14 C.F.R. 21, subpart H­ Airworthiness Certificates 14 CFR §§ 91.203­(a) (1)

Civil aircraft:

Certifications required.

(a) Except as provided in 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness certificate used to

comply with this subparagraph (except a special flight permit, a copy of the applicable operations

specifications issued under §21.197

This regulation establishes the procedure requirements for the issuance of an airworthiness certificate.

Given the size and weight of the aircraft utilized by Go Pilot, this meets the requirements of an equivalent

of safety under Part 11, Section 333 of the Reform Act. The Federal Aviation Act (49 USC §44701 F) and

Section 333 of the Reform Act both authorize the FAA to exempt the UASs from the requirement for an

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and

proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria

demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment

and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed.

14 CFR 45.23(b)­Display of marks.

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on

limited, restricted or light­sport category aircraft or experimental or provisionally certificated aircraft, the

operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in

letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light­sport,”

“experimental,” or “provisional,” as applicable.

Even though the UA will have no airworthiness certificate, modifications will need to be made to the

requirements of this regulation, due to the size and type of aircraft seeking exemption,

­As this UAS does not have a cabin, cockpit or pilot station, lettering cannot be displayed. I

propose placing the word “experimental” on the fuselage, in compliance with § 45. 29(f), therefore

providing an equivalent level of safety, enabling pilot, observer and others working with the UAS to see

the identification as “experimental.”

­Due to the size of the UAS, adhering to the size requirements of the lettering will be impossible,

however, lettering will be used that is as large as possible to fit on given UAS.

14 CFR § 61.113 (a) & (b)­Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot

certificate may act as pilot in command of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an

aircraft.

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

connection with any business or employment if:

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

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

1
Unlike conventional aircraft, UAS will not carry a pilot or passenger nor any cargo, which means that an

equivalent level of safety can be achieved, minimally, through the supervision of operations by an

individual on the ground holding a private pilot’s license. This positioning results in an increased level

of safety in comparison to that of a commercial pilot holding a certificate operating a conventional

aircraft.

14 CFR § 61.133­ Commercial pilot privileges and limitations.

(a) Privileges—(1) General. A person who holds a commercial pilot certificate may act as pilot in

command of an aircraft—

(i) Carrying persons or property for compensation or hire, provided the person is qualified in

accordance with this part and with the applicable parts of this chapter that apply to the operation; and

(ii) For compensation or hire, provided the person is qualified in accordance with this part and with the

applicable parts of this chapter that apply to the operation.

Unlike conventional aircraft, UAS will not carry a pilot or passenger, which means that an equivalent

level of safety can be achieved, minimally, through the supervision of operations by an individual on the

ground holding a private pilot’s license.

14 CFR § 91.7 (a)­ Civil aircraft airworthiness.

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

(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.

The pilot in command will determine whether the UAS is in condition for safe flight, since there will be no

airworthiness certificate issued by the FAA for this aircraft. The pilot in command will follow

pre­established safety guidelines and/or checklists.

14 CFR § 91.9 (b)(2)­Civil aircraft flight manual, marking, and placard requirements.

(b) No person may operate a U.S.­registered civil aircraft—

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved

manual material, markings, and placards, or any combination thereof.

It is understood that this regulation is requiring the possession of the UAS flight manual, markings and

placard requirements to be met. However, as the UAS does not have a crew nor the physical capabilities

to store a manual or placard, these items will be be made available to the crew at the ground station

anytime the aircraft is in, or preparing for, flight.

14 CFR § 91.103(b)­Preflight action.

2
Each pilot in command shall, before beginning a flight, become familiar with all available information

concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing

distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff

and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable

information appropriate to the aircraft, relating to aircraft performance under expected values of airport

elevation and runway slope, aircraft gross weight, and wind and temperature.

The pilot in command will do all necessary research and preflight actions to ensure the safety of each

flight. This includes all standard preflight actions, such as reviewing weather, airspace, NOTAMS, TRFs

flight battery requirements, takeoff and landing distances, and performance data before commencement

of flight. In addition, the pilot in command will verify that all components attached to the UAS are secure

prior to each flight.

14 CFR § 91.105­ Flight crewmembers at station.

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.

14 CFR § 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 throwover control wheel that

controls the elevator and ailerons, in place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certificate with appropriate

category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls the

elevator and ailerons, in place of fixed, dual controls may be used for flight instruction to conduct a flight

review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument

proficiency check required by §61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during

the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the

requirements of §61.195(b), and has logged at least 25 hours of pilot­in­command 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.

3
(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 lighter­than­air aircraft, that aircraft is equipped with fully functioning dual

controls. However, simulated instrument flight may be conducted in a single­engine 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.

The purpose of this regulation is to ensure the safety of instructor and student during flight instruction

and tests. It is acknowledged that the UAS will be used for the purpose of flight instruction and tests,

however, as it does not operate with the same set of instruments and controls as a typical aircraft.

The UAS’s ground­based control station consists of a primary and secondary hand­held radio

transmitter, which can be operated simultaneously. However, if needed, the primary hand­held radio

transmitter can “override” any potential hazardous actions, which meets the intent of regulation 91.109

and provides an equivalent level of safety.

14 CFR § 91.119­Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following

altitudes:

(a)Anywhere.​ An altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface.

(b)Over congested areas.​ Over any congested area of a city, town, or settlement, or over any open air

assembly of persons, an altitude of 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.

The regulation states that over sparsely populated areas, the aircraft cannot be operated closer than 500

feet to any person, vessel, vehicle, or structure. SInce the UAS will be operating at a maximum of 400

feet AGL, we cannot comply with this requirement.

In order to provide an equivalent level of safety, certain precautions will be taken with the UAS when it is

operated over congested areas or over any open air assembly of persons. First, prior approval will be

sought. Second, any property owner affected will be briefed on the UAS’s expected route of flight and the

associated risks to persons and property on the ground. The UAS will be operated at a low altitude

4
allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the

surface. Due to the size of the UAS, the potential hazards to persons, vehicles and structures is minimal.

14 CFR § 91.121­Altimeter 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—

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 29.92′′ Hg.

This regulation does not apply to flying the UAS due to the restriction that requires adherence to a

maximum altitude of 400 feet AGL.

14 CFR § 91.151­(a)­Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming

normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

For all intensive purposes, the word “fuel” will be understood as battery capacity in the discussion of this

regulation, as the UAS operates on a battery. The intention of this regulation is to ensure an energy

reserve as a safety buffer for delays to landing. The maximum duration of flight from a single battery

charge is well under the regulation’s stipulation of 30 minutes during the day and 45 minutes at night.

Furthermore, the UAS is equipped with a battery life fail safe feature, which ensures the UAS returns to

the homepoint.

14 C.F.R.§§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a)and (b):Maintenance

Inspections Section 91.405(a)

requires that an aircraft operator or owner “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.” Section 91.407 similarly makes reference

to requirements in Part 43. Section 91.409(a)(2) requires an annual inspection for the issuance of an

airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain

maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots

and records of approval of the aircraft for return to service. A qualified person prior to each flight and at

predefined intervals as part of the maintenance schedule will perform pre­flight checks.

5
It is understood that responsibility of keeping the UAS maintained and updated falls under the Pilot of

Command (PIC) before conducting the flight. The owner is a responsible to keep all documental records

up to date. The intention of this regulation is to be specific on who is responsible

The Pre­flight checklist includes but may not be limited to:

1. Visual inspection of the airframe;

2. Visual inspection of propeller;

3. Verify GPS acquisition;

4. Plan and upload mission;

5. Video And payload check;

6. Controls Check;

7. Gyro/control surfaces check;

8. Throttle Check

9. Altimeter check;

10. Check Sensors;and

11. Verify Fail Safes are set correctly.

An equivalent level of safety will be achieved because the sUAS will carry no external payload, will

operate only in restricted predetermined areas, and is not a complex mechanical device. In addition, the

operator will ensure that the sUAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person

most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition and to

ensure an equivalent level of safety. Last, the Operator’s Manual will have instructions to develop and

document maintenance, overhaul, replacement, and inspection requirements in the absence of Flight

Ventures Ltd requirements,and procedures to document and maintain maintenance records for the sUAS.

The sUAS maintenance guidelines provide an equivalent level of safety to the maintenance requirements

in Part 91.

DJI INSPIRE 1 User manual

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Quick_Start_Guide_v1.4_en.pdf

6