21, subpart H, registration of our aircraft should provide the FAA a means to 

monitor and ensure that our sUA operations are safe and legal. 

Public benefit – Thousands of sUA without airworthiness certificates are presently operating safely 

within the National Airspace System (NAS). Increasing numbers of sUA in increasing numbers of 

makes and models are being manufactured and sold each year. Issuing airworthiness certificates to 

the existing fleet alone would burden the public with the need to fund the manpower and resources 

for doing so with no effect on the current levels of safety with which they currently operate in the 

NAS. 

Summary: Aerial Logistics NW LLC seeks relief from the rules associated with Part 21, Subpart H 

requiring airworthiness certificates for its Small Unmanned Aircraft (sUA). No regulation (including 

Part 21) currently exists which requires sUA to possess an airworthiness certificate. A requirement to 

issue airworthiness certificates for sUA would unduly burden the FAA with its implementation and 
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general public with the costs of manpower and resources to issue a certificate for every sUA in 

commercial operation in the National Airspace System (NAS). The company maintains that the 

FAA’s requirement to register sUA operated for non-hobby or non-recreational purposes already 

allows the FAA to monitor their safe use and proper maintenance as effectively as issuing an 

airworthiness certificate.

Part 61 Certification: Pilots, Flight Instructors, and Ground Instructors 

Reason for the request – The rules of 14 CFR Part 61 are not applicable to Small Unmanned 

Aircraft (sUA) because there is no cockpit and consequently no pilot in sUA. Neither is there a need 

for pilots, flight instructors or ground instructors in the sUA community to comply with the 

requirements of manned aircraft under 14 CFR Part 61.

Extent of relief – Aerial Logistics NW LLC requests relief from the rules of Part 61 as they apply to 

pilots, instructors and ground instructors since they apply to manned aircraft. 

Equal level of safety – Although pilots and instructors as described in Part 61 are not necessary in 

sUA, our company pilots, instructors and their training will parallel applicable parts of Part 61. Pilot 

training, instructor requirements and training syllabi are addressed later in this document. But 

company instructors and pilots will be trained on sUA to the same level of competency and focus on 

safe operations required of Part 61 pilots and instructors. Consequently, the level of safety in sUA 

operation will mirror that already provided for through traditional Part 61 flight training. Our pilots and 

instructors will use the same methodology and much of the same training material used at flight 

schools for manned aircraft. Company training syllabi, training facilities, training aids, check flights 

and testing will also mirror Part 61 manned aircraft training requirements. 

Public benefit – The United States NAS is the safest in the world in part because of the standards 

set in training its pilots and instructors. The company intends to model the training of its instructors 

and pilots by using the same system that trains safe pilots in the US manned aircraft industry. Doing 

this will provide the general public with the benefit of the same level of safety in our sUA operation 

that the FAA currently maintains in manned aircraft operations. No further burden will fall on the FAA 

to require and monitor training that differs substantially with existing Part 61 training the agency 

currently monitors.

Summary: Aerial Logistics NW LLC, which operates Small Unmanned Aircraft (sUA) seeks relief 

from the rules of 14 CFR Part 61 entitled “Certification: Pilots, flight instructors, and ground 

instructors.” Aerial Logistics NW LLC maintains that because sUA are unmanned the rules of Part 61 

do not apply to the company. Still, as applicable to sUA, the company intends to use the same 

standards and methodologies for its pilots and instructors as currently used to train manned aircraft 

pilots and instructors under Part 61. Since the training for the company pilots and instructors will 

mirror manned aircraft training where applicable, the same level of safety and public good will be 

derived from its operation as is currently enjoyed within the United States National Airspace System 

(NAS). 
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Part 91 General Operating and Flight Rules

91.103 Preflight action, (b)(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.”

Reason for the request – The information required to comply with the rule is not available for sUA 

in general, and the sUA the company will operate specifically. The manufacturers of sUA are not 

required to meet the airworthiness standards specified in 14 CFR. Consequently, their performance 

is not tested or derived by 14 CFR standards nor mapped on charts or placards common to manned 

aircraft used in the US NAS. 

Extent of relief - Aerial Logistics NW LLC requests relief from the rules of Part 91.103(b)(2) relating 

to aircraft performance planning for their operation of sUA. 

Equal level of safety – Operating procedures of the company include the same requirement as this 

rule e.g., for the pilot to insure the aircraft can be operated safely within the manufacturer’s operating 

restrictions and recommendations as well as all applicable Federal Aviation Regulations. Further, 

company operating procedures require that the pilot conduct performance checks (such as hover in 

and out of ground effect checks), careful flight planning and a detailed safety survey prior to 

conducting any flight. 

Public benefit – Relieving the company of complying with rules not applicable to them allows the 

FAA to spend their assets and efforts ensuring that sUA operations use operating procedures and 

safety standards applicable to sUA. The public benefits by being able to utilize drones while still 

having the FAA oversight of their safe operation.

Summary: Aerial Logistics NW LLC seeks relief from the rules of Part 91.103(b)(2) relating to 

aircraft performance planning. The company notes that Small Unmanned Aircraft (sUA) are not 

manufactured under 14 CFR airworthiness standards. Consequently, performance charts and 

graphs typically used in manned aircraft are not available to plan a flight according to the guidance 

of the subject regulation. Company operating procedures require the pilots’ compliance with 

manufacturers’ restrictions, careful flight planning and that they conduct performance checks prior to 

conducting any flight. 

91.105 Flight crewmembers at stations-

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in connection 

with the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. 
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(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, 

keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does 

not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness 

fastened.

Reason for the request – This regulation is only pertinent to manned aircraft as sUA have neither 

onboard crew members, nor seats and seatbelts.

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated with 

crewmembers at their flight stations.

Equal level of safety – The safety concerns addressed by this regulation are only applicable to 

manned aircraft, not sUA. The level of safety assured by this regulation is unaffected by the 

company’s relief from its rules.

Public benefit – Without relief from this regulation the company and the public in general will not be 

able to use UAS operated for non-hobby or non-recreational purposes” Otherwise there is no benefit 

or loss to the public by relieving the company of compliance with the rules of this regulation. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.105: “Flight 

crewmembers at stations” as Small Unmanned Aircraft operated by the company do not have 

crewmembers onboard, seats or seatbelts. 

91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(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 equipped with a single, functioning throw-over 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 has at least a private pilot certificate with appropriate 

category and class ratings. 

(b) An airplane equipped with a single, functioning throw-over 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;
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(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 logged 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 each 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, simulated 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.

Reason for the request – This regulation is only pertinent for manned aircraft with standard flight 

controls operating with a pilot and a flight instructor, flying in either visual or instrument conditions. 

Extent of relief – Because our sUA do not carry pilots or fly in instrument conditions, the company 

requests relief from the rules associated with dual pilot, in-cockpit flight instruction where flight 

controls are available to both pilots. The rules of this part are also not pertinent regarding instrument 

flight as our sUA are not instrument flight capable and will only fly in Visual Meteorological 

Conditions (VMC).

Equal level of safety – Relief from the rules associated with 14 CFR, part 91.109 will have no 

bearing on the company’s safe operations because the rules are not applicable to our sUA. 

Public benefit – There is no benefit or loss to the public by relieving the company of compliance 

with the rules of this regulation. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.109: “Flight 

instruction; Simulated instrument flight and certain flight tests.” The rules of this part do not apply to 

Small Unmanned Aircraft (sUA) because the aircraft has no cockpit and cannot fly in instrument 

meteorological conditions.

91.119 Minimum safe altitudes
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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 1,000 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 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 helicopter 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 parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

Reason for the request – 14 CFR, 91.119, “Minimum Safe Altitudes” as written is only pertinent to

manned aircraft which with the exception of helicopters, powered parachutes, and weight-shiftcontrol aircraft must operate above 500 feet above the surface. Relief from the rules as published 

will allow the company to prepare a plan for operating our sUA in the safest manner in order to 

mitigate risk to other aircraft, persons and property within the NAS or on the ground. 

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated with this part

and requests permission to modify operations to comply with the guidance offered in Advisory 

Circular 91-57A, “Model Aircraft Operating Standards,” dated September 2, 2015. 

Equal level of safety – Aerial Logistics NW LLC intends to comply with the guidance of AC 91-57A, 

“Model Aircraft Operating Standards” which limits Unmanned Aircraft (UA) to 400 feet above the 

surface. This altitude lies below the minimum altitudes delineated by Sec. 91.119 for all but 

helicopters, powered parachutes, and weight-shift-control aircraft. Per AC 91-57A, company pilots 

will give way to manned aircraft and check NOTAMs to avoid operations where our sUA might cause 

a hazard to them. 

Public benefit – The benefit to relieving the company of the rules as published and establishment of 

the company’s plan to operate their sUA will result in safer operations of our sUA above and around 

the public. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, 91.119, “Minimum Safe 

Altitudes.” The rules of this part apply to manned aircraft, not Small Unmanned Aircraft (sUA). The 

company plans to comply instead with the guidance other rule as it related to low level flight and with 

Advisory Circular 91-57A dated September 2, 2015. This AC limits maximum altitude of sUA to 400 
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feet above the surface and suggests ways to avoid operations near people, property, noise hazard 

areas and airports and otherwise operate sUA more safely. 

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; or 

(2) At or above 18,000 feet MSL, to 29.92ʺ 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 
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28.41 through 27.92 2,000 

27.91 through 27.42 2,500 

27.41 through 26.92 3,000

Reason for the request – This regulation is not pertinent to our sUA as there is no altimeter 

onboard. 

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated with 91.121 

“Altimeter settings.”

Equal level of safety – There is no requirement for sUA pilots to have an altimeter onboard or to 

have an altitude function in its operation. But there is a statutory requirement for the sUA pilot to 

remain below 400 feet above the ground and to post a NOTAM before a flight. Absence of an 

altimeter on our sUA will have no negative bearing on safe and legal flight operations or to remain 

below the maximum altitude of 400 feet above the surface. Most company operations are expected 

to take place at altitudes below 200 feet. Since the pilots of our sUA are FAA certificated pilots,

operating at that low altitude an experienced pilot should be able to keep the sUA well below its 

maximum altitude.

Operations above 200 feet above the surface will most likely be associated with work around tall 

towers. In the event of work near tall towers, reference to aeronautical charts will allow the pilot to 

note the height of the towers in comparison to the altitude of the sUA in order to maintain altitude 

below 400 feet. 

Public benefit – There is no benefit or loss to the public by relieving the company of compliance 

with the rules of this regulation. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.121: “Altimeter 

settings.” The sUA operated by the company do not possess altimeters. Since they will not operate 

in the NAS above 400 feet, except by NOTAMs posted by the company before a flight there is no 

need to report their altitude to other aircraft. Altitude of the sUA will be determined by its pilot who is 

also an FAA certificated pilot. Since most company operations will take place within 200 feet of the 

surface their experience should allow them to keep the sUA well below 400 feet. Work at altitudes 

above 200 feet will most likely be associated with tall towers. Reference to aeronautical charts will 

allow the pilot to estimate altitude of the sUA in relation to tower height. 

91.151 Fuel requirements for flights 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; or 
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(2) At night, to fly after that for at least 45 minutes. 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.

Reason for the request – The rules associated with part 91.151 “Fuel requirements for flights in 

VFR conditions” are not pertinent to the company’s sUA. The company sUA carry no flammable 

liquids/fuel. The company cannot comply with the rule because our sUA are electrically powered with 

between 20 and 30 minutes of actual battery life/operating time available. This is less than the 

minimum fuel required as a reserve during a day VFR flight in a manned aircraft. 

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated “Fuel 

requirements for flights in VFR conditions.”

Equal level of safety – Exemption from the rules associated with part 91.151 will have no bearing 

on safe operation because the company’s sUA operate on batteries. Safety will be enhanced in our 

operations because the sUA are required to remain within line of sight of the pilot and consequently 

well within range of their takeoff point at all times. Because of the short duration of their battery 

charge and 1 kilometer range of its radio controls, our sUA will not be engaged in cross-country 

operations. The company will continue to plan for VFR flight checking weather and winds, but will not 

conduct any cross-country operations. All flights will be safely terminated with a reserve battery 

power of no less than 25% of their maximum charge. 

Public benefit – There is no benefit or loss to the public by relieving the company of compliance 

with the rules of this regulation. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.151: “Fuel 

requirements for flights in VFR conditions” because the rules are not applicable to their sUA 

operations. The company will continue to plan for VFR flight checking weather and winds, but will not 

conduct any cross-country operations because the short range of control and the short duration of 

the sUA battery charge does not permit it. All flights will be safely terminated with a reserve battery 

power of no less than 25% of their maximum charge. 

91.405 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;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance 

records indicating the aircraft has been approved for return to service; 
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(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by 

§91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required 

inspection; and 

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a 

placard has been installed as required by §43.11 of this chapter.

Reason for the request – This regulation is not pertinent to sUA because they are not 

manufactured in accordance with 14 CFR airworthiness standards. The company sUA do not have 

any part 43 FAA required inspections. Neither do they have any flight instruments that require 

inspection or placards when they fail. 

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated with 91.405 

“Maintenance required.”

Equal level of safety – The manufacturer of the company’s sUA provide guidance for maintaining 

them in the operator’s manual provided when purchasing the sUA. In the interest of safety of flight, 

efficient operation and preservation of company assets the company sUA will be maintained to 

manufacturer’s standards. The manufacturer provides a troubleshooting guide, a 24/7 hotline for 

assistance in maintaining the sUA, and deep-level repair at their US facility. 

Any company sUA that has undergone maintenance or alterations that affects the operation or flight 

characteristics will undergo a functional test flight prior to conduct further operations under this 

exemption. Functional test flights will be conducted by a pilot with a visual observer and shall remain 

at least 500 feet from other people in such a manner so as to not pose an undue hazard to persons 

and property. 

Public benefit – There is no benefit or loss to the public by relieving the company of compliance 

with the rules of this regulation. 

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.405: “Maintenance 

required.” The company sUA is not a passenger carrying aircraft and is not manufactured to 14 CFR 

airworthiness standards. Maintenance is provided by the owner utilizing the manufacturer’s 

instruction manual, a 24/7 hotline with the company and if necessary advanced maintenance 

provided at the manufacturer’s United States facility. 

91.407 Operation after maintenance

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; 

and 

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has 

been made. 
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(b) No person may carry any person (other than crewmembers) in an aircraft that has been maintained, 

rebuilt, or altered in a manner that may have appreciably changed its flight characteristics or substantially 

affected its operation in flight until an appropriately rated pilot with at least a private pilot certificate flies 

the aircraft, makes an operational check of the maintenance performed or alteration made, and logs the 

flight in the aircraft records. 

(c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to flight, 

ground tests, inspection, or both show conclusively that the maintenance, preventive maintenance, 

rebuilding, or alteration has not appreciably changed the flight characteristics or substantially affected the 

flight operation of the aircraft.

Reason for the request – This regulation is not pertinent to the company’s sUA as it is not 

manufactured to 14 CFR, Part 43 or Part 21 airworthiness standards. The aircraft is “unmanned” so 

rules pertinent to the carriage of passengers and flight by a pilot after repair or alteration are not 

applicable to the sUA and the company’s operation. 

Extent of relief – Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.407, 

“Operation after maintenance.”

Equal level of safety –The level of safety assured by this regulation is unaffected by the company’s 

relief from its rules because the sUA will be maintained to manufacturers’ standards by the 

company. In the interest of safety, effectiveness of the equipment and preservation of company 

assets the company’s aircraft will be maintained and safely operated to meet manufacturer’s 

standards. In the interest of safety of flight, efficient operation and preservation of company assets 

any company sUA that has undergone maintenance or alterations that affects the operation or flight 

characteristics will undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights will be conducted by a pilot with a visual observer and shall remain 

at least 500 feet from other people in such a manner so as to not pose an undue hazard to persons 

and property. 

Public benefit – Public assets and manpower will be preserved because there is no requirement for 

an FAA maintenance inspector to examine Part 43 maintenance performed by an FAA certificated 

Airframe and Power-plant mechanic. Even so, the FAA can continue to monitor and check the 

maintenance performed by the company as desired.

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.407, “Operation 

after maintenance” because it is not applicable to sUA. Since the sUA is unmanned, rules referring 

to operation of the aircraft with a pilot or passenger onboard are not applicable. Safety of flight will 

require post-maintenance check flights be conducted in such a way as to avoid persons or property. 

91.409 Inspections 
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(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. 

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any 

person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft 

which that person provides, unless within the preceding 100 hours of time in service the aircraft has 

received an annual or 100-hour inspection and been approved for return to service in accordance with part 

43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. The 100-hour limitation may be exceeded by not more than 10 

hours while en route to reach a place where the inspection can be done. The excess time used to reach a 

place where the inspection can be done must be included in computing the next 100 hours of time in 

service. 

(c) Paragraphs (a) and (b) of this section do not apply to—

(1) An aircraft that carries a special flight permit, a current experimental certificate, or a light-sport 

or provisional airworthiness certificate; 

(2) An aircraft inspected in accordance with an approved aircraft inspection program under part 

125 or 135 of this chapter and so identified by the registration number in the operations 

specifications of the certificate holder having the approved inspection program; 

(3) An aircraft subject to the requirements of paragraph (d) or (e) of this section; or 

(4) Turbine-powered rotorcraft when the operator elects to inspect that rotorcraft in accordance 

with paragraph (e) of this section. 

(d) Progressive inspection. Each registered owner or operator of an aircraft desiring to use a progressive 

inspection program must submit a written request to the FAA Flight Standards district office having 

jurisdiction over the area in which the applicant is located, and shall provide—

(1) A certificated mechanic holding an inspection authorization, a certificated airframe repair 

station, or the manufacturer of the aircraft to supervise or conduct the progressive inspection;

(2) A current inspection procedures manual available and readily understandable to pilot and 

maintenance personnel containing, in detail—

(i) An explanation of the progressive inspection, including the continuity of inspection 

responsibility, the making of reports, and the keeping of records and technical reference 

material;

(ii) An inspection schedule, specifying the intervals in hours or days when routine and 

detailed inspections will be performed and including instructions for exceeding an 

inspection interval by not more than 10 hours while en route and for changing an 

inspection interval because of service experience;

(iii) Sample routine and detailed inspection forms and instructions for their use; and
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(iv) Sample reports and records and instructions for their use;

(3) Enough housing and equipment for necessary disassembly and proper inspection of the aircraft; and

(4) Appropriate current technical information for the aircraft.

The frequency and detail of the progressive inspection shall provide for the complete inspection of the 

aircraft within each 12 calendar months and be consistent with the manufacturer's recommendations, field 

service experience, and the kind of operation in which the aircraft is engaged. The progressive inspection 

schedule must ensure that the aircraft, at all times, will be airworthy and will conform to all applicable FAA 

aircraft specifications, type certificate data sheets, airworthiness directives, and other approved data. If 

the progressive inspection is discontinued, the owner or operator shall immediately notify the local FAA 

Flight Standards district office, in writing, of the discontinuance. After the discontinuance, the first annual 

inspection under §91.409(a)(1) is due within 12 calendar months after the last complete inspection of the 

aircraft under the progressive inspection. The 100-hour inspection under §91.409(b) is due within 100 

hours after that complete inspection. A complete inspection of the aircraft, for the purpose of determining 

when the annual and 100-hour inspections are due, requires a detailed inspection of the aircraft and all its 

components in accordance with the progressive inspection. A routine inspection of the aircraft and a 

detailed inspection of several components is not considered to be a complete inspection.

(e) Large airplanes (to which part 125 is not applicable), turbojet multiengine airplanes, turbopropeller-powered multiengine airplanes, and turbine-powered rotorcraft. No person may operate 

a large airplane, turbojet multiengine airplane, turbo-propeller powered multiengine airplane, or 

turbine-powered rotorcraft unless the replacement times for life-limited parts specified in the 

aircraft specifications, type data sheets, or other documents approved by the Administrator are 

complied with and the airplane or turbine-powered rotorcraft, including the airframe, engines, 

propellers, rotors, appliances, survival equipment, and emergency equipment, is inspected in 

accordance with an inspection program selected under the provisions of paragraph (f) of this 

section, except that, the owner or operator of a turbine-powered rotorcraft may elect to use the 

inspection provisions of §91.409(a), (b), (c), or (d) in lieu of an inspection option of §91.409(f). 

(f) Selection of inspection program under paragraph (e) of this section. The registered owner or 

operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section 

must select, identify in the aircraft maintenance records, and use one of the following programs 

for the inspection of the aircraft: 

(1) A continuous airworthiness inspection program that is part of a continuous 

airworthiness maintenance program currently in use by a person holding an air carrier 

operating certificate or an operating certificate issued under part 121 or 135 of this 

chapter and operating that make and model aircraft under part 121 of this chapter or 

operating that make and model under part 135 of this chapter and maintaining it under 

§135.411(a)(2) of this chapter. 

(2) An approved aircraft inspection program approved under §135.419 of this chapter and 

currently in use by a person holding an operating certificate issued under part 135 of this 

chapter. 

(3) A current inspection program recommended by the manufacturer. 

(4) Any other inspection program established by the registered owner or operator of that 

airplane or turbine-powered rotorcraft and approved by the Administrator under 
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paragraph (g) of this section. However, the Administrator may require revision of this 

inspection program in accordance with the provisions of §91.415.

Each operator shall include in the selected program the name and address of the person 

responsible for scheduling the inspections required by the program and make a copy of 

that program available to the person performing inspections on the aircraft and, upon 

request, to the Administrator. 

(g) Inspection program approved under paragraph (e) of this section. Each operator of an airplane or 

turbine-powered rotorcraft desiring to establish or change an approved inspection program under 

paragraph (f)(4) of this section must submit the program for approval to the local FAA Flight Standards 

district office having jurisdiction over the area in which the aircraft is based. The program must be in 

writing and include at least the following information: 

(1) Instructions and procedures for the conduct of inspections for the particular make and model 

airplane or turbine-powered rotorcraft, including necessary tests and checks. The instructions and 

procedures must set forth in detail the parts and areas of the airframe, engines, propellers, rotors, 

and appliances, including survival and emergency equipment required to be inspected. 

(2) A schedule for performing the inspections that must be performed under the program 

expressed in terms of the time in service, calendar time, number of system operations, or any 

combination of these. 

(h) Changes from one inspection program to another. When an operator changes from one inspection 

program under paragraph (f) of this section to another, the time in service, calendar times, or cycles of 

operation accumulated under the previous program must be applied in determining inspection due times 

under the new program.

Reason for the request – This regulation is only pertinent for manned aircraft build under 14 CFR 

regulations.

Extent of relief – Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.409 

“Inspections.”

Equal level of safety –The level of safety assured by this regulation is unaffected by the company’s 

relief from its rules because the sUA will be maintained to manufacturers’ standards by the 

company. In the interest of safety, effectiveness of the equipment and preservation of company 

assets the company’s aircraft will be maintained and safely operated to meet manufacturer’s 

standards. In the interest of safety of flight, efficient operation and preservation of company assets 

any company sUA that has undergone maintenance or alterations that affects the operation or flight 

characteristics will undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights will be conducted by a pilot with a visual observer and shall remain 

at least 500 feet from other people in such a manner so as to not pose an undue hazard to persons 

and property. 

Public benefit – Public assets and manpower will be preserved because there is no requirement for 

an FAA maintenance inspector to examine Part 43 maintenance performed by an FAA certificated 
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Airframe and Power plant mechanic. Even so, the FAA can continue to monitor and check the 

maintenance performed by the company as desired.

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.409 “Inspections.”

because it is not applicable to sUA. Since the sUA is unmanned, rules referring to operation of the 

aircraft with a pilot or passenger onboard are not applicable. Safety of flight and will require postmaintenance check flights be conducted in such a way as to avoid persons or property. 

91.417 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 

(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 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 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. 
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(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. 

(c) The owner or operator shall make all maintenance records required to be kept by this section available 

for inspection by the Administrator or any authorized representative of the National Transportation Safety 

Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this 

section for inspection upon request of any law enforcement officer. 

(d) When a fuel tank is installed within the passenger compartment or a baggage compartment pursuant to 

part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner 

or operator.

Reason for the request – This regulation is only pertinent for manned aircraft built under 14 CFR 

regulations.

Extent of relief – Aerial Logistics NW LLC requests relief from the rules associated with 14 CFR, 

Part 91.417, “Maintenance records.”

Equal level of safety – The level of safety assured by this regulation is unaffected by the company’s 

relief from its rules because the sUA will be maintained to manufacturers’ standards by the 

company. In the interest of safety, effectiveness of the equipment and preservation of company 

assets the company’s aircraft will be maintained and safely operated to meet manufacturer’s 

standards. In the interest of safety of flight, efficient operation and preservation of company assets 

any company sUA that has undergone maintenance or alterations that affects the operation or flight 

characteristics will undergo a functional test flight prior to conducting further operations under this 

exemption. Functional test flights will be conducted by a pilot with a visual observer and shall remain 

at least 500 feet from other people in such a manner so as to not pose an undue hazard to persons 

and property. 

Public benefit – Public assets and manpower will be preserved because there is no requirement for 

an FAA maintenance inspector to examine Part 43 maintenance performed by an FAA certificated 

Airframe and Power plant mechanic. Even so, the FAA can continue to monitor and check the 

maintenance performed by the company as desired.

Summary: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.417 “Maintenance 

records,” because it is not applicable to sUA. Since the sUA is unmanned, rules referring to 

operation of the aircraft with a pilot or passenger onboard are not applicable. Safety of flight and will 

require post-maintenance check flights be conducted in such a way as to avoid persons or property. 

Describe the design and operational characteristics for the type(s) of UAS the

company intends to operate.

The company intends to operate Yuneec ‘Typhoon Q500/ 500H,’ Yuneec ‘Tornado 

H920,’The DJI ‘Phantom,’ the DJI ‘Inspire,’ Sensefly ‘Ebee Ag,’ Precision Hawk 

‘Landcaster Platform,’ and the 3D Robotix ‘IRIS.’ Because these Unmanned Aerial 
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Systems weigh less than 55 pounds each (including payload) they are classified as 

Small Unmanned Aircraft (sUA). These models are “quadcopters” with four propellers 

driven by electric motors or ‘hexcopters’ driven by eight propellers. We also intend to 

utilize two types of fixed wing sUA driven by one electric driven propeller. The 

Quadcopter and Hexcopter has a set of skid type landing gear for vertical landings. The 

fixed wing sUA have a fixed set for landing gear that will aid in roll-on landings.

The Quadcopter and the Hexcopter have similar flight characteristics and performance 

similar to a helicopter and the fixed wing sUA flight characteristics would model most 

manned fixed wing airplanes. They are remotely controlled by a standard 10 channel 

radio control device common to recreational radio controlled aircraft. Sensors of various 

types can be attached to a pilot controlled gimbal mount on the underside of the sUA. 

The company will use remotely controlled digital cameras for the type the sUA is 

designed to carry, such as the “gopro HERO4.”

Aircraft performance and limitations.

The company operates seven models of sUA. General operating limitations listed here 

are optimal and are representative of capabilities that can be met by all seven models. 

Some models may perform better than the specifications listed here i.e. have longer 

operating times on a single battery charge, operate at higher ambient temperatures, higher 

altitudes above sea level or maneuver at faster rates.

Battery charge duration depends on the flight’s altitude above sea level. Maximum 

duration of flight below 3000 feet above mean sea level (MSL) is between 15 – 45

minutes with a full battery charge depending on sUA model, with the DJI Phantom noting 

a 30 minute maximum flight time in the same operating regime. Flights of 11 minutes 

have been documented by users at the service ceiling altitude. 

Maximum airspeed allowed for sUA is 100 mph.

Maximum speed of our sUA are 35 mph.

Operating temperatures: -10°C to 40°C (80°C for the ‘Typhoon’)

Maximum bank angle: 35° at 300° per second

Maximum yaw rate: 150° per second

Maximum rate of climb: 1200 feet per minute (fpm)

Maximum rate of descent: 400 fpm

Service ceiling: 12,000 feet MSL @ -9°C 

Maximum legal altitude: 400 feet AGL (above ground level)

Maximum controllable range from the pilot: 1000m, (0.6 miles)

Provide aircraft loading information in as much detail as possible.
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All models of sUA operated by the company are equipped with a removable 

camera which when attached, brings the sUA to the maximum gross weight

reflected below. (All weights are based on a grams to pounds conversion). 

DJI ‘Inspire’ – 6.5 lbs.

DJI ‘Phantom’ – 2.8 lbs.

3D Robotix ‘Iris’ – 2.9 lbs.

Yuneec ‘Typhoon’ – 3.7 lbs.

Yuneec ‘Tornado’ – 11 lbs.

Sensefly ‘Ebee Ag’ – 1.25 lbs.

Precision Hawk ‘Landcaster’ – 7.5 lbs.

All aircraft will perform normally at the service ceiling at maximum gross weight. 

Operating procedures will vary based on the job, location, customer and the sUA used to 

complete it. But procedures used that are common to every flight include conduct of a company Site 

Assessment, Risk Management Assessment and Safety Mitigation Plan. These 

documents are included later in this document. These documents describe in detail how a safe 

and legal company flight is to be planned, performed, terminated and recorded.

Each job will be conducted by a minimum of one FAA certificated and company trained 

pilot and one company trained visual observer. After conducting the Site Assessment

and Risk Management Assessment, the pilot and observer will work together to 

produce a Safety Mitigation Plan. This document will serve as a flight plan for the 

conduct of the job. All of these documents will be turned over to and maintained by 

company management at the completion of the job to document flight time, the planning 

for the flight and the lessons learned in performing the job. These lessons will be 

circulated throughout the company and covered in training in order to increase the level 

of safety and efficiency of the operation.

Company personnel are trained to either not launch, discontinue or terminate a flight 

immediately whenever any unplanned hazard or risk develops. Flight will not be initiated 

or continued until the identified risk or hazard has been mitigated or eliminated. Flying 

safely is the most important element of our business. No job is worth risking injury to 

people, damage to property over which we fly or damage or loss of our equipment.

Petitioners should describe any procedures they would implement to ensure that 

the UAS is in a condition for safe flight, such as:
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Pre-flight inspections – A careful preflight inspection will be conducted on company 

aircraft before each flight by using guidance in the manufacturer’s operator’s manual.

During Pre-flight inspections the pilot will look for mechanical or electronic defects in 

order to insure the sUA is in good condition and safe for flight. The pilot will check radio 

controls, structural members, landing gear and propellers for improper function, damage 

and wear. Company operating procedures require that the pilot conduct performance 

and power checks (such as hover in and out of ground effect checks) prior to departing 

the takeoff area for a flight. 

Maintenance and repair – Aerial Logistics NW LLC will use the manufacturer’s 

recommended component maintenance. Since these manuals are limited to owner 

maintenance the company will refer to the manufacturer’s help line for advice on

overhaul, replacement, inspection, and component life limits to repair or replace parts

and keep the aircraft in good repair. In the interest of safety, effectiveness of the 

equipment and preservation of company assets the company’s aircraft will be 

maintained and safely operated to meet manufacturer’s standards. 

Where covered by owner’s manual instructions, repair and maintenance shall be 

completed by the company. Higher level maintenance will be completed with reference 

to the manufacturer’s help line to complete the repair in-house or by returning the sUA to 

an authorized repair facility. 

Any company sUA that has undergone maintenance or alterations that affects the 

operation or flight characteristics will undergo a functional test flight prior to conducting 

further operations under this exemption. Functional test flights will be conducted by a 

pilot with a visual observer and shall remain at least 500 feet from other people in such a 

manner so as to not pose an undue hazard to persons and property. 

Maintenance Manuals – The company owner’s manual that comes with each sUA 

contains procedures for troubleshooting and maintaining the aircraft. These will serve as 

the company maintenance manuals. A record of flights with discrepancies found and 

type of repair performed will be kept in the sUA logbook as a company record. 

Describe the Radio Frequency (RF) spectrum used for control of the UAS and 

associated equipment that is part of the UAS (i.e., sensors, cameras, etc.)

All company aircraft onboard systems and remote radio controllers comply with FCC 

requirements for model (radio controlled) aircraft. The PIC inputs to the aircraft are

maintained by standard 10 channel remote controls operating on the 2.4GHz RC band. 

Video downlink is achieved on the 5.8GHz band. Documentation of this compliance is 

printed in the operator’s manuals for each aircraft.
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Describe the qualifications required of any PIC(s) who will be directly responsible 

for the operation of the uAS.

14 CFR, Sec. 91.3 will govern the authority of the company pilots. 

Sec. 91.3 — Responsibility and authority of the pilot in command.

(a) The pilot in command of an aircraft is directly responsible for, and is the final 

authority as to, the operation of that aircraft.

Under this grant of exemption, a company PIC must hold a US Federal Aviation 

Administration (FAA) pilot certificate either recreational, private, commercial or airline 

transport. 

The PIC must possess a current US driver’s license and/or a current FAA Class I, II or III 

medical certificate. The sUA must be operated within visual line of sight (VLOS) of the 

PIC at all times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses.

The pilot must also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the pilot is rated on his or her pilot certificate.

The company shall not permit any PIC to operate unless the pilot demonstrates the 

ability to safely operate the uAS in a manner consistent with how the uAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. 

PICs must have at least 5 hours total flight time in Unmanned Aircraft (UA) and 5 hours 

in the type uAS the company flies before conducting company business operation flights. 

PICs must log flight time in a manner consistent with 14 CFR § 61.51(b). Flights shall be 

logged along with their purpose, be it company operations or for the purposes of training 

the PICs and Visual Observers (VO), or for determining the PIC’s ability to safely 

operate the sUA.

Training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered non-participants, and the PIC must operate the sUA.
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Describe the qualifications and roles required of any Visual Observer who will be 

directly responsible for the operation of the UAS and any applicable training 

related to the operation; 

At least one visual observer is required to conduct any sUA company flight. This person 

shall have corrected or uncorrected sight in both eyes and be capable of clear verbal 

communication in the English language.

Except for training flights, Visual Observers (VO) must have received at least one hour 

of ground training to include FAA sUA requirements and regulations and company 

procedures included in this application; and one hour of training with a PIC flying the 

sUA before acting as an observer on company flights. VO training operations may only 

be conducted during dedicated training sessions. 

The role of the VO is to assist the pilot in keeping the sUA in sight and clear of hazards 

and obstructions over the flight planned route. The VO should also: maintain direct lineof-sight observations unaided by anything but corrective lenses; help the pilot conduct 

pre-flight assessments; identify and avoid or otherwise remediate hazards prior to and 

during the flight; find and direct the pilot to safe and appropriate landing sites as 

required; assist the pilot with any task that would cause the pilot to take a hand off of the 

flight controls. The VO will call for the pilot to land the sUA and postpone or discontinue 

the flight whenever he/she is unable to see the sUA or continue his/her duties while the 

sUA is airborne. 

 

Petitioners should describe the medical standards and certification of the PIC(s) 

directly responsible for the operation of the sUA.

The PIC must possess a current US driver’s license and/or a current FAA Class I, II or III 

medical certificate. The sUA must be operated within visual line of sight (VLOS) of the 

PIC at all times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses.

Regarding the Operation of the Unmanned Aircraft:

 

Describe their intended UAS operation(s).

Aerial Logistics NW LLC intends to utilize sUA to safely conduct commercial photography 

and video operations for public, private and commercial use including but not limited to: 

inspection of residential, commercial, and industrial real estate for realty companies; 

assisting engineering firms or agencies and the energy industry in conducting surveys 
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and inspections, assisting wildlife and agriculture businesses or agencies searches and 

surveys; aiding public agencies in search and rescue operations; providing aerial 

videography for TV production companies and providing training for pilots and observers 

in the operation of sUA. . 

Describe how the proposed operation(s) would not adversely affect safety and

how they would provide a level of safety at least equivalent to that provided by

the rule from which exemption is sought.

The FAA has found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no 

passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, gives the FAA good cause to find that the 

UAS operation enabled by this exemption is in the public interest. Likewise it is safer to 

use sUA to conduct many of the requested operations than to rely on a helicopter to 

hover over critical infrastructure, or ask a person to climb on and/or photograph a bridge, 

walk over hazardous terrain, climb a flare stack or other piece of equipment that can 

easily be reached by sUA. 

Describe plans to implement clearly defined operational borders and procedures 

to ensure public safety, which includes persons and property both in the air and 

on the ground. 

Twenty-four hours prior to any flight the company will submit a Notice to Airmen 

(NOTAM) to alert air traffic to the location, time and maximum altitude of our operation. 

Immediately prior to flight the company pilot will do a detailed survey of the site of the 

intended flight and the surrounding area utilizing the company Site Assessment, Risk 

Management Assessment and Safety Mitigation Plan. If hazards or safety risks are 

noted during the initial Site Assessment, these will be mitigated or eliminated before 

flight is conducted. As necessary, signs and/or observers will be placed at points along 

the sUA intended flight path to keep it clear of people, vehicles and other obstructions 

and hazards. Observers noting a hazard will notify the pilot who will immediately take the 

appropriate action to mitigate that risk, which may include re-direction of the sUA to a 

safe area where the flight can be terminated until the risk is mitigated. 

Specify the proposed maximum operating speed and altitude

Regulations limit sUA to 100 mph and 400 feet above the surface.

No company sUA can travel faster than 50 mph. Pilots insure that the job can be safely 

and legally completed at altitudes less than the maximum altitude of 400 feet above the 

surface. 
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Describe minimum flight visibility and distance from clouds for operation(s). 

Aerial Logistics NW LLC intends to use the guidance of 14 CFR, Part 91.155 (b) (1) for 

flight visibility and cloud clearance minimums in Class G airspace. 

(b) Class G Airspace. Notwithstanding the provisions of paragraph (a) of this 

section, the following operations may be conducted in Class G airspace below 

1,200 feet above the surface:

(1) Helicopter. A helicopter may be operated clear of clouds if operated at a 

speed that allows the pilot adequate opportunity to see any air traffic or 

obstruction in time to avoid a collision.

Flights in other airspace as cleared by a Certificate of Authorization for specific flights will 

utilize the most conservative guidelines of Sec. 91.155 used for airplanes as follows:

Sec. 91.155 — Basic VFR weather minimums.

(a) Except as provided in paragraph (b) of this section and §91.157, no 

person may operate an aircraft under VFR when the flight visibility is less, or 

at a distance from clouds that is less, than that prescribed for the 

corresponding altitude and class of airspace in the following table:

Airspace Flight visibility Distance from clouds

Class A - NOT APPLICABLE TO sUA Not Applicable Not Applicable.

Class B 3 statute miles Clear of Clouds.

Class C 3 statute miles 500 feet below.

1,000 feet above.

2,000 feet horizontal.

Class D 3 statute miles 500 feet below.

1,000 feet above.

2,000 feet horizontal.

Class E:
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Less than 10,000 feet MSL 3 statute miles 500 feet below.

1,000 feet above.

2,000 feet horizontal

At or above 10,000 feet MSL

NOT APPLICABLE TO sUA

5 statute miles 1,000 feet below.

1,000 feet above.

1 statute mile horizontal.

Class G:

1,200 feet or less above the surface (regardless of MSL altitude)

Day, except as provided in §91.155(b) 1 statute mile Clear of clouds.

Night, except as provided in §91.155(b)

NOT APPLICABLE TO sUA

3 statute miles 500 feet below.

1,000 feet above.

2,000 feet horizontal.

More than 1,200 feet above the surface but less than 10,000 feet MSL

Day 1 statute mile 500 feet below.

1,000 feet above.

2,000 feet horizontal.

Night

NOT APPLICABLE TO sUA

3 statute miles 500 feet below.

1,000 feet above.

2,000 feet horizontal.

More than 1,200 feet above the surface and at or above 10,000 feet MSL 5 statute miles 1,000 feet below.

1,000 feet above.

1 statute mile horizontal.

Describe potential hazards and safety mitigations associated with these 

proposed conditions. Describe in detail the Risk Analysis of the site so that the 

planned operation can be completed safely. 

Aerial Logistics NW LLC has a comprehensive plan to identify and either mitigate or eliminate 

hazards before a flight is conducted. (see next paragraph) The plan also calls on the pilot and 

observer to accommodate unexpected hazards. Before and then after a flight the pilot and 
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observer works together to plan and then record the flight using the company’s Site 

Assessment, Safety Survey, Safety Hazard Mitigation Plan.

The Site Assessment, Risk Management Assessment and Safety Mitigation Plan

are designed to help the pilot evaluate the planned job and assess the risks at the site and the 

surrounding area where the sUA will be flown. These tools will allow company pilots and 

management to insure all flights are conducted safely and in accordance with regulations and 

guidance from the FAA. They will also act as tools to improve training and day-to-day operations. 

Safety in company operations will improve by passing on the lessons that are learned at each job.
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Site Assessment

Date: ________________________

Pilot:

Observer: 

Job Location: (address, latitude/longitude and/or description).

A Notice to Airmen (NOTAM) must be filed 24 hours before the flight is made.

NOTE!

You may not fly a drone:

 From a moving vehicle or vessel.

 Near military or federal facilities, certain stadiums (see NOTAMs/TFRs), 

emergency services vehicles or stations, power plants, dams, electric substations 

or industrial complexes.

 In a Temporary Flight Restricted area (TFR) or Prohibited Area.

 Near wind farms or oil refineries without permission.

 Near The Disney resorts or inside the Washington DC restricted zones and other 

Special Use airspace.

 Between sunset and sunrise (i.e., no night operations).

 Within 5 miles of an airport unless a Certificate of Authorization is issued for the 

operation by an FAA Flight Standards District Office. 
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Prior to conducting any flight,

The pilot and observer shall walk the site or otherwise evaluate the job site. If this 

is impossible or ability to walk part of the site is limited, the pilot and observer 

shall walk to all points around the site from which they shall observe and control 

the drone. During the site survey the following factors will be considered. 

** Be sure to note other factors not listed that may affect or detract from the safe 

and efficient completion of the job.

Factors to note at the job site:

 Altitude of the site above sea level (Density Altitude)

 Ambient temperature

 Weather (cloud types & height, horizontal visibility and wind direction, velocity 

and gusts, presence of rain, thunderstorms, fog or phenomena that will limit 

visual observation.)

 Air traffic

 People, animals or livestock in the open 

 Birds (especially in flocks and migratory birds like geese, ducks, doves, etc.).

 Structures or property that could be damaged if struck by our drone

 Noise sensitive areas

 Other sensitive areas like cemeteries, historical sites, wildlife refuges, etc.

 Drone prohibited areas like federal or military facilities, power plants, electric 

substations, dams, national parks, emergency services and industrial complexes.

 Wires, antennas, towers and other obstructions to the drone’s flight path

 Roads & Type and frequency of vehicular traffic

 Presence of construction or farm equipment and persons

 Condition of the terrain

 Ponds, streams and other bodies of water

 Height and types of vegetation

 The flight path and its traffic ability (Can you walk it?)

 Safety Area along the intended flight path

 Emergency Landing sites

Other factors I saw during my site assessment are listed here:
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Use this space to map the area and hazards you noted during your 

assessment.
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Risk Management Assessment

Date:________________________

Pilot: Flight Time logged

on this job: ________________

(post this upon ending the flight)

Observer: 

Job Location: (address, latitude/longitude and/or description). 

Address/Location:

The purpose of the Risk Management Assessment is to document your 

evaluation of the job site and record the information you need to plan a safe and 

effective flight. The information you record will help us to plan safe flights and 

train others based on the flight you conduct.

Use your “site assessment” and this “risk management assessment” to create a 

“mitigation plan” to be submitted to the company for each job you do. Note the 

hazards and write down your plan to mitigate them. If a risk cannot be effectively 

and safely mitigated, DO NOT CONDUCT THE FLIGHT!
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Date:________________________

PREFLIGHT RISK ASSESSMENT CHECKLIST

Starting the day before the flight answer the following questions and recheck the day of the flight:

Has a NOTAM been filed 24 hours or more before this flight? If not, cancel the 

flight until the requirement is met.

Has permission of the land/property owners around the site been obtained? 

Have you checked NOTAMs for the local area? 

Does the area for the job include Temporary Flight Restrictions (TFR) or 

Prohibited Areas? 

** NO flights are permitted within the boundaries of a TFR or Prohibited Area.

Is the flight within a Special Flight Rules Area? Flying within these requires 

special procedures. Check FAA.gov for updates on these areas which include 

Washington, D.C., The Hudson River in New York, Luke Air Base and other 

areas around the United States.

Have you checked the weather for trends and for weather that may pose a 

hazard for the intended flight? Are storms or weather limiting visibility predicted 

for the time and place of the flight operation?

Is the weather equal to or better than company minimums AND above the pilot’s 

personal minimums?

(Refer to FAR 91.155 for visibility, cloud clearance and visibility required to 

conduct the flight. Check winds <15 knots and not gusty – Your personal 

minimums can be more conservative than the company’s but not less. You 

don’t HAVE to fly!)

On the day of the flight, re-check the questions above and answer the 

following questions:
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Has a site assessment been conducted that allows you to examine the area of 

operations surrounding the job site for hazards within the area where the drone 

will fly?

(If “no,” conduct that before proceeding with this form) 

Has the pilot and visual observer walked the flight path looking for hazards?

Did the pilot check the appropriate VFR and if applicable the IFR Aviation Charts 

for the site to see if airports, air traffic, instrument approach procedure routes, 

towers, wires or obstructions are charted which may affect the conduct and 

safety of the flight? 

(Note these hazards on the mitigation plan).

Did you check local road maps for the presence of noise sensitive areas (such as 

schools, hospitals, eldercare facilities, churches conducting services) or other 

sensitive areas, (cemeteries, historical sites or wildlife refuges)?

(If “yes” include these on the mitigation plan?)

Are there people (including spectators, gatherings of people) in the open within 

or outside of the edges of the proposed flight path? 

If “yes,” note them on your mitigation plan and prepare a plan to reduce 

the risk our operation might pose to them. 

Verbally notify people in the area that you will be conducting drone 

operations. 

Stay clear and do not overfly uncovered people, pets, livestock, vessels 

and vehicles.

Avoid overflying property that could be damaged if struck by a falling 

drone. 

Did you post warning signs, company observers or otherwise block access to the 

job site where our drone will be operating?

Has the pilot planned and delineated a “safety zone” to keep the flight path clear 

of people, property and obstructions?
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Does the pilot have emergency landing areas along the route that can be rapidly 

reached to safely land the drone from any point in the flight in the event of an 

unchecked hazard, mechanical failure, unexpected weather or other hazard? 

Is the take-off and landing area clear of people and obstructions and segregated 

from public access?

Will the pilot and observer have clear and unobstructed sight of the drone 

throughout the planned flight? 

Can the pilot avoid other aircraft and can the observer(s) restrict or warn 

persons, vessels or vehicles that may enter the flight path?

Is the pilot satisfied that the drone is in 100% safe and serviceable condition? If

“no,” do not fly until repair and (if required) a functional test flight is successfully 

flown. 

Will the pilot and observer have clear, unobstructed verbal communication with 

each other at all points of the flight? 

Can you describe how you will maintain altitude below a maximum of 400 feet 

above the ground?

Can you complete all operations during daylight hours?

(Flights must not begin before sunrise nor continue after sunset).

Are there any other drones working in your area?

(No more than one drone will normally be permitted at any one time within the 

same block of designated airspace).

Did you turn off all personal electronic devices? 

NOTE: Except for devices used to call between the pilot and observer, cell 

phones, radios, devices which use earbuds, head phones or other similar 

distracting devices should be turned off during flight operations. 
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Are there high voltage electric lines, radar dishes or other high power electrical 

facilities in the area which may interfere with the radio control devices 

transmitting between the drone and the pilot?

POST FLIGHT PROCEDURES:

Record flight time on the risk management assessment sheet and in the drone’s 

logbook. 

In keeping with 14 CFR, section 61.51 the pilot shall maintain a record of each 

flight (in a personal logbook or other acceptable record).

Do a post-flight inspection on the remote controls and aircraft for wear or 

damage.

Complete the Safety Mitigation Plan and turn all paperwork associated with the 

flight into company management.
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Describe the characteristics of the area of intended operation(s) and the 

associated potential hazards, in accordance with the statutory mandate under 

Section 333 regarding proximity to populated areas. 

Aerial Logistics NW LLC intends to conduct business operations within the 50 United States. 

Whether working in a small local area or in diverse places, it is the pilot’s responsibility to 

assess and mitigate risks. The company provides the pilot with a checklist/questionnaire to 

help with the site survey and risk assessment. 

After using these safety/operational planning tools the pilot develops a written risk mitigation 

plan to both document and ensure the pilot and later, the company that all available risks had 

been taken into consideration before a flight was conducted. After the flight, the pilot 

evaluates the effectiveness of the mitigation plan. “Lessons learned” are passed throughout 

the company to help other pilots and company employees to learn from the valuable lessons, 

and reduce similar risks at future jobs.

These risk assessment and mitigation tools are submitted to the company management and 

kept as a matter of record. They are to be used in future operations to plan safe and efficient 

ways to do the next job.

These tools are living documents, i.e. the company will continue to modify and update them. 

“Lessons learned” will be compiled and passed to pilots and observers and used to train new 

employees and crews.

Describe if you intend to operate in the proximity of any airports, in accordance 

with the statutory mandate under Section 333 regarding proximity to airports. 

Aerial Logistics NW LLC will follow the regulatory guidance for UAS of remaining clear of 

airports by at least 5 miles and airspace other than Class G. For any exceptions to this 

the company will request a Certificate of Authorization (COA) from the local FAA Flight 

Standards District Office (FSDO).

Any operation in the proximity of airports will be outlined and discussed with the airport 

management and the control tower (if applicable) with details including distance, height, 

time of operation, duration and the pilot and company’s point of contact information. The 

pilot will remain in contact by telephone with the tower during any operation near an 

airport that is approved by the FAA. 

Describe any procedures as they would be implemented for conducting a 

preflight safety risk assessment to determine that the UAS is in a condition for 

safe flight (14 CFR § 91.7(b))
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Sec. 91.7 — Civil aircraft airworthiness.

(b) The pilot in command of a civil aircraft is responsible for determining whether 

that aircraft is in condition for safe flight. The pilot in command shall discontinue the 

flight when unairworthy mechanical, electrical, or structural conditions occur.

As noted earlier, the manufacturer of the company’s sUA provide guidance in maintaining 

them in the operator’s manual provided when purchasing the sUA. In the interest of safety of 

flight, efficient operation and preservation of company assets the company sUA will be 

maintained to manufacturer’s standards. The manufacturer provides a troubleshooting guide, 

a 24/7 hotline for assistance in maintaining the sUA, and deep-level repair at their US facility. 

Any company sUA that has undergone maintenance or alterations that affects the operation 

or flight characteristics will undergo a functional test flight prior to conducting further 

operations under this exemption. Functional test flights will be conducted by a pilot with a 

visual observer and shall remain at least 500 feet from other people in such a manner so as 

to not pose an undue hazard to persons and property. 

End of document