June 26, 2015

Exemption No. 11925

Regulatory Docket No. FAA–2015-1347

James Michael Hourihan

70 Fern Hollow Road

Bridgewater, MA 02324

Dear Mr. Hourihan:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 20, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. You requested to operate an unmanned aircraft system (UAS) to conduct 

EMS/fire emergency support, police operation support and missing persons support.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision, DJI Phantom 3 and DJI 

S1000.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 
2

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA 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.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, James Michael Hourihan is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c),

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, James Michael Hourihan is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision, DJI Phantom 3 and DJI S1000 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 
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operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

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

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC 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. PIC 
5

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

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 nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must 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. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from certain parts of the FARs.

James Michael Hourihan

April 20, 2015

Name / Address of Petitioner:

James Michael Hourihan

70 Fern Hollow Rd

Bridgewater, MA 02324

Telephone Number of Petitioner: ​617.838.6453

Email:​mike.hourihan@bostonmedflight.org

Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2)

14 C.F.R. § 45.23(b) 14 C.F.R. § 91.103 14 CFR § 61.3

14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121

14 CFR § 91.151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.205(b)

14 CFR § 91.215 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3

Appendix A​describes the FARs from which an exemption is requested and summarizes the

justification for each requested exemption.

This Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the

Reform Act, which directs the Secretary of Transportation to consider whether certain

unmanned aircraft systems may operate safely in the national airspace system (NAS) before

completion of the rulemaking required under Section 332 of the Reform Act. In making this

determination, the Administrator must determine which types of UASs do not create a hazard

to users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a).

If the Administrator determines that such vehicles “may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such aircraft in

the national airspace system.” Id. § 333(c).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

1
The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its

regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which

includes sUASs. The Administrator may grant an exemption from a requirement of a

regulation prescribed under subsection (a) or (b) of this section or any sections 44702­44716

of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49

U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1).

Petitioner Background:

The Petitioner has served proudly as a Flight Paramedic for Boston MedFlight for the past six

years to the present day. Boston MedFlight operates several EC­145, Sikorsky S76 C++

helicopters and a Cessna Citation jet. As a Flight Medic, the Petitioner routinely functions as

a clinician and as an aid to the PIC with radio communications, GPS navigation and

see­and­avoid operations. After completing hundreds of emergency rotor and fixed wing

missions in the NAS, his respect for aviation safety and the need for careful, regulated sUAS

integration into the NAS is unmatched.

The Petitioner has also been a model helicopter, fixed wing and multirotor hobbyist for eight

years and has been a member of the American Aeromodellers Association (AMA).

After a thirteen year career in EMS / SAR / Aeromedical operations in New England, the

Petitioner is in a unique position to not only safely utilize sUAS technology in the NAS, but to

serve as a leader to other sUAS operators. If permission is granted, the Petitioner will serve

numerous Local, State and Federal entities. The professional relationships he’s cultivated

with the Massachusetts State Police, USCG and endless Fire and Police departments would

serve as a conduit to safe sUAS implementation into the local airspace. His significant

on­scene emergency aeromedical experience with full scale helicopters will serve as the

backbone for safe, efficient sUAS operations in numerous roles. His business model in place

would include but is not limited to EMS / Fire emergency support, Police operation support

and missing persons support.

At no time will he operate outside the clearly outlined sUAS guidelines published by the FAA.

For example, never >400’AGL, within five miles of an airport or beyond VLOS.

Petitioner also notes and has read the congressional mandate in sections 332 and 333 of the

FAA Revitalization and Reform Act of 2012 that the FAA move quickly to accommodate the

economic and societal benefits that can result from widespread deployment of sUAS

technology. Accordingly, Petitioner applies for authorization under the Federal Aviation Act

and the FARs to undertake the aforementioned activities for commercial purposes. If the

Petition is granted, Petitioner will be at a significant competitive advantage if it, as it prefers,

complies with FAA policy.

2
Vehicle(s):

The Petitioner will fly one or more DJI Phantom 3s, DJI Phantom 2 Visions, DJI S1000s

equipped with a three­axis camera gimbal. OE / IR / Thermal imagers may be fielded for

better data acquisition as needed.

These vehicles have the built in capability to limit the height they fly above the ground, to limit

the radius of the distance they fly from the operator, and to exclude them from class B, C, and

D airspace as well any TFR’s (Temporary Flight Restricted) areas. The vehicles also have the

built­in capability to return to the launching point if the wireless control link is interrupted or if

the operator attempts to exceed any of the height, radius, or airspace limitations programmed

into them. The vehicle weighs about five pounds and has a maximum gross weight of

approximately twenty pounds. It has a top speed of about 30 knots. It has four fixed­pitch

rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer smart

battery.

Flight profiles:

The petitioner will program the Phantoms or S1000 so that they will not fly more than 400 feet

above ground level, or more than 1500 feet away from its operator. The PIC (Person in

Control) will carefully preflight the vehicle before each mission to assure that its compass and

GPS system are properly calibrated and that the return­to­home feature, altitude, and radius

limitations work.

They will not operate in controlled airspace. In the unlikely event that a manned aircraft flies

below 400 feet AGL where the Petitioner is operating its Phantom, the operator will keep both

the vehicle and manned aircraft in sight and avoid the manned aircraft.

More particularly, the Petitioner will fly the Phantoms or S1000 only over the hazard areas

that are in control of an on­scene Incident Commander, most likely being a Fire Chief, SAR

rep or Police rep, etc.

The Petitioner will not conduct flight operations of any kind without a minimum of three

dedicated personal. A PIC, SIC and observer will be present and functioning as a cohesive

flight team for each mission.

Public interest Granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of sUAS into

the National Airspace System advances the public interest. The Committee Report leading

the House to adopt H.R. 658 said: "The successful integration of unmanned aircraft systems

(UAS) into the National Airspace System (NAS) can support more than 23,000 high­paying

jobs in the United States. . . . The absence of a plan to integrate UASs into the NAS is a

barrier to such job creation . . . ."1 Granting the Petition represents a step toward such

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integration, in the absence of a comprehensive regulatory regime for sUAS, and thus would

serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in Emergency Response activities, one in

which the responders themselves have a tool to safely, quickly and remotely assess a

situation without placing lives in harm’s way. In comparison, the EOD robots have saved

countless lives since their inception, a feat that will become common place for aerial

assessments.

3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of

creating new safety techniques and tactics with new aeronautical technology, thereby

improving the efficiency of Emergency Responders around the world and making for a safer

society. The rules from which Petitioner seeks exemption artificially and irrationally limit the

effective use of new technologies to expand Emergency Response safety and improve the

efficiency of markets, thereby subverting the public interest.

______________________________________

1. H. R. Rep. 112­29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House­Senate Conference Committee on the

FAA Modernization and Reform Act of 2012 recommended amendments to H.R. 658 in lieu of amendments adopted

by the Senate. Conference Report to Accompany H.R. 658, H.R. Rep. 112­381, 112th Cong., 2d Sess., at p. 1 (Feb.

1, 2012).

4. Granting this Petition will enable the Petitioner to help demonstrate that the FAAs sUAS

FARs are indeed a safe and effective means in which to govern the NAS. He will serve as an

advocate for the practice of lawful sUAS operations.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new aviation

technologies advances the public interest. The FAA itself has recognized the public interest in

its role of "Encouraging and developing civil aeronautics, including new aviation technology."2

Granting the Petition will enhance FAA fulfillment of that commitment, thereby serving the

public interest. Air commerce flourishes in the United States because of the rapid pace of

innovation in aeronautical and associated technologies, followed by their commercialization

and their introduction into the marketplace. The drone technology that the Petitioner uses

exemplifies the latest innovative leap forward in aeronautical technology. Preventing it from

using this in air commerce subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS

technology into the NAS serves the public interest. Section 330 of the FAA Modernization and

Reform Act of 2012, specifically recognizes the advantages to air commerce obtainable from

the deployment of sUAS technologies. It mandated several steps by the FAA to accelerate the

availability of these technologies in the National Airspace System, thereby representing a

congressional determination that the public interest is served by making these technologies

more widely available at the earliest practicable date. The Petition represents a way for the

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FAA to move incrementally, while still satisfying its congressional mandate and meeting its

obligation to enhance the public interest by making new technologies available by allowing the

use of sUAS technologies in a manner that protects the public and the rest of the aviation

community from significant risk.

The commercial activities by Petitioner proposed in the Petition represent contributions to new

forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 2012 Act.

7. Granting the Petition will enhance aviation safety, thereby advancing the public interest.

The Petitioner has committed itself in the Petition to safety practices that reduce or eliminate

hazards to aircraft in the National Airspace System and to persons and property on the

ground. Many others are flying sUAS without regard to these hazards. Granting the Petition

will offer the Petitioner up as an example of how the FAA is willing to accommodate the new

technology when it is constrained by appropriate limitations to enhance safety. It will also

allow the Petitioner to be a role model for safe commercial sUAS operations.

Users of the National Airspace System are confronted by mushrooming threats from sUAS

flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to accommodate

lawful and safe operation of sUAS for legitimate commercial purposes, the level of defiance

will increase, intensifying the hazards to manned aircraft and to persons and property on the

ground.

Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from certain parts of the FARs.

Thank you very kindly for exemption consideration.

Sincerely

James Michael Hourihan

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APPENDIX A

FAR SUBJECT JUSTIFICATION

14 CFR § 45.23(b) Requirement to display

registration number on

vehicle

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification

requirements and

procedures

Designed for manned

aircraft; not suitable for

off­the­shelf sUAS

14 CFR § 61.3 Requirement for pilot

certificate

Part 61 requirements

designed for manned

aircraft, not sUAS; petition

describes training for sUAS

operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned

aircraft; not suitable for

off­the­shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to

be available in the cockpit

No one aboard to read

manual

14 CFR § 91.103(b) Requirement for crew

members to be onboard

Unmanned vehicle

6
14 CFR § 91.109 Requirement for dual

controls during flight

instruction

No one aboard to operate

controls

14 CFR § 91.119 Minimum altitudes for safe

flight

Safety requires operation

below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration

and airworthiness

certificates to be onboard

No one aboard to read

certificates

14 CFR § 91.205(b) aboard Cockpit instruments No one to read

FAR SUBJECT JUSTIFICATION

14 CFR § 45.23(b) Requirement to display

registration number on

vehicle

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification

requirements and

procedures

Designed for manned

aircraft; not suitable for

off­the­shelf sUAS

14 CFR § 61.3 Requirement for pilot

certificate

Part 61 requirements

designed for manned

aircraft, not sUAS; petition

describes training for sUAS

operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned

aircraft; not suitable for

off­the­shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to

be available in the cockpit

No one aboard to read

manual

14 CFR § 91.103(b) Requirement for crew

members to be onboard

Unmanned vehicle

7
14 CFR § 91.109 Requirement for dual

controls during flight

instruction

No one aboard to operate

controls

14 CFR § 91.119 Minimum altitudes for safe

flight

Safety requires operation

below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration

and airworthiness

certificates to be onboard

No one aboard to read

certificates

8