Docket Operations, M-30; 

U.S. Department of Transportation (DOT), 

1200 New Jersey Avenue, SE, Room Wl2-140, 

West Building Ground Floor, Washington, DC 20590-0001 

Dear Sir: 

Ref: Petition for Exemption (Pursuant to 14 CFR Section 11.81) 

June 30, 2015 

... "•,, 

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-~ ·• 

This petition for exemption is submitted on behalf ofNORTH SHORE AVIATION aerial drone photography and it 

owner and operator, 

North Shore Aviation, Inc. 

PO Box 79128 

Carolina, PR 00984 

Request for Exemption 

NORTH SHORE AVIATION respectfully requests relief from the following regulations for the purpose of 

conducting commercial "aerial work" flight operations (as defined by 14 CFR Section 119.l(e)(l) Student 

instruction, Section 119.l(e)(4)(iii) Aerial photography or survey, and Section 119.l(e)(4)(vi) (Power line or 

pipeline patrol) utilizing DJI Octocopter Model SIOOO and Quadcopter Model Inspire. 

As of today we are a local aerial photography business, 135 Charter operator and Flight school for the last 12 years. 

Due to the technology evolution and costumers requests, we have to move to next level, Drone world. We also have 

notice a constant request among pilots to provide Drone training, base on FAR AIM new regulations 14CFR 119. 

We recognize this petition of exemption as a privilege. Here at North Shore Aviation like to contribute and educate 

future Drone pilots the right way, do aerial photography legally, and evolve correctly on this new drone world 

ahead. 

Respectfully, like you to consider our exemption. 

Sincerely, 

J c ~-...___ ___ _ Raul G. Dalmau, CEO 

North Shore Aviation Inc. 

P.O. ~ 111zg, ~~ P~ R~, 001g4-112g 

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June 30, 2015 

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 

Dear Sir: 

Ref: Petition for Exemption (Pursuant to 14 CFR Section 11.81) 

-=2=- -=iFINGENUI7Y 'DRONES ~ 

rauldalmau@yahoo.com 

787-505-3752 

This petition for exemption is submitted on behalf of NORTH SHORE AVIATION aerial drone photography 

and it owner and operator, 

North Shore Aviation, Inc. 

PO Box 79128 

Carolina, PR 00984 

Request for Exemption 

NORTH SHORE AVIATION respectfully requests relief from the following regulations for the purpose of 

conducting commercial "aerial work" flight operations (as defined by 14 CFR Section 119.1(e)(l) Student 

instruction, Section 119.l(e)(4)(iii) Aerial photography or survey, and Section 119.1(e)(4)(vi) Power line or 

pipeline patrol) utilizing DJI Octocopter Model S1000 and Quadcopter Model Inspire. 

Part 21 prescribing the procedural requirements for issuing and changing design approvals, productions 

approvals, airworthiness certificates, and airworthiness approvals. NORTH SHORE AVIATION believes 

relief from this section is not necessary under the statutory criteria provided in Section 333 of Public Law 112-

95 [P.L. 112-95] in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating 

area associated with the proposed UAS) 

Section 45.23(b) prescribing that when marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport 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," 

"light-sport," "experimental," or "provisional," as applicable. NORTH SHORE AVIATION believes relief 

from this section is not necessary as the proposed UAS is not certificated under Section 21.191 and this petition 

is submitted in connection with proposed operations as a Civil UAS) 

Section 61.31(a) prescribing that a person who acts as a pilot in command of any of the following aircraft must 

hold a type rating for that aircraft for other aircraft specified by the Administrator through aircraft type 

certificate procedures: 

(1) Large aircraft (except lighter-than-air). 

(2)Turbojet-powered airplanes. 

(3)0ther aircraft specified by the Administrator through aircraft type certificate procedures. 

POBox 79128 

Carolina, PR 00984 
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NORTH SHORE AVIATION believes relief from this section is not necessary under the statutory criteria 

provided in Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and 

limited operating area associated with the proposed UAS) 

Section 61.31 (c) prescribing that unless a person holds a category, class, and type rating (if a class and type 

rating is required) that applies to the aircraft, that person may not act as pilot in command of an aircraft that is 

carrying another person, or is operated for compensation or hire. That person also may not act as pilot in 

command of that aircraft for compensation or hire. NORTH SHORE AVIATION believes relief from this 

section is not necessary under the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 

USC Section 44794 given the size, weight, speed, and limited operating area associated with the proposed UAS) 

Section 61.31 (d) prescribing that to serve as the pilot in command of an aircraft, a person must-

(1) Hold the appropriate category, class, and type rating (if a class or type rating is required) for 

the aircraft to be flown; or 

(2) Have received training required by this part that is appropriate to the pilot certification level, 

aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be 

flown, and have received an endorsement for solo flight in that aircraft from an authorized 

instructor. NORTH SHORE AVIATION believes relief from this section is not necessary under the 

statutory criteria provided in Section333 of P. L. 112-95 in reference to 49 USC Section 44794 given the 

size, weight, speed, and limited operating area associated with the proposed UAS or, alternatively, 

requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this 

petition) 

Section 91.7(a) prescribing that no person may operate a civil aircraft unless it is in an airworthy condition. 

NORTH SHORE AVIATION requests relief from this section by Pilot in Command (PIC) compliance with 

the applicable operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

Section 91. 7(b) prescribing that the pilot in command of a civil aircraft is responsible for determining whether 

that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when un-airworthy 

mechanical, electrical, or structural conditions occur. NORTH SHORE AVIATION requests relieffrom this 

section by Pilot in Command (P 1 C) compliance with the applicable operational documents published by the 

manufacturer and the Proposed Conditions and Limitations set forth in this petition. 

Section 91.9(b)(2) prohibits operation ofU.S.-registered civil aircraft 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. NORTH SHORE AVIATION believes relief from this section is not necessary as 

the FAA has previously determined relief is not required provided the relevant materials published by the 

manufacturer are kept in a location accessible to the PIC in compliance with the regulations) 

PO Box 79128 

Carolina, PR 00984 
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Section 91.103(b) prescribing that a pilot shall for any flight, become familiar with runway lengths at airports of 

intended use, and takeoff and landing distance information. NORTH SHORE AVIATION believes relief from 

this section is not necessary provided the PIC complies with the Proposed Conditions and Limitations set forth 

in this petition. 

Section 91.109(a) prescribing, in pertinent part, 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. 

NORTH SHORE AVIATION believes relief from this section is not necessary provided the P JC complies 

with the Proposed Conditions and Limitations set forth in this petition or utilizes the DT7 & DR16 RC SYSTEM 

dual control feature. 

Section 91.119 prescribing that, 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. NORTH SHORE AVIATION believes relief from this 

section is not necessary provided the Pilot in Command (P !C) complies with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition. 

(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. NORTH SHORE AVIATION believes relief from this 

section is not necessary provided the Pilot in Command (PIC) complies with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition. 

(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. NORTH SHORE AVIATION requests 

relief from this section by Pilot in Command (P !C) compliance with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set 

forth in this petition. 

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." NORTH SHORE AVIATION believes relief from this section is not necessary 

provided the PIC complies with the Proposed Conditions and Limitations set forth in this petition. 

Section 91.151(a) prescribing that 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 [emphasis added]. NORTH SHORE AVIATION requests relief from this section by Pilot in 

Command (P !C) compliance with the applicable operational documents published by the manufacturer and the 

Proposed Conditions and Limitations set forth in this petition. 

PO Box 79128 

Carolina, PR 00984 
INGENUITY V'RVNES ~ 

Continue. 

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration 

certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft 

registration Application as provided for in§ 47.31(c). NORTH SHORE AVIATION believes relief from this 

section is not necessary as the FAA has previously determined relief is not required provided the relevant 

materials published by the manufacturer and the Proposed Conditions and Limitations are kept in a location 

accessible to the PIC in compliance with the regulations J 

Section 91.203(b) prescribing, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate 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. NORTH SHORE AVIATION believes relief 

from this section is not necessary as the FAA has previously determined relief is not required provided the 

relevant materials published by the manufacturer and the Proposed Conditions and Limitations are kept in a 

location accessible to the PIC in compliance with the regulations) 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as 

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 4 3 of 

the chapter. NORTH SHORE AVIATION requests relief from this section by Pilot in Command (PIC) 

compliance with the applicable operational documents published by the manufacturer and the Proposed 

Conditions and Limitations set forth in this petition. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved 

for return to service by a person authorized under§ 43.7 ofthe same chapter. NORTH SHORE AVIATION 

requests relief from this section by Pilot in Command (PIC) compliance with the applicable operational 

documents published by the manufacturer and the Proposed Conditions and Limitations set forth in this 

petition. 

Section 91.409(a) prescribing that no person may operate an aircraft unless, within the preceding 12 

calendar months, it has had- ( 1) an annual inspection in accordance with part 4 3 of this chapter and 

has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) that no 

person may operate an aircraft unless, within the preceding 12 calendar months, it has had an 

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

NORTH SHORE AVIATION requests relief from this section by Pilot in Command (PIC) compliance with 

the applicable operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition. 

PO Box 79128 

Carolina, PR 00984 
~ "'9iPINGENUI1Y V'RONES ~ 

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Section 91.417(a) and (b) prescribing, in pertinent part, that-

( a) 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 ofthe 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 ofthe 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. 

(3) A list of defects furnished to a registered owner or operator under § 4 3.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service. 

NORTH SHORE AVIATION requests relief from this section by Pilot in Command (PIC) compliance 

with the applicable operational documents published by the manufacturer and the Proposed Conditions 

and Limitations set forth in this petition. 

PO Box 79128 

Carolina, PR 00984 
INGENUITY V'Rc:JNES ~ 

Extent of and Reasons for Relief Sought 

NORTH SHORE AVIATION intends to operate two commercially available DJI Octocopter Model S1000, 

Quadcopter Model Inspire for the purpose of providing flight demonstration and aerial work under the 

provisions of 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power 

line or pipeline patrol. NORTH SHORE AVIATION intends to offer commercial "aerial work" services 

utilizing U AS under the exemptions to 14 CFR Section 13 5 granted under 14 CFR 119.1 (e) as set forth above. 

Additionally, NORTH SHORE AVIATION pilot, Raul Dalmau, holds a Private Pilot Rating Certificate No. 

3032258 (Airplane Single Land) 

Public Interest and Benefit 

The above "aerial work" services, normally provided in manned aircraft, may be provided with increased safety 

and at significantly lower cost in situations where the use of unmanned UAS aircraft would supplement or 

replace the use of manned aircraft as a result of safety or economic considerations in certain applications where 

extended operational range and limited time aloft are not a factor. The proposed UAS operations will pose no 

threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft, 

minimize potential ecological affects or damage, and promote economic growth by providing data information 

to individuals or companies requiring aerial survey or imaging data. Additionally, the growth of the UAS 

industry has precipitated a large influx of "recreational" UAS pilots without formal knowledge or training 

regarding the effects or potential danger ofUAS flight with the National Airspace System (NAS). 

While it is unclear what, if any, pilot certification requirements will ultimately apply to UAS pilots operating 

for commercial purposes under the final rulemaking process, there is a present need for training and 

dissemination of the applicable federal aviation regulations and flight characteristics ofUAS to the general 

public; specifically current and potential UAS operators. UAS flight and ground demonstration and instruction 

for compensation utilizing the current system of certificated flight instructors provides economic incentive to 

accomplish the public goal of integration of both recreational and commercial UAS into the NAS while 

promoting safety and maintenance public awareness of current regulations affecting UAS operation. 

Exemptions Provide a Level of Safety Equal to or Greater than the Existing Level under Current 

Regulations 

The use ofUAS operated under the requested exemptions as set forth above have the capacity to operate with 

less risk of accident or injury and the associated loss of property or life while performing the same aerial work 

services offered in manned aircraft in certain situations where extended operational range and limited time aloft 

are not a factor. Likewise, UAS flight and ground demonstration and instruction for compensation promote and 

encourage the existing system of certificated flight instructors to participate in the public educational process 

utilizing UAS rather than manned aircraft. Manned aircraft are at risk of fuel spillage and fire in the event of an 

incident or accident. The DJI Octocopter Model S 1000, Quadcopter Model Inspire carry no fuel, and therefore 

the risk of fire following an incident or accident due to fuel spillage is eliminated. 

This petition for exemption does not propose an electronic means to monitor and communicate with other 

aircraft, such as transponders or sense and avoid technology. Rather the risk is mitigated by placing limits on 

altitude, requiring stand-off distance from clouds, permitting daytime operations only, and requiring that the 

UAS be operated within VLOS and yield right of way to all manned operations. Additionally, the Proposed 

Conditions and Limitations provide that the NORTH SHORE AVIATION will request a notice to airmen 

(NOT AM) prior to operations to alert other users of the NAS. 

PO Box 79128 

Carolina, PR 00984 
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NORTH SHORE AVIATION'S UAS has the capability -to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability augmentation and control. The 

UAS is also able to respond to a loss ofGPS or a lost-link event with pre-coordinated automated flight 

maneuvers. These safety features provide an equivalent or higher level of safety compared to a manned aircraft 

holding airworthiness certificate (restricted or otherwise) performing a similar operation. 

Federal Register Summary 

NORTH SHORE AVIATION, chief pilot Raul Dalmau, seeks exemption from the following 

regulations for the purpose of conducting flight instruction and commercial "aerial work" flight operations 

utilizing Unmanned Aerial Systems ("UAS") as set forth under the provisions of 14 CFR Section 119.1 (e)(1) 

Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) 

Powerline or pipeline patrol: 

Relief considered (14 CFR) FAA Consideration or Action Requested 

Part 21 Relief not necessary pursuant to prior exemption 

45.23(b) Relief not necessary pursuant to prior exemption 

61.31(a) Relief not necessary (Section 333 ofP.L. 112-95) 

61.31(c) Relief not necessary (Section 333 ofP.L. 112-95) 

61.31(d) Reliefnotnecessary (Section 333 ofP.L. 112-95) 

91.7(a) Relief granted in prior exemption with conditions and limitations 

91.7(b) Relief not necessary pursuant to prior exemption 

91.9(b)(2) Relief not necessary pursuant to prior exemption 

91.103(b) Relief not necessary pursuant to prior exemption 

91.109(a) Relief not necessary pursuant to prior exemption 

91.119 Relief [paragraph (c)] granted in prior exemption with conditions and limitations 

91.121 Relief granted in prior exemption with conditions and limitations 

91.151 (a) Relief [paragraph 91.151 (a)( 1 ), day] granted in prior exemption with conditions and 

limitations 1 

91.203(a) and (b) Relief not necessary pursuant to prior exemption 

91.405(a) Relief granted in prior exemption with conditions and limitations 

91.407 (a)( 1) Relief granted in prior exemption with conditions and limitations 

91.409(a)(1) and (2) Relief granted in prior exemption with conditions and limitations 

91.417(a) and (b) Relief granted in prior exemption with conditions and limitations 

Additional Information Offered in Support of this Petition for Exemption 

NORTH SHORE AVIATION chief pilot, Raul Dalmau, operated various manned aircraft, including fixedwing for flight instruction, commercial, and recreational including aerial work. Additionally, Raul Dalmau has 

operated U AS vehicles for the past two years for non-commercial personal use in order gain flight experience 

and familiarity with the operating characteristics and limitations of the UAS and its videography and 

photography systems. As a result it is believed there are certain aerial work situations, where the range and time 

aloft limitations ofUAS are not a factor, whereby aerial work may be conducted with greater safety and less 

risk to persons or property on the ground while offering the same or improved level of aerial work product. 

PO Box 79128 

Carolina, PR 00984 
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Manned aircraft platforms such as airplanes and helicopters often subject the occupants as well as persons and 

property on the ground to higher levels of risk for accident or injury even while being operated pursuant to all of 

the applicable federal aviation regulations. 

1 In the matter of Douglas Trudeau, Realtor, Regulatory Docket No. FAA-2014-0481 

2 Relief from this section is not necessary under the statutory criteria provided in Section 333 of P.L. 

112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area 

associated with the proposed UAS. 

The DJI Octocopter Model S 1000, Quadcopter Model Inspire UAS are both commercially produced and widely 

available aerial videography and photography platforms utilizing advanced GPS enabled stability augmentation 

and control systems including "failsafe" features allowing the operator to manually take control ofthe aircraft or 

initiate an automated "return to horne" feature in the event of adverse inflight events. The UAS also 

incorporates automated "failsafe" features to initiate "return to horne" or "auto-land" commands in the event of 

loss of control signal link or diminished battery output or capacity. 

The manufacturer, DJI provides comprehensive operational and safety manuals for both UAS and all flights will 

be conducted in accordance with the requirements and guidance issued in these manuals. NORTH SHORE 

AVIATION states that§ 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

NORTH SHORE AVIATION asserts that since there is currently no certificate applicable to his operation, 

this regulation is inapplicable. 

NORTH SHORE AVIATION states that§ 91.9(b)(2) requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board his aircraft and given its size, this regulation is 

inapplicable. NORTH SHORE AVIATION further indicates an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station. 

Proposed Conditions and Limitations 

NORTH SHORE AVIATION (also hereafter referred to as the operator) proposes the following Proposed 

Conditions and Limitations in the form of a proposed Grant of Exemption: 

The following documents, including any updates or revision by the manufacturer, provided by the operator in its 

petition are incorporated by reference, and are hereinafter referred to as operating documents: 

1) DJI Octocopter Model S1000, Quadcopter Model Inspire User Manual 

2) DJI Octocopter Model S 1000, Quadcopter Model Inspire Safety Guidelines 

3) DJI Octocopter Model S1000, Quadcopter Model Inspire Intelligent Flight Battery Safety Guidelines 

Failure to comply with any of the conditions and limitations ofthis 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 following aircraft described in 

the operating documents which are quad-rotor aircraft weighing less than 55 pounds: DJI Octocopter Model 

S 1000, Quadcopter Model Inspire Unmanned Aircraft System (manufacturer published gross weight 1.54 

pounds) ; and, 

PO Box 79128 

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Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 

2) The UAS may not be flown at an indicated airspeed exceeding 15 knots. 

3) The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents. All altitudes reported to ATC 

must be in feet AGL. 

4) The UAS must be operated within visual line of sight (VLOS) ofthe Pilot in Command (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. 

5) All operations commercial "aerial work" flight operations [as defined by 14 CFR Section 119.1 (e)(l) 

Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 

(e)(4)(vi) Power line or pipeline patrol] must utilize a visual observer (VO). The UAS must be operated 

within the visual line of sight (VLOS) of the 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. 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 functions prescribed in the operating documents. 

6) All flight instruction operations must be conducted such that the flight instructor has immediate 

access to the master ground control station (either through physical proximity or electronic access 

through a slave ground controller) for the purpose of assuming positive control of the UAS in the 

event of loss of control by a trainee or person acting under the provisions of a student pilot 

certificate issued by the FAA. 

7) The operating documents and this grant of exemption 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 tal( e 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 operator's responsibility to track 

such revisions and present updated and revised documents to the Administrator upon request. The 

operator must also present updated and revised documents if he 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 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) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the 

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

Maximum published velocity for DJI Octocopter Model S1000 and Quadcopter Model Inspire (15 

knots), operating until the necessary maintenance has been performed and the UAS is found to be in a condition 

for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

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9) Any UAS 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. The PIC who 

conducts the functional test flight must make an entry in the aircraft records. 

10) The pre-flight inspection section in the operating documents must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

11) The operator must follow the UAS manufacturer's aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

12) The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations must be noted 

in the aircraft records, including total flight hours, description of work accomplished, and the 

signature of the authorized person returning the UAS to service. 

13) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

14) The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

15) UAS operations must be conducted by a PIC possessing at least a private pilot certificate and at least 

a current third-class medical certificate. 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. 

16) Prior to operations conducted for the purpose of flight instruction or aerial work as defined by 14 

CFR Section 119.1 (e)(l) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, 

and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol, the PIC must have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior 

documented flight experience that was obtained in compliance with applicable regulations may 

satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted 

under this grant of exemption to accomplish the required flight time. However, said training 

operations may only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights the PIC is required to operate the UAS with appropriate distances in 

accordance with 14 CFR 91.119. 

1 7) Prior to operations conducted for the purpose of flight instruction or aerial work as defined by 14 

CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) Aerial photography or survey, 

and Section 119.1 (e)(4)(vi) Power line or pipeline patrol, the PIC must have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), a minimum of5 hours as UAS pilot operating the make 

and model of the UAS to be used in operations under the exemption; 5 hours make and model time 

may be included in the 10 hours of multi-rotor time prescribed above. The PIC must accomplish 3 

take-offs and landings in the preceding 90 days (for currency purposes). Training, proficiency, 

experience-building, and take-off and landing currency flights can be conducted under this grant of 

exemption to accomplish the required flight time and 90 day currency. However, said training 

operations may only be conducted during dedicated training sessions. During training, proficiency, 

and experience-building flights the PIC is required to operate the UAS with appropriate distances in 

accordance with 14 CFR 91.119. 

PO Box 79128 

Carolina, PR 00984 
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INGENUI1Y V'R<9NES ~ 

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18) The operator may not permit the PIC to operate the UAS for the purpose of flight instruction or 

aerial work as defined by 14 CFR Section 119.1 (e)(1) Student instruction, Section 119.1 (e)(4)(iii) 

Aerial photography or survey, and Section 119.1 (e)( 4)(vi) Power line or pipeline patrol, unless the 

PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), 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 people, 

vessels, vehicles and structures. 

19) 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). 

20) The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless, prior to such operation, the PIC coordinates and 

obtains authorization and airspace clearance from any National Airspace System (NAS) controlling 

authority having jurisdiction over the affected airspace and establishes and maintains continuous 

verbal communication or contact with said authority (ATC) through radio or telephonic methods for 

the duration of flight. 

21) The UAS 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. 

22) If the UAS loses communications or loses its GPS signal, it must return to a pre-determined location 

within the planned operating area and land or be recovered in accordance with the operating documents. 

23) The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance 

with the operating documents. 

24) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UAS with 30% battery power remaining. 

25) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. 

26) 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. 

27) Before conducting operations, the radio frequency spectrum used for operation and control of the 

UAS must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

28) The 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 UAS is operating. These documents must be made available 

to the Administrator or any law enforcement official upon request. 

29) The UAS must remain clear and yield the right of way to all manned aviation operations and 

activities at all times 

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

31) The UAS may not be operated over congested or densely populated areas. 

PO Box 79128 

Carolina, PR 00984 
"9lP- <=il=-

INGFNUI1Y V'RC>NES ~ 

Continue. 

32) 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 

UAS 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 UAS, flight operations must cease immediately 

and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission 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, and; 

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per§ 91.119(a). 

33) All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

34) 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. 

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. 

Respectfully, 

~I c ~2::::>\...__-

Raul Dalmau 

NORTH SHORE AVIATION 

Owner/Operator 

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PO Box 79128 

Carolina, PR 00984