UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION 

DOCKET MANAGEMENT SYSTEM 

1200 NEW JERSEY AVE., SE 

WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Sense Above, LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 

OF THE CODE OF FEDERAL REGULATIONS SECTIONS: Part 21 Subpart H, 45.23 

(b), 61.113(a) &(b), 91.7 (a), 91.103, 91.109 (a), 91.119 (c), 91.121, 91.151 (a), 91.405 

(a), 91.407 (a)(1), 91.409(a)(1) &(a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ v3 SMALL UNMANNED 

AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on 6/23/2015

Sense Above, LLC 

9225 County Road 513 

Alvarado, TX 76009 

(214) 308-8377 
Summary

Cover Letter

1/ the Company

2/ the Small Unmanned System (sUAS) Model

3/ Operations

4/Public Interest

5/ Extent of relief Sense Above is seeking

6/ List of Exemptions to regulations requested and equivalent level of safety

Annex 1 Manufacturer Manual

Annex 2 Manufacturer Checklists

Annex 3 Sense Above Checklists
US Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Dear Sir or Madam, 

Sense Above LLC, a Texas registered company, located 9225 County Road 513 

Alvarado 76009 Texas, intends to fly commercially an small unmanned system, and is 

petitioning for an exemption based on FAA Section 333 to operate a sUAS (hereunder 

described) in NAS.

We are aware of the safety risks involved by flying a sUAS in the NAS and this petition 

will present our sUAS model, characteristics, our standard operating procedures 

(SOP’s), and our certification requirements regarding pilots in command of the sUAS.

Sense Above wish to use commercially a sUAS in order to propose aerial photography 

and training for third parties. Sense Above is committed to help businesses and public 

agencies to access sUAS technology Sense Above contemplate to use its model sUAS 

hereunder described to perform flight demonstrations, aerial photography/videography 

for third parties, and instruction / training regarding flight and maintenance of the model 

of sUAS hereunder described.

The Reform Act gives the Secretary of Transportation the authority to determine if 

certain sUAS may operate safely in the national airspace system (NAS) before 

completion of the FAA’s plan and rulemaking to integrate sUAS into the NAS. The

Reform Act directs the Secretary to consider which types of sUAS as a result of their 

size, weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the national 

airspace or a threat to national security. If the secretary determines that such vehicles 

may operate safely in the NAS, the Secretary “shall establish requirements for the safe 

operation of such aircraft.” 

Committed to safety with each flight this exemption request would permit operation of 

unmanned (piloted by remote control) sUAS in tightly controlled and limited airspace 

and predetermined areas away from general public, airports, heliports and vehicular 

traffic. We contemplate to operate in the region of North Texas, more specifically in and 

around the DFW Metroplex, with respect of the required distant radius from International 

airport (5miles) and other airports without communication tower or heliports (3 miles 

radius), and other flight limitations listed hereunder (III Operations).
Safety protocols and controls are in place and described in this petition, those protocols 

aim to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. 

Further I Edouard Maurin, as the CEO of Sense Above, will conduct my operations in 

compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below I, Edouard Maurin respectfully request the grant of an 

exemption allowing Sense Above llc to operate remote controlled sUAS’s for perform 

aerial photography/videography and/or training/academic services for third parties 

providing that the sUAS fly in class G airspace at or below 400 feet above ground level 

(ALG), in line of sight of the PIC (Pilot in Command) and the VO (Visual Observer) 

during daylight hours and above controlled privately owned and operated property.

Sense Above’s sUAS weigh less than 3 pounds including payload. The sUAS will 

operate at no more than 50 knots and have the capability to hover, and move vertically 

and horizontally simultaneously. Operations would be conducted above privately owned 

and operated properties, with the consent of owner/operator. Sense Above operations 

will be performed by sUAS pilots holding at less Aeronautical knowledge airmen 

certification, sport pilot licenses, and in a manner consistent with 14 CFR 61.51(b), 25 

hours of total time as a sUAS rotorcraft pilot including at least 10 hours logged as a

sUAS Pilot the sUAS hereunder described (II the Small Unmanned Aircraft model).

The grant of this exemption request is in the public interest, does not create a hazard to 

users of the NAS or the public, or pose a threat to national security. In the following 

pages Sense Above addresses all areas of concern to include; 

Equivalent levels of safety 

Exemptions requested 

Sense Above appreciates your consideration in this matter. 

Very Respectfully 

Edouard Maurin

CEO

Sense Above, LLC 
I) the Company

Sense Above was founded in 2015 in an effort to provide the North Texas area with 

business opportunities utilizing sUAS technology. sUAS is a much safer alternative to 

aerial imaging than the traditional use of light aircraft in the past. 

Sense Above aims to help business owners or public agencies to benefit from sUAS 

aerial imagery capabilities, and we plan to help them have a full access to this 

technology as well. We are contemplating to perform aerial 

photography/videography for third parties and also train individuals to fly sUAS 

safely. Our goal is to accompany customers to learn and use sUAS and also to help 

them comply with existing and pending rules, should they buy a drone themselves.

Sense Above Owners (Edouard Maurin CEO - Kolton Krottinger COO) has over 40 

hours of flight with this sUAS each in a hobby capacity, since the acquisition of the 

sUAS in fall 2014. 

II) The Small Unmanned System (sUAS) Model

Section 333 of the “FAA Modernization and Reform Act of 2012” states: 

“... the Secretary of Transportation shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system... In making the determination under 

subsection (a). the Secretary shall determine, at a minimum – (1) which types of 

unmanned aircraft systems, if any, as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or 

pose a threat to national security...” 

Sense Above will utilize the DJI Phantom 2 Vision + to conduct its missions. 

This aircraft have fail safe features to include geo fencing and lost link return home 

capability. DJI is the manufacturer of multirotor sUAS aircraft weighing less than 25lbs 

and has developed technology that will enhance safe sUAS operations within the NAS.
Airframe : 1000g / Payload (Camera) : 242g
Remote Controller: 5,728 GHz - 5,85 GHz / Communication distance : FCC Compliance 

800m / FCC ID : SS3-201309581

Range Extender: 2412 MHz - 2462 MHz / Communication distance 500-700m / FCC 

ID : SS3-RE7001402

Complete specs and manual: INDEX 1

III Operations 

A. The sUAS shall not operate within 5 nautical miles of the geographic center of any 

airport as denoted on the current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted 

in accordance with a NOTAM as required by the operator’s COA. This letter of 

agreement with the airport management shall be made available to the Administrator 

upon request. 

B. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel. 

a. The sUAS shall only operate within a pre-defined Operations Area that shall be 

thoroughly inspected by the PIC for buildings, overhangs, obstacles, wires, poles, 

people, vehicles, sun angle, shadows, glare, reflective surfaces, clouds, smoke, and 

terrain among other potential hazards 

C. Flights shall be conducted under day visual meteorological conditions (VMC). 

a. In addition, the sUAS shall 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. 

b. sUAS operations shall not be conducted during night, as defined in 14 CFR §1.1. 

c. Flights shall not be conducted under special visual flight rules (SVFR). 

D. Flights shall be operated at an altitude below 400 feet AGL. 
E. The PIC shall be prohibited from operating the sUAS from any moving device or 

vehicle. 

F. The sUAS shall be operated within VLOS of the PIC. 

a. The PIC shall maintain VLOS without the aid of telescopes, cameras or other 

devices. 

b. The PIC will maintain VLOS with their own vision, which includes the use of 

eyeglasses or corrective lenses as specified on the PIC’s medical certificate. 

G. The sUAS shall remain clear and yield the right of way to manned operations and 

activities at all times including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc. 

H. Sense Above will require the PIC and VO to have successfully completed a 

qualification process which will include ground and flight training, as outlined in the 

Manufacturer’s Operating Manual. 

I. The PIC’s primary responsibility while in flight is the safe operation of the sUAS. 

Permitting 

A. All required permissions and permits shall be obtained from territorial, state, county, 

or city jurisdictions, including local law enforcement, or other appropriate governmental 

agencies. 

B. At least three days before a scheduled mission, Sense Above shall submit a written 

plan of activities to the local flight standards district office with jurisdiction over the area 

of the proposed flight. The 3-day notification may be waived with the concurrence of the 

FSDO. 

1. The plan of activities shall include at least the following: 

2. Dates and times for all requested flights 

3. Name and phone number of Sense Above sUAS Flight Operations 

4. Name, certificate, phone number of the PIC responsible 

5. Make, and model of sUAS to be used 

6. Statement from Sense Above that it will be operating on approved privately owned 

and operated property; the list of those who gave permission shall be made available on 

request. 

7. Description of the flight activity, including maps or diagrams of any area over which 

flights will be conducted, the relationship of that area to any nearby city, town, etc., and 

the altitudes essential to accomplish the operation 

8. Signature of exemption-holder or representative 
C. Documents required under 14 CFR §91.9 and §91.203 shall be readily available to 

the PIC any time the aircraft is in operation. These documents shall be made available 

to the Administrator or any law enforcement official upon request. 

D. Sense Above shall request a Notice to Airman (NOTAM) not more than 72 hours in 

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

E. Sense Above shall obtain the consent of all persons involved in the operation and 

ensure that only consenting persons be allowed within 500 feet of the Operations Area. 

AERA OF OPERATIONS:

flights limitations / international airports.
International airports local airports 

IV Public Interest

The demand for aerial photography and sUAS aerial photography and training with

affordable and convenient airframes like the DJI Phantom is important in the DFW area. 

The product is highly available and a lot of businesses are willing to use those 

technologies in a safe and lawful manner. Our will is to help those entities, public or 

private, to access and implement the technology in compliance with FAA and TSA 

regulations. 

To achieve this goal we plan to provide DFW metroplex area customers with aerial 

pictures or videos to address their immediate needs for real estate aerial photography, 

local survey, construction site aerial photography, or emergency operations support. We 

also want to advise customers on the safest and economic solutions available on the 

market to make this technology their own safe aerial technology, through consultancy 

and training services. 

The public’s interest is achieved by the safe integration of sUAS into the NAS, and the 

effort to improve customers training and safety awareness education.

sUAS can offer a low cost alternative to the traditional methods of aerial video and 

photography taken from fixed wing or rotor aircraft. This opens up financial boundaries 

for consumers to take video, pictures, and inspections of their property. 
sUAS offers reduced noise and a much smaller environmental impact than traditional 

aircraft. 

With its light weight and small footprint as well as lack of fuel (in a traditional sense), 

any incident or accident is much less likely to cause damage to persons or property. 

V) Extent of relief Sense Above is seeking 

I, Edouard Maurin submit this application on the behalf of my company, Sense Above, 

in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any 

currently applicable FARs operating to prevent Sense Above, to perform commercial 

sUAS aerial photography, academic/training and other flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration 

of civil unmanned aircraft systems into our national airspace system as it is in the 

public’s interest to do so. Sense Above’s sUAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of this sUAS is 

expressly contemplated by the Reform Act.

The Reform Act guides the Secretary in determining the types of sUAS's that may 

operate safely in the national airspace system. Considerations include: The weight, 

size, speed and overall capabilities of the sUAS; whether the sUAS will be operated 

near airports or heavily populated areas; and, whether the sUAS will be operated by line 

of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an exemption for 

Sense Above. Our sUAS utilizes four (4) counter-rotating propellers for balance, control 

and stability. Our sUAS is equipped with GPS and auto return safety technology. 

Weighing less than three (3) pounds including camera with gimbal.

Built in safety systems include a GPS mode that allows our sUAS to hover in place 

when radio controls are released. When pilot communication is lost the sUAS is 

designed to slowly descend to point of take-off. We will not operate sUAS near airports, 

Hospitals nor Police heliports, and will not operate near areas where general public is 

within five hundred (500) feet depending on location, conditions and weather. We are 

constantly on alert for any manned aircraft (Police/Medical helicopters, etc.) and 

prepared to land/abort immediately to the nearest and safest ground point should a 

manned aircraft approach our location or we suspect manned aircraft may approach 

near our location (see Annex 3 Sense Above Checklists and SOP’s/Preflight 

Briefing/Contingency Procedures). Our sUAS is capable of vertical and horizontal 

operations, and is flown only within line of sight of PIC, VO, and (if any) Remote sensor 

operator RSO).

Utilizing battery power rather than combustible fuels, flights generally last between eight 

(8) to sixteen (16) minutes, with an altitude under four hundred (400) feet. Sense Above 

utilizes a fresh fully charged battery with each flight as a safety precaution; full flight 

time limit for each battery is 25 minutes as tested. We do not operate the sUAS at or 
below manufacture recommend minimum charge levels for operation; preferring to 

remain well within a safe operating range to insure adequate communication between 

radio control and sUAS to eliminate potential for crash, loss of control or hazard. 

Reserve batteries are at hand with each exercise to insure replacement for sufficient 

safe level of operation.

We, Sense Above, are extremely cautious when operating sUAS and will not “create a 

hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). 

The size, weight and enclosed operational area of Sense Above’s sUAS permits 

exemption from Part 21 because sUAS meets (and exceeds) an equivalent level of 

safety pursuant to Section 333 of the Reform Act.

This exemption will not adversely affect safety. Sense Above only operates in 

reasonably safe environment that are strictly controlled, are away from power lines, 

elevated lights, airports and actively populated areas; we conduct extensive pre-flight 

inspections and protocol, during which safety carries primary importance; we have 

procedures (Annex 3 Sense Above’s Checklists/mission planning) in place to abort 

flights in the event of safety breaches or potential danger. Our safety protocols provide 

a level of safety equal to or exceeding existing rules. 

First, the potential loss of life is diminished because sUAS's carry no people on board 

and Sense Above only operates its sUAS in specific areas away from mass populations.

Second, there is no fuel on board a sUAS and thus the potential for fire or explosions is 

greatly diminished.

Third, the small size and extreme maneuverability of the sUAS allows us to remotely 

pilot away from and avoid hazards quickly and safely.

VI) List of Exemptions to regulations requested and 

equivalent level of safety

14 C.F.R. Part 21 Subpart H - Airworthiness Certificates 

14 C.F.R. Part 21 Subpart H States: The procedural requirements for the issuance of 

airworthiness certificates as required by 14 C. F. R. § 91 203(a)(l) 

Given the small size of the sUAS, the limited operating areas and meticulous 

procedures defined within the operations section of this document, an exemption from 

Part 21 Subpart H meets the requirements of an equivalent level of safety under Part II 

and section 333 of the “Reform Act” with consideration “of size, weight, speed, 

operation capability, and proximity to airports and populated areas of the particular 

UAS.”
No operations within one statute mile; Prior notice given to ATC tower/Airport Operator 

within five statute miles. 

• Minimum distance of 500 ft from persons, structures, roads and vehicles not being 

photographed. 

• Operations will be contained within one square mile and all dangers identified and 

mitigated before the flight plan is finalized into the GPS flight planning program. 

The size, weight and enclosed operational area of our sUAS permits exemption from 

Part 21 because our sUAS meets (and exceeds) an equivalent level of safety pursuant 

to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

sUAS's from the airworthiness certificate requirement in consideration of the weight, 

size, speed, maneuverability and proximity to areas such as airports and dense 

populations. 

14 C.F.R. 45.23(b) - Aircraft Marking and Identification Requirements 

A. 14 C.F.R. § 45.23(b): Markings of the Aircraft: states: 

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. 

Sense Above will ensure compliance with§ 45.29(t) to meet the intent of the regulation 

by placing the word "experimental" on the fuselage of the air vehicle(s). 

14 C.F.R. 61.113 (a)(b) - Private and Pilot Privilege and Limitations 

14 C.F.R. § 61.113: (a) Except as provided in paragraphs (b) through (g) of this section 

no person who holds a private pilot certificate may act as pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, 

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

for compensation or hire, act as pilot in command of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

1. Due to the fact that there are no standards for private or commercial sUAS 

operations, Sense Above requests to utilize at least certified airmen holding a ground 

instruction certificate and/or a sport pilot license with a third class medical certificate

and/or a valid Driver License in support of its own operations. 
2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), 

along with the ability to physically manipulate the controls of the sUAS are the critical 

aspects of the requested operation. Sense Above feels this can be accomplished by a 

private pilot that has specific training on the sUAS aircraft and operates in accordance 

with the Sense Above sUAS Operating Manual, Federal Aviation Regulations, local, 

state and federal laws. 

3. The risks associated with the operation of a sUAS are so diminished from the level of 

risk associated with commercial aviation operations contemplated by Part 61 when 

drafted, that allowing operations of the sUAS as requested with a sport pilot license 

holder as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) 

& (b). 

4. Equivalent or better safety levels will be achieved as there will be no human beings 

on board the sUAS aircraft. 

5. FAA has authority to waive pilot requirements for commercial operations under 49 

U.S.C §44701(f). 

14 C.F.R. 91.7(a)- Civil Aircraft Airworthiness 

14 C.F.R. 91.7(a) States: No person may operate a civil aircraft unless it is in an 

airworthy condition. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. In an effort to provide an equivalent level of safety, daily pre 

and post flight inspections will be accomplished in accordance with manufactures 

maintenance manuals(s) and guidance. 

14 C.F.R. 91.103- Preflight Action 

14C.F.R. 91.103 States: Each pilot in command shall, before beginning a flight, become 

familiar with all available information concerning that flight. This information must 

include- (paragraphs a, b, 1 and 2) 

A pre-flight mission brief must be attended by all crew members. This pre-flight mission 

brief will contain weather and all flight information including emergency and abort 

procedures 

14 C.F.R. 91.109(a)- Flight Instruction 

14 C.F.R. 91.109(a) States: 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. 

The majority of sUAS by design are developed with single operational control through 

the use of pre-determined GPS enabled waypoints programmed before or during flight 

in addition to the use of a single hand held transmitter or control station controlled by

the PIC. The design does not allow for dual controls during flight training and therefore 
the exemption is requested to qualify/certify operators as required by the manufacturer 

along with specific operations training and procedures identified in Annex 2 and 3. 

An equivalent level of safety will be ensured during training operations by utilizing the

same flight planning process for normal operations. In the flight planning document, all 

ground hazards will be identified and mitigation techniques will be enacted to ensure 

flights stay outside of 500 ft of any improved roads, vehicles, persons or structures. All 

training operations will be conducted within a confined space on private land in-which 

permission has been obtained by land owner prior to the execution of training. 

NOTE: The FAA has set precedent by previously issuing exemptions for§ 91.1 09(a): 

Exemption Nos. 5778K and 9862A. Also, see most recent exemption approvals for 

Astraeus Aerial, Aerial MOB. HeliVideo Productions, RC Pro Product ions. Snaproll 

Media and Pictorvision for further justification of approval

14 C.F.R. 91.119 (c) - Minimum Safe Altitudes 

14 C.F.R. 91.119 (c) States: Except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes: (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. 

1. The sUAS will be operated below 400 feet AGL. 

2. Sense Above shall obtain the consent of all persons involved in the operation and 

ensure that only consenting persons be allowed within 500 feet of the Operations Area. 

3. The sUAS will only operate within the lateral boundaries of approved privately owned 

and operated property. An Operations Area within those boundaries will be established 

for each flight. These areas will be free of unnecessary hazards or risks and nonparticipating personnel. 

4. Given the size, weight, speed, material, and operation of the sUAS, equivalent levels 

of safety will be achieved.

14 C. F. R. 91.121 - Altimeter Settings 

14 C. F. R. 91.121 - States: Each person operating an aircraft shall maintain the 

cruising altitude or flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating ... 

1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out 

indication instead, so an exemption may be needed. 

2. An equivalent level of safety will be achieved by the operator as the sUAS uses AGL 

height from its initialization/takeoff point. 

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

14 C.F.R. 91.151(a) States: No person may begin 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- (I) 

During the day to fly after that for at least 30 minutes: 

This regulation is written based on the capabilities of a traditional aircraft which have 

flight times of several hours or greater; therefore, with the majority of sUAS which have 

flight times of only an hour or less, this regulation would effectively deny the ability of 

the air vehicle to operate. 

Aircraft Fuel (Battery) Requirements 

DJI Phantom 2 - 25 minutes or 25% whichever occurs first. 

1. The DJI Phantom 2 have a second level of safety that is achieved through the use of 

an aircraft battery monitoring system. The aircraft system will alert the operator of low 

battery voltage and return the aircraft to its take-off location before battery capacity is 

depleted. 

2. Sense Above will not operate sUAS at night in accordance with 14 CFR 1.1 

3. An equivalent level of safety will be achieved because this sUAS is limited in size, 

operational purposes of the sUAS, and shall only fly above approved privately owned 

and operated property at or below 400 feet AGL, it does not bear the same risks 

associated with this section’s requirements. 

14 CFR 91.405 (a) – Maintenance Required 

14 CFR 91.405 (a) States: Each owner or operator of an aircraft – (a) 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. 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply. 

1. Maintenance will be accomplished by Sense Above pursuant to the manufacturer’s 

recommendations and sUAS Operating Manual and Inspection Program

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only. 

3. Sense Above will maintain daily of pre and post flight inspections and ensure the 

aircraft is in a flight ready status prior to conducting every mission. 

4. Sense Above shall only operate its sUAS with all systems functioning per 

manufactures specification in a discrepancy free condition. 

5. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by Federal Aviation Regulations. 

Sense Above and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition. This maintenance 
process allows for an equivalent level of safety to be achieved due to the limited size, 

scope and area of operations. 

14 CFR 91.407 (a) (1) – Operation after Maintenance, Preventive Maintenance, 

Rebuilding or Alteration 

14 CFR 91.407 (a) (1) States: (a) No person may operate any aircraft that has 

undergone maintenance, preventative maintenance, rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter. 

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply. 

1. Maintenance will be accomplished by Sense Above pursuant to the manufacturer’s 

recommendations and sUAS Operating Manual and Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only. 

3. Functional test flights will be performed by the PIC when required, the sUAS shall 

only be returned to service when this functional test flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the 

Operations Area

4. Sense Above shall only operate its sUAS with all systems functioning per 

manufactures specifications in a discrepancy free condition 

5. These records will be maintained at the principle base of operation for the life of the 

aircraft or as required by the Federal Aviation Regulations. 

Sense Above and the Aircraft Manufacturer (DJI) are the most familiar with the aircraft 

and best suited to maintain the aircraft in an airworthy condition. This maintenance 

process allows for an equivalent level of safety to be achieved due to the limited size, 

scope and area of operations. 

14 CFR 91.409 (a) (1) and (2) – Inspections 

14 CFR 91.409 (a) (1) and (2) States: (a) Except as provided in paragraph (c) of this 

section, no person may operate an aircraft unless, within the preceding 12 calendar 

months, it has had – (1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person authorized by §43.7 of this 
chapter ; or (2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore 

these sections will not apply. 

1. Maintenance will be accomplished by Sense Above pursuant to the manufacturer’s 

recommendations and sUAS Operating Manual and Inspection Program. 

2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully 

accomplished by trained personnel only. 

3. Functional test flights will be performed by the PIC when required, the sUAS shall 

only be returned to service when this functional test flight is successfully completed. If a 

mechanical issue arises the sUAS can land safely or be recovered within the 

Operations Area. 

4. Sense Above shall only operate its sUAS with all systems functioning per 

manufactures specifications in a discrepancy free condition 

5. These records will be maintained at the principle base of operation for the life of the 

aircraft or as required by the Federal Aviation Regulations

14 CFR 91.417(a) and (b) – Maintenance Records 

14 CFR 91.417(a) and (b) States: (a) Except for work performed in accordance with 

§91.411 and 91.413, each registered owner or operator shall keep the following records 

for the periods specified in paragraph (b) of this section: 1(i-iii), (2) (i-vi); (b) The owner 

or operator shall retain records for the periods prescribed: (paragraphs 1-3) 

1. Maintenance will be accomplished by Sense Above pursuant to the manufacturer’s 

recommendations. 

2. Maintenance, preventative maintenance, rebuilding, and alteration maintenance 

record keeping will be performed by trained personnel and entered into the respective 

aircraft maintenance log at completion of each event. 

3. These records will be maintained at the principle base for operation for the life of the 

aircraft or as required by the Federal Aviation Regulations. 

4. Sense Above and the Aircraft Manufacturer (DJI) are the most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition. This 

maintenance process allows for an equivalent level of safety to be achieved due to the 

limited size, scope and area of operations.