Docket Operations, M-30; U.S. Department ofTransportation (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 onbehalfofNORTH SHORE AVIATION aerial drone photography and it

owner and operator, North Shore Aviation, Inc. PO Box 79128 Carolina, PR00984

Request for Exemption

NORTH SHORE AVIATION respectfullyrequests relieffrom 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 oftoday 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 onFARAIM newregulations 14CFR 119. We recognize this petition ofexemption as a privilege. Here atNorth 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

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# ____ Raul G. Dalmau, CEO North Shore Aviation Inc.



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# !g)-sos-nszJune 30, 2015

Docket Operations, M-30; U.S. Department ofTransportation (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

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rauldalmau@yahoo.com 787-505-3752

This petition for exemption is submitted onbehalfofNORTH 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 relieffrom 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 notnecessary under the statutory criteriaprovidedin Section 333 of Public Law 112- 95 [P.L. 112-95] in reference to 49 USC Section 44794 given the size, weight, speed, andlimitedoperating

area associatedwith theproposed UAS)

Section 45.23(b) prescribing that whenmarks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display onthat 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 notnecessary as theproposed UAS is not certificated under Section 21.191 andthispetition

is submitted in connection withproposedoperations as a Civil UAS)

Section 61.31(a) prescribing that a person who acts as a pilot in command ofany ofthe 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 bythe Administratorthrough aircraft type certificate procedures.

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NORTH SHORE AVIATION believes relief from this section is notnecessary under the statutory criteria providedin Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, and limitedoperatingarea associated with theproposed UAS)

Section 61.31(c) prescribing that unless a person holds a category, class, andtype rating (ifa class and type rating is required) that applies to the aircraft, that personmaynot act as pilot in command ofan aircraft that is carrying another person, or is operated for compensation orhire. Thatperson also may not act as pilot in command ofthat aircraft for compensation or hire. NORTH SHORE AVIATION believes relief from this section is notnecessary under the statutory criteriaprovided in Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, andlimitedoperatingarea associatedwith theproposed UAS)

Section 61.31(d) prescribing that to serve as the pilot in command ofan aircraft, a person must- (1) Hold the appropriate category, class, and type rating (ifa class or type rating is required) for the aircraft to be flown; or (2) Have received training required bythis part that is appropriate to the pilot certification level, aircraft category, class, andtype rating (ifa class ortype rating is required) for the aircraft to be flown, and have received an endorsement for solo flight inthat aircraft from an authorized instructor. NORTH SHORE AVIATION believes relief from this section is notnecessary under the statutory criteriaprovidedin Section333 of P. L. 112-95 in reference to 49 USC Section 44794 given the size, weight, speed, andlimitedoperatingarea associatedwith theproposed UAS or, alternatively, requests relief from this section byPilot in Command (PIC) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations 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 documentspublishedby the manufacturer andthe Proposed Conditions and Limitations set forth in thispetition)

Section 91.7(b) prescribing that the pilot in command ofa civil aircraft is responsible for determining whether that aircraft is incondition 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 (P1C) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

Section 91.9(b)(2) prohibits operation ofU.S.-registered civil aircraft unless there is available inthe aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof. NORTH SHORE AVIATION believes relief from this section is notnecessary as the FAA haspreviously determinedrelief is not required providedthe relevant materialspublishedby the manufacturer are kept in a location accessible to the PIC in compliance with the regulations)

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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 takeoffand landing distance information. NORTH SHORE AVIATION believes relief from this section is notnecessaryprovidedthe PIC complies with the Proposed Conditions andLimitations set forth in thispetition.

Section 91.109(a) prescribing, inpertinentpart, 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 notnecessaryprovidedthe PJC complies with the Proposed Conditions andLimitations set forth in thispetition or utilizes the DT7 & DR16RCSYSTEM dual control feature.

Section 91.119 prescribing that, except when necessary for takeoffor landing, no person may operate an aircraft belowthe following altitudes: (a) Anywhere. An altitude allowing, ifa powerunit fails, an emergency landing without undue hazard to persons or property onthe surface. NORTH SHORE AVIATION believes relief from this section is notnecessaryprovidedthe Pilot in Command (P!C) complies with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

(b) Over congested areas. Over any congested area ofa city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. NORTH SHORE AVIATION believes relief from this section is notnecessaryprovidedthe Pilot in Command (PIC) complies with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

(c) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparselypopulated areas. Inthose 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 byPilot in Command (P!C) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

Section 91.121 requires, inpertinentpart, eachperson operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." NORTH SHORE AVIATION believes relief from this section is notnecessary providedthe PIC complies with the Proposed Conditions andLimitations set forth in thispetition.

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 documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

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Section 91.203(a) prohibits, inpertinentpart, any person from operating a civil aircraft unless ithas within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation withinthe United States, the second copy ofthe Aircraft registration Application as provided for in§ 47.31(c). NORTH SHORE AVIATION believes relief from this section is notnecessary as the FAA haspreviously determined relief is not required providedthe relevant materialspublishedby the manufacturer andthe Proposed Conditions andLimitations are kept in a location accessible to the PIC in compliance with the regulations J

Section 91.203(b) prescribing, inpertinentpart, 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 notnecessary as the FAA haspreviously determined relief is notrequired providedthe relevant materialspublishedby the manufacturer andthe Proposed Conditions andLimitations are kept in a location accessible to the PIC in compliance with the regulations)

Section 91.405(a) requires, inpertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E ofthe same part and shall, betweenrequired inspections, except as provided inparagraph (c) ofthe same section, have discrepancies repaired as prescribed inpart 4 3 of the chapter. NORTH SHORE AVIATION requests relief from this section byPilot in Command (PIC) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

Section 91.407(a)(1) prohibits, inpertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless ithas been approved for return to service by a person authorized under§ 43.7 ofthe same chapter. NORTH SHORE AVIATION requests relief from this section byPilot in Command (PIC) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in this petition.

Section 91.409(a) prescribing that no person may operate an aircraft unless, withinthe preceding 12 calendar months, it has had- (1) an annual inspection in accordance withpart 4 3 ofthis chapter and has been approved for return to service by a person authorized by §43.7 ofthis 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 ofan airworthiness certificate in accordance withpart 21 ofthis chapter.

NORTH SHORE AVIATION requests relief from this section byPilot in Command (PIC) compliance with the applicable operational documentspublishedby the manufacturer andthe Proposed Conditions and Limitations set forth in thispetition.

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Section 91.417(a) and (b) prescribing, inpertinentpart, that- (a) Eachregistered owner or operator shall keep the following records for the periods specified in paragraph (b) ofthis section:

(1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100- hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft.

The records must include- (i) A description (or reference to data acceptable to the Administrator) ofthe workperformed; and (ii)The date ofcompletion ofthe workperformed; and (iii)The signature and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. (ii)The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed onthe 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 bythe inspectionprogram under which the aircraft and its appliances are maintained. (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required. (vi)Copies ofthe forms prescribed by§ 43.9(d) ofthis 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 inparagraph (a) (1) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the workis performed. (2) The records specified inparagraph (a) (2) ofthis section shall be retained and transferred withthe aircraft atthe time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under § 43.11 ofthis 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 documentspublishedby the manufacturer andthe Proposed Conditions andLimitations set forth in thispetition.

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Extent ofand Reasons for ReliefSought
NORTH SHORE AVIATION intends to operate two commercially available DJI Octocopter Model S1000, Quadcopter Model Inspire for the purpose ofproviding flight demonstration and aerial workunder the provisions of 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power line orpipeline patrol. NORTH SHORE AVIATION intends to offer commercial "aerial work" services utilizing UAS underthe exemptions to 14 CFR Section 135 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 inmanned aircraft, may be provided with increased safety and at significantly lower costin situations where the use ofunmanned UAS aircraft would supplement or replace the use ofmanned aircraft as a result ofsafety 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 ofcombustible fuel when compared to larger manned aircraft, minimize potential ecological affects or damage, andpromote economic growthbyproviding data information to individuals orcompanies requiring aerial survey or imaging data. Additionally, the growth ofthe UAS industry has precipitated a large influx of "recreational" UAS pilots without formal knowledge ortraining regarding the effects orpotential danger ofUAS flight with the National Airspace System (NAS).

While it is unclear what, ifany, 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 ofthe 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 ofcertificated flight instructors provides economic incentive to accomplishthe public goal ofintegration ofbothrecreational and commercial UAS into the NAS while promoting safety and maintenance public awareness ofcurrent regulations affecting UAS operation.

Exemptions Provide a Level ofSafety Equal to or Greater than the Existing Level under Current Regulations

The use ofUAS operated underthe requested exemptions as set forth above have the capacity to operate with less risk ofaccident or injury and the associated loss ofproperty or life while performing the same aerial work services offered inmanned 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 ofcertificated flight instructors to participate inthe public educational process utilizing UAS rather than manned aircraft. Manned aircraft are atrisk offuel spillage and fire inthe event ofan incident or accident. The DJI Octocopter Model S1000, Quadcopter Model Inspire carry no fuel, and therefore the risk offire 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 byplacing limits on altitude, requiring stand-offdistance from clouds, permitting daytime operations only, and requiring that the UAS be operated within VLOS and yield right ofway to all manned operations. Additionally, the Proposed Conditions and Limitations provide that the NORTH SHORE AVIATION will request a notice to airmen (NOTAM) priorto operations to alert other users ofthe NAS.

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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 withpre-coordinated automated flight

maneuvers. These safety features provide an equivalent orhigher level ofsafety compared to a manned aircraft holding airworthiness certificate (restricted or otherwise) performing a similar operation.

Federal Register Summary
NORTH SHORE AVIATION, chiefpilot Raul Dalmau, seeks exemption from the following regulations for the purpose ofconducting 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 orpipeline patrol:

Reliefconsidered (14 CFR) FAA Consideration or Action Requested

Part 21 Reliefnot necessary pursuant to prior exemption 45.23(b) Reliefnot necessary pursuant to prior exemption 61.31(a) Reliefnot necessary (Section 333 ofP.L. 112-95) 61.31(c) Reliefnot necessary (Section 333 ofP.L. 112-95) 61.31(d) Reliefnotnecessary (Section 333 ofP.L. 112-95) 91.7(a) Reliefgranted inprior exemption with conditions and limitations 91.7(b) Reliefnot necessary pursuant to prior exemption 91.9(b)(2) Reliefnot necessary pursuant to prior exemption 91.103(b) Reliefnot necessary pursuant to prior exemption 91.109(a) Reliefnot necessarypursuant to prior exemption 91.119 Relief [paragraph (c)] granted inprior exemption with conditions and limitations 91.121 Reliefgranted 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) Reliefnot necessary pursuant to prior exemption 91.405(a) Reliefgranted inprior exemption with conditions and limitations 91.407(a)(1) Reliefgranted inprior exemption with conditions and limitations 91.409(a)(1) and (2) Reliefgranted in prior exemption with conditions and limitations 91.417(a) and (b) Reliefgranted in prior exemption with conditions and limitations

Additional Information Offered in Support ofthis Petition for Exemption
NORTH SHORE AVIATION chiefpilot, Raul Dalmau, operated various manned aircraft, including fixedwing for flight instruction, commercial, and recreational including aerial work. Additionally, Raul Dalmau has operated UAS vehicles for the pasttwo years for non-commercial personal use in order gain flight experience and familiarity withthe operating characteristics and limitations ofthe UAS and its videography and photography systems. As a result it is believedthere 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 orproperty on the ground while offering the same or improved level ofaerial workproduct.

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Manned aircraft platforms such as airplanes and helicopters often subjectthe occupants as well as persons and property on the ground to higher levels ofrisk for accident or injury even while being operatedpursuant to all of the applicable federal aviation regulations.

1In the matter of Douglas Trudeau, Realtor, RegulatoryDocketNo. FAA-2014-0481 2 Relieffrom 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 giventhe size, weight, speed, and limited operating area associated with the proposed UAS.

The DJI Octocopter Model S1000, 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 "returnto horne" feature inthe event ofadverse inflight events. The UAS also incorporates automated "failsafe" features to initiate "return to horne" or "auto-land" commands inthe event of loss ofcontrol signal link or diminished battery output or capacity.

The manufacturer, DJIprovides comprehensive operational and safety manuals for bothUAS 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 ofan 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 inthe aircraft, however since there are no pilots orpassengers on board his aircraft and given its size, this regulation is inapplicable. NORTH SHORE AVIATION further indicates an equivalent level ofsafety will be achieved by maintaining a safety/flight manual withthe UAS ground station.

Proposed Conditions and Limitations
NORTH SHORE AVIATION (also hereafter referred to as the operator)proposes thefollowing Proposed Conditions andLimitations in theform of aproposed Grant of Exemption:

The following documents, including any updates or revision by the manufacturer, provided bythe 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 S1000, Quadcopter Model Inspire Safety Guidelines 3) DJI Octocopter Model S1000, Quadcopter Model Inspire Intelligent Flight Battery Safety Guidelines

Failure to comply with any ofthe conditions and limitations ofthis grant ofexemption will be grounds for the immediate suspension or rescission ofthis exemption.

1) Operations authorized bythis grant ofexemption are limited to the following aircraft described in the operating documents which are quad-rotor aircraft weighing less than 55 pounds: DJI Octocopter Model S1000, Quadcopter Model Inspire Unmanned Aircraft System (manufacturerpublished gross weight 1.54 pounds) ; and,

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Proposed operations ofany other aircraft will require a newpetition 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 ofno more than 500 feet above ground level (AGL), as indicated bythe procedures specified inthe operating documents. All altitudes reported to ATC must be in feet AGL. 4) The UAS must be operated within visual line ofsight (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 onthe 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 orpipeline patrol] must utilize a visual observer (VO). The UAS must be operated within the visual line ofsight (VLOS) ofthe 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 cannottransfer his or her designation for the duration ofthe flight. The PIC must ensure thatthe VO canperform the functions prescribed inthe 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 ofassuming positive control ofthe UAS inthe event ofloss ofcontrol by a trainee orperson acting under the provisions ofa studentpilot certificate issued bythe FAA. 7) The operating documents and this grant ofexemptionmust be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists betweenthe 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 orrevise its operating documents. Itis 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 ifhe petitions for extension or amendment to this grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon which the FAA granted this exemption, then the operator mustpetition for amendment to its grant ofexemption. The FAA's UAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates or revisions to the operating documents. 8) Prior to each flight, the PIC must inspectthe UAS to ensure it is in a condition for safe flight. Ifthe inspectionreveals a condition that affects the safe operation ofthe 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 beenperformed andthe UAS is found to be in a condition for safe flight. The Ground Control Station must be included inthe preflight inspection. All maintenance and alterations must be properly documented inthe aircraft records.

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9) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry inthe 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 ofthe 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 withthe operating documents. Maintenance, inspection, and alterations must be noted in the aircraft records, including total flight hours, description ofwork accomplished, and the signature ofthe authorized personreturning the UAS to service. 13) Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 14) The authorized personmust make an entry inthe aircraft record ofthe 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 currentthird-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 onhis or her pilot certificate. 16) Prior to operations conducted for the purpose offlight 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 orpipeline patrol, the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of25 hours oftotal 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 ofexemptionto accomplish the required flight time. However, saidtraining 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 offlight 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 orpipeline 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 ofthe UAS to be used in operations under the exemption; 5 hours make and model time may be included in the 10 hours ofmulti-rotor time prescribed above. The PIC must accomplish 3 take-offs and landings inthe preceding 90 days (for currency purposes). Training, proficiency, experience-building, and take-offand landing currency flights can be conducted under this grant of exemptionto accomplish the required flight time and 90 day currency. However, said training operations may onlybe conducted during dedicatedtraining 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.

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18) The operatormay not permitthe PIC to operate the UAS for the purpose offlight 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 orpipeline 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 underthis 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 ofan 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 havingjurisdiction over the affected airspace and establishes and maintains continuous verbal communication or contact with said authority (ATC) through radio ortelephonic methods for the duration offlight. 21) The UAS may not be operated less than 500 feet below orless than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 22) Ifthe UAS loses communications or loses its GPS signal, it must return to a pre-determined location within the planned operating area and land orbe 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 ofWaiver or Authorization (COA) priorto conducting any operations under this grant ofexemption. 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 CFRpart 47, and have identification (N-Number) markings in accordance with 14 CFRpart 45, Subpart C. Markings mustbe as large as practicable. 27) Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply withthe 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 ofthe UAS any time the UAS is operating. These documents mustbe made available to the Administrator or any law enforcement official upon request. 29) The UAS must remain clear and yield the right ofway to all manned aviation operations and activities at all times 30) The UAS may not be operated bythe 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=- INGFNUI1YV'RC>NES

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32) Flight operations mustbe conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are presentthat sufficiently protect nonparticipating persons from the UAS and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe 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 ofthe risk ofoperating closer to those objects and determined that it does not present

anundue hazard, and;

c. Operations nearer to the PIC, VO, operatortrainees or essential persons do not present an undue hazard to those persons per§ 91.119(a).

33) All operations shall be conducted overprivate 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 operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined bythe 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 onthe NTSB Web site: www.ntsb.gov. Unless otherwise specified inthis grant ofexemption, the UAS, the UAS PIC, and the UAS operations
must comply with all applicable parts of 14 CFRincluding, but not limitedto, parts 45, 47, 61, and 91.

Respectfully,

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# c**~2::::>\...__-** Raul Dalmau NORTH SHORE AVIATION Owner/Operator

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PO Box 79128 Carolina, PR 00984