May 5th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations

Dear Sir or Madam:

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

and 14 C.F.R. Part 11, Utah Drone Services LLC (“Utah Drone Services”), an operator of the DJI

Inspire 1, DJI Phantom 3, 3D Robotics Solo Unmanned Aircraft System (“UAS”) and seeks

exemption from the Federal Aviation Regulations (“FARs”) as described below.

The exemption request will permit Utah Drone Services to operate UASs commercially for the

purpose of filming and photographing property, people, and events. Utah Drone Services will

provide a service that is beneficial to an industry that is already using, and seeking to use, UASs

for these purposes with a legal and safe option while providing relevant experience and

information to the FAA and the UAS community. This will benefit the public with the controlled

operation of UASs by Utah Drone Services and increased integration into the National Airspace

System (“NAS”).

All operations by Utah Drone Services will strictly adhere to safety, applicable FARs, Operator’s

Handbook, applicable Airworthiness Directives, and all other guidelines from the FAA. Utah

Drone Services will, at all times, conduct operations in a manner as to maintain the same level of

safety as current manned aircraft operations.

Utah Drone Services will operate exclusively in controlled conditions, within visual line of sight

(“VLOS”), at low altitudes of 400 feet above ground level (“AGL”), or no higher than 200 feet

above the highest obstacle (“AHO”) with prior Flight Safety District Office (“FSDO”) approval. Any

UAS in operation by Utah Drone Services will not exceed 55 lbs. weight.

At all times Utah Drone Services will have a Chief Pilot responsible to properly train, maintain

safe operations, ensure currency requirements are met, and consistently assure an open line of

communication with the FAA. The Chief Pilot will, at a minimum, will hold a sport pilot certificate

and a valid U.S. driver’s license.

Utah Drone Services is poised to be the model of a safe and responsible approach to integrate the

UASs into the NAS through the experience of a professional aviator and UAS enthusiast. As a pilot

owned business, Utah Drone Services will maintain the highest of standards in all UASs

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operations. A thorough understanding of the importance of safety guidelines in the NAS, and a

desire to promote the appropriate integration of UASs for the furtherance of aviation as a whole

is the foundation upon which this business will operate.

The name and address of the applicant are:

Utah Drone Services LLC

Attn: Ryan Badger

Ph: 801-210-0220

Address: 1120 E 2700 S #J78

Salt Lake City, UT 84106

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.105

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).

Appendix A discusses each rule listed above and explains why exemptions pursuant to the

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in

the public interest.

The Applicable Legal Standard Under Section 333

Utah Drone Services submits that grant of this exemption application advances the Congressional

mandate in Section 333 of the Reform Act to accelerate the introduction of UASs into the NAS if it

can be accomplished safely. This law directs the Secretary of Transportation to consider whether

certain UASs may operate safely in the NAS before completion of the rulemaking required under

Section 332 of the Reform Act. In making this determination, the Secretary is required to

determine which types of UASs do not create a hazard to users of the NAS, the public, or pose a

threat to national security in light of the following:

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

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● 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)(1). If the Secretary 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) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

● The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if

the Administrator finds the exemption is in the public interest.

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended;

the strong equivalent level of safety surrounding the proposed operations; and the significant

public benefit, including enhanced safety and cost savings associated with use of UASs for aerial

videography/photography, the reduction or elimination of unregulated operators, and the safe

integration of UASs. Accordingly, the applicant respectfully requests that the FAA grant the

requested exemption without delay.

_____________________________

1 Applicant submits that this provision places a duty on the Administrator to not only process

applicants for exemptions under Section 333, but for the Administrator, if he deems the

conditions proposed herein require modification in order to allow approval, to supply conditions

for the safe operation of the UAS. Utah Drone Services respectfully requests the opportunity to

consult with FAA staff in order to address any issues or concerns that this proposal may raise

that they believe may require modification.

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Airworthiness

Grant of the exemption to Utah Drone Services will be subject to the following mandatory

airworthiness conditions:

● The UAS will never exceed a gross takeoff weight (GTOW) of 55 lbs., or in excess of the

Operator Handbook/Manufacturer recommendations, whichever is more restrictive.

● The Manufacturer checklist and Utah Drone Services preflight checklist will be followed

prior to each flight.

● The aircraft registration number will be displayed on the aircraft in accordance with

current regulations.

● The POH, registration, copy of exemption, checklist, and copy of maintenance records will

be mandatory documents for operation and must be located with or in the base station

and accessible to the PIC at all times.

● Any FAA or manufacturer required placards are placed and clearly visible on the base

station or controlling device.

● All equipment installed on the UAS will be operational for flight.

● PIC will be the determining authority on the airworthiness of the UAS prior, during, and

after each flight, and will cease operations upon deeming the UAS not airworthy until

proper maintenance or action has been taken.

● In adherence to 14 C.F.R. §43.9 each person who maintains, performs preventative

maintenance, rebuilds, or alters the UAS, airframe, motor, propeller, appliance, or

component part will make an entry in the maintenance record of that equipment

containing the following information:

○ Description of work performed.

○ Date of completion of work performed.

○ Name of the person performing the work.

○ Signature of the person performing the work.

● In addition to the information above, the following will be included on any maintenance

records for record keeping and reporting to the FAA upon request:

○ Aircraft total time.

○ Time in service of part by method of Time Since New (TSN) or Time Since

Overhaul (TSO).

○ Manufacturer, model, serial and/or part number when available.

● Any maintenance action that may affect flight characteristics or airworthiness will have a

maintenance operational check and test flight performed by a pilot holding at minimum a

private pilot certificate and an appropriate entry made in the UAS records.

Mandatory Operating Conditions

Grant of the exemption to Utah Drone Services will be subject to the following mandatory

operating conditions:

● Operations occurring within Class B airspace require coordination and approval from the

FAA Flight Standards District Office having jurisdiction, and upon request with Air Traffic

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Control one hour prior to operations commencing (14 CFR §91.215(d)(3)).

Communication commencing operations, during operations, and termination of

operations by use and constant monitoring of appropriate tower frequency by ground

radio.

● Operations within Class B 30NM Mode C Veil require at minimum 48 hour prior

notification of the FAA Flight Standards District Office having jurisdiction. Notification

and communication with Air Traffic Control upon commencing operations, during

operations, and termination of operations by use and constant monitoring of appropriate

tower frequency by ground radio (14 CFR §91.215(3)).

● Operations within Class C, or D airspace require notification at minimum 24 hour prior

notification of the FAA Flight Standards District Office having jurisdiction, and upon

request with Air Traffic Control one hour prior to operations commencing (14 CFR

§91.215(d)(3)). Communication commencing operations, during operations, and

termination of operations by use and constant monitoring of appropriate tower frequency

by ground radio.

● Operations within 2.5 NM radius of airport runway centerline within class E, or G airspace

require at a minimum 24 hour prior notification of the FAA Flight Standards District

Office having jurisdiction, at a minimum 24 hour prior notification of the Airport Manager

or Controlling Agency, notification and communication with any control tower, or on

CTAF frequency, upon commencing operations, during operations, and termination of

operations by use and constant monitoring of appropriate frequency by ground radio.

● Operations within class E or G airspace not within 2.5 NM of airport runway centerline

requires constant monitoring of applicable CTAF or 123.025 (helicopter air to air) and

reporting upon commencing operations, during operations, and termination of operations

by ground radio.

● No operations are to be conducted within 2.5 NM inline with runway centerline azimuth

and on the approach end of a runway that is actively in use.

● All operations are required to remain at, or below, 400 feet AGL unless prior approval is

received from the FAA Flight Standards District Office having jurisdiction, and no flight

exceeding 400 feet AGL may go above 200 feet above the highest obstacle, or outside

visible range, or beyond the capability of the UAS (whichever is lower in altitude).

● Operations are to be conducted over private or controlled access property.

● Permission from land owner/controller required before commencing any flight.

● Operations to occur under Visual Flight Rules during Visual Meteorological Conditions

(VMC).

● Aircraft to remain within Visual Line of Sight (VLOS).

● Operations to be conducted in a controlled environment with only the necessary persons

present, any person present, not employed by Utah Drone Services, will sign a waiver

acknowledging UAS operations, proper safety procedures, and a statement

acknowledging risks.

● Operations will be conducted with a visual observer (VO), in addition to the UAS pilot,

who will remain in VLOS with the UAS pilot, the UAS, and the area of operations at all

times. VO will assist in maintaining a controlled environment, spotting hazards to persons

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or property, monitoring and communicating on appropriate ATC, CTAF, or other

appropriate radio frequencies.

● UAS will not be operated below 25% battery capacity, or a battery power reserve of less

than 10% flight time, whichever is the greater of the two.

Operator Requirements

Utah Drone Services understands and upholds the stance that necessary precautions are required

to protect aircraft already operating in the NAS, and the safety and security of the flight crew

members, passengers as well as the public and property. For this reason Utah Drone Services will

require all pilots of the UAS to hold, at minimum, a sport pilot or recreational sport pilot

certificate and a valid U.S. driver’s license. Furthermore Utah Drone Services will use an

appropriately certified pilot for the type of operation being conducted as it would fall under 14

C.F.R. if it were a manned aircraft.

The PIC and the Visual Observer will, at all times, be aware that UASs currently cannot adhere to

the standard “see and avoid” requirements due to the size of the UAS impacting the distance at

which it can be identified by pilots of manned aircraft. Utah Drone Services maintains a zero

tolerance policy for any pilot that fails to give complete right of way, and wide berth to any

aircraft that comes within 1 statute mile horizontally or 2000 feet vertically of operations. At all

times the PIC and VO will monitor appropriate ATC, CTAF, or air to air frequency, announce

actions, and adhere to requests of any manned aircraft, airspace controller, FAA representative,

or law enforcement official so long as it can be performed safely and legally.

In the interest of safety, and the furtherance of aviation, Utah Drone Services requires it’s

operators to adhere to its “See and Hear” policy. This policy requires that any aircraft that can be

both observed and heard (excluding large turbine, turboprop, and other aircraft that are heard

and seen but are clearly 2000 feet above the highest permitted altitude of the UAS) by the PIC or

the VO will require UAS operations to cease until the aircraft acknowledges the operations of the

UAS verbally through radio communications.

The PIC will adhere to appropriate FARs as well as follow the included Utah Drone Services

Training Manual. The PIC will, while the exemption is in place, log all flights conducted for Utah

Drone Services, or any flight to meet the training requirements.

The visual observer will be trained according to the Utah Drone Services Training Manual. The

VO will be required to exhibit proficiency in operating and communicating using the radio. The

VO will not, at any time during operations conducted under this exemption, operate or control

any portion of the flight of the UAS unless they meet the PIC requirements of this exemption.

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Privacy

All flights will occur over private or controlled access property with the property owner’s or

controlling authorities prior consent and knowledge. Filming will be of people who have also

consented to being filmed or otherwise have agreed to be in the area where filming will take

place.

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In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A to

allow commercial operations of UASs conducting aerial flights as described.

Approval of the exemption allowing commercial operations of Utah Drone Services UASs will

increase safety by permitting an operator to conduct a service safely that is already occurring

without FAA knowledge, exemption, or adhering to prescribed safety guidelines. The exemption

will also encourage the education of UAS operators and the adoption of FAA guidelines and

approval for commercial UAS operations. It benefits the public through a higher level of safety of

UAS operations and a service that benefits the local public and business. It also benefits the public

through a smooth and well approached integration of UASs into the NAS, and continual

communication with the FAA and the information gained. Having a pilot owned business aids in

bridging the gap between the advancement of UAS technology and the current practices and

operations in the NAS and with the FAA. This assists the FAA with its mission of promoting

aviation while preserving safety of aviators, the public, and property.

The UASs operated by Utah Drone Services satisfies the criteria set forth in Section 333 of the

Reform Act–size, weight, speed, operating capabilities, operation within visual line of sight, and

national security–and showing an equivalent level of safety to manned aircraft flights through

appropriate pilot certification and safety focused standards of operation, providing more than

adequate justification for the grant of the requested exemptions allowing commercial operations.

Best Regards,

Ryan Badger

Owner and Chief Pilot

Utah Drone Services LLC

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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Due to the flight characteristics, such as the ability to hover, vertical takeoff and landing, and the

type of operations performed by the UASs operated by Utah Drone Services respectfully request

that where a regulation differentiates according to class that it be permitted to operate under

those regulations pertaining to helicopters.

Utah Drone Services requests an exemption from the following regulations as well as any

additional regulations that may technically apply to the operation of its UASs:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21,

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the

aircraft and the limited operating area associated with its utilization, it is unnecessary to

go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed

current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both

authorize the FAA to exempt aircraft 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 UAS involved.

In this case, an analysis of these criteria demonstrates that the Utah Drone Services UASs

operated without an airworthiness certificate, under the conditions proposed herein, will be at

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an

airworthiness certificate. The UASs will remain less than 55 lbs. GTOW. Will not carry a pilot or

passenger, will not carry flammable fuel, and will operate exclusively within an area pre

disclosed and in compliance with conditions set forth herein. Operations under this exemption

will be tightly controlled and monitored by both the operator, pursuant to the conditions set

forth above, and by local public safety requirements. The FAA will have advance notice of all

operations through the filings with the FSDO. Receipt of the prior permission of the land owner,

or controlling authority, the size of the aircraft, the lack of flammable fuel, and the fact that the

aircraft is carried to the location and not flown there all establish the equivalent level of safety.

The UASs construction with absorbent material provides at least an equivalent level of safety to

that of such operations being conducted with conventional aircraft that would be orders of

magnitude larger and would be carrying passengers, cargo, and flammable fuel.

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14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of the UASs without

an airworthiness certificate, no standard will exist for airworthiness of the UASs. Given the size of

the aircraft and the requirements that have presumably already been met in the approved

standard operating procedures (for instance, the Maintenance & Inspection Manual and Safety

Checklist), an equivalent level of safety will be achieved by ensuring compliance with the

operating manuals prior to each flight.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

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.

The equivalent level of safety will be achieved by keeping the flight manual at the ground control

point where the pilot flying the UAS will have immediate access to it. The FAA has issued to

others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(2)

This regulation provides that flight crewmembers must keep a safety belt fastened while at a

crewmember station. Utah Drone Services UASs are by definition not manned and therefore

maintain a equivalent level of safety without the use of safety belt since no danger is posed due to

no persons being aboard the aircraft.

14 C.F.R. § 91.121(a)

This regulation requires that aircraft be operated at altitude in reference to an altimeter set to

applicable barometric pressure. According to the Flight Manuals and information included with

this exemption request the UASs operated by Utah Drone Services uses GPS positioning, and the

T600 uses, in addition, a specialized sensor that limits the aircraft altitude to a predetermined

height set by the pilot during preflight inspections. This, in addition to all flights being conducted

by VLOS, assures altitude restrictions will be maintained by the pilot. Given the nature of the

flight being limited to an upper altitude limit, the limited area of operations, the See and Avoid

procedures set forth by Utah Drone Services, and in light of the UASs not being operated at VFR

or IFR cruising altitudes an equivalent level of safety will be achieved.

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14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that 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. UASs are a remotely piloted aircraft and by design, do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates with

the aircraft via radio communications. If instruction is accomplished through a training program,

as set forth in an equivalent level of safety will be assured. The FAA has approved exemptions for

flight training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of

safety will be achieved by the Utah Drone Services providing the training as outlined.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Due to the flight

characteristics of Utah Drone Services UASs (vertical takeoff and landing, and ability to hover) as

well as the nature of the type of flights conducted by UASs and the similarity to helicopters Utah

Drone Services requests to operate in accordance with section 91.119(d). The equivalent level of

safety will be achieved given the size, weight, speed, and material with which the UASs are built.

Furthermore; no flight will be taken without the permission of the land owner or those who

control the land. Because of the advance notice to the landowner, all affected individuals will be

notified of the flights. Compared to aerial photography or videography operations conducted

with aircraft or rotorcraft weighing far more than the UAS and carrying flammable fuel, any risk

associated with these operations will be far less than those currently allowed with conventional

aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of the UAS will

maintain separation between these small UAS operations and the operations of conventional

aircraft that must comply with Section 91.119, give right of way to all manned aircraft, and

adhere to Utah Drone Services See and Hear policy.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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 – (1) During the day, to

fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 20 minutes.”

Given the limitations on its proposed operations and the location of those proposed operations, a

longer time frame for flight in daylight VFR conditions is reasonable. Utah Drone Services

believes that an exemption from 14 CFR § 91.151(b) is safe and within the scope of a prior

exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without

compliance with 91.151(a)). Operating the small UAS, without 20 minutes of reserve fuel does

not engender the type of risks that Section 91.151(b) was meant to prevent given the size and

speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also

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enhances its safety. Additionally, limiting flights to a 20 minute reserve would greatly reduce

their utility. In the unlikely event that the UAS should run out of fuel, it would simply land. Given

its weight and construction material, the risks are less than contemplated by the current

regulation.

Utah Drone Services believes that an equivalent level of safety can be achieved by maintaining

25% battery power, or 10% of time (whichever is longer) would be more than adequate to return

the UAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) . . . no person may operate a civil aircraft unless it has . . . an appropriate and current

airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at

the cabin or cockpit entrance so that it is legible to passengers or crew.

Utah Drone Services UASs have no cockpit or cabin to place or carry certification. As such, the

exemption and any other certifying document from the FAA will be maintained with the ground

station, and placed in a manner as to be clearly visible to any government official or person

authorized in the controlled operations environment.

An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the UAS will have immediate access to them. The FAA has issued

numerous exemptions to this regulation. A representative sample of other exceptions includes

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): 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.

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Maintenance on Utah Drone Services aircraft will be accomplished by the owner/operator

pursuant to the manuals, provided by Utah Drone Services, and the manufacturer. An equivalent

level of safety will be achieved because the UAS is small in size, will operate only in restricted

predetermined areas and is not a complex mechanical device. As provided in the attached

Maintenance Manual and the Safety Checklist, which were reviewed as part of the application, the

operator of the UAS will ensure that it is in working order prior to initiating flight, perform

required maintenance, and keep a log of any maintenance that is performed. Moreover, the Utah

Drone Services Chief Pilot is familiar with the aircraft, has extensive experience with UAS

maintenance, and has thousands of hours of helicopter airframe and powerplant maintenance,

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent

level of safety.

The Utah Drone Services Maintenance Manual provides for a 30 day/100 hour and Annual

inspection of the airframe and components similar in scope to inspections on manned aircraft.

This will ensure an equivalent level of safety to the maintenance requirements in Part 91.

In addition, between such inspections, should a mechanical issue arise, the aircraft will either

return to its launch site or immediately land.

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APPENDIX B

SUMMARY OF Utah Drone Services SECTION 333 EXEMPTION REQUEST

Utah Drone Services hereby provides pursuant to Part 11 a summary of its exemption application

to allow commercial operation of its UASs in aerial photography/videography. An exemption is

requested from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.105

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).

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