Name / Address of Petitioner: 

Christopher DiBona 

Brewster Ambulance Service 

285 Hyde Park Avenue 

Boston, MA 02130 

Telephone Number of Petitioner: 617-983-1000 

Email: Cdibona@brewsterambulance.com 

Regulations from which the exemption is requested: 

14 CFR Part 21

14 C.F.R. § 45.23(b) 

14 C.F.R. § 91.109 

14 CFR § 91.151 (a) 

14 CFR § 409 (a) (2) 

14 C.F.R. § 91.7 (a)

14 C.F.R. § 91.103

14 C.F. R. § 91.119

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.405 (a) 

14 CFR § 417 (a) & (b) 3 

14 CFR § 91.9 (b) (2) 

14 CFR § 61.3

14 C.F.R. § 91.121 

14 CFR § 91.205(b) 

14 CFR § 407 (a) (1) 

Appendix A describes the FARs from which an exemption is requested and 

summarizes the justification for each requested exemption. 
This Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rule making required under Section 332 of the Reform Act. In 

making this determination, the Administrator must determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

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

• Operation of the UAS in close proximity to airports and populated areas; and • 

Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of 

such aircraft in the national airspace system.” Id. § 333(c). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

1 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions 

from its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, 

which includes sUASs. The Administrator may grant an exemption from a requirement 

of a regulation prescribed under subsection (a) or (b) of this section or any sections 

4470244716 of the Federal Aviation Act if Administrator finds the exemption in the public 

interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR 

§91.203 (a) (1). 

Petitioner Background: 

The Petitioner has served proudly as a Flight Paramedic for Boston MedFlight for 10 

years and has been involved in the Emergency medical field for the past 22 years. 

Boston MedFlight operates several EC145, Sikorsky S76 C++ helicopters and a Cessna 

Citation jet. As a Flight Medic, the Petitioner routinely functions as a clinician and as an 

aid to the PIC with radio communications, GPS navigation and see and avoid 

operations. After completing 2,500 missions of emergency rotor and fixed wing missions 

in the NAS, his respect for aviation safety and the need for careful, regulated sUAS 

integration into the NAS is unmatched. 

Currently Mr DiBona is the Director of Clinical Performance at Brewster Ambulance 

Service involved in the medical and operational oversight of close to 700 clinicians 

within the Commonwealth of Massachusetts. Mr DiBona oversees clinical development, 

quality assurance, education and research associated with pre-hospital medicine. He 

has over twenty years of pre-hospital care and clinical experience and was part of the 

original Brewster Ambulance team. After moving to Denver, Colorado, to deepen his 
experience with a career in EMS, he returned to Massachusetts and worked for multiple 

non-transport, hospital-based advanced life support services along the south shore. 

Mr DiBona also worked for ten years with Boston MedFlight as a flight paramedic and 

was previously the Tactical Medical Element Leader for the Metropolitan Law 

Enforcement Council, Quincy Police Marine Unit, and the FBI Boston SWAT Advanced 

Life Support Division. Chris is a graduate of Northeastern University and has extensive 

training in Advanced Trauma Life Support and Fundamentals of Critical Care Support 

for adult and pediatric patients. 

In addition the need for aerial imaging is imperative for rescue personnel in now the five 

911 municipalities we serve in the commonwealth. Those cities and towns include 

Quincy, Braintree, Brockton, Middleboro and Plymouth

After a 22 year career in EMS / SAR / Aeromedical operations in New England, the 

Petitioner is in a unique position to not only safely utilize sUAS technology in the NAS, 

but to serve as a leader to other sUAS operators. If permission is granted, the Petitioner 

will serve numerous Local, State and Federal entities. The professional relationships 

he’s cultivated with the Massachusetts State Police, USCG and endless Fire and Police 

departments would serve as a conduit to safe sUAS implementation into the local 

airspace. His significant on scene emergency aeromedical experience with full scale 

helicopters will serve as the backbone for safe, efficient sUAS operations in numerous 

roles. Our deployment model in place would include but is not limited to EMS / Fire 

emergency support, Police operation support and missing persons support. 

At no time will he operate outside the clearly outlined sUAS guidelines published by the 

FAA. For example, never >400’AGL, within five miles of an airport or beyond VLOS. 

Petitioner also notes and has read the congressional mandate in sections 332 and 333 

of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to 

accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. Accordingly, Petitioner applies for authorization under 

the Federal Aviation Act and the FARs to undertake the aforementioned activities for 

commercial purposes. If the Petition is granted, Petitioner will be at a significant 

competitive advantage if it, as it prefers, complies with FAA policy. 

Vehicle(s): 

The Petitioner will fly one or more DJI Inspire1

These vehicles have the built in capability to limit the height they fly above the ground, 

to limit the radius of the distance they fly from the operator, and to exclude them from 

class B, C, and D airspace as well any TFR’s (Temporary Flight Restricted) areas. The 

vehicles also have the built in capability to return to the launching point if the wireless 
control link is interrupted or if the operator attempts to exceed any of the height, radius, 

or airspace limitations programmed into them. The vehicle weighs about five pounds 

and has a maximum gross weight of approximately twenty pounds. It has a top speed of 

about 30 knots. It has four fixed pitch rotors, thrust from which is varied by changing 

RPM. It is powered by a lithium polymer smart battery. 

Flight profiles: 

The petitioner will program the Inspire 1 so that they will not fly more than 400 feet 

above ground level, or more than line of site from its operator. The PIC (Person in 

Control) will carefully preflight the vehicle before each mission to assure that its 

compass and GPS system are properly calibrated and that the return-to-home feature, 

altitude, and radius limitations work. 

They will not operate in controlled airspace. In the unlikely event that a manned aircraft 

flies below 400 feet AGL where the Petitioner is operating its Inspire 1, the operator will 

keep both the vehicle and manned aircraft in sight and avoid the manned aircraft. 

More particularly, the Petitioner will fly the Inspire 1 only over the hazard areas that are 

in control of an on scene Incident Commander, most likely being a Fire Chief, SAR rep 

or Police rep, etc. 

The Petitioner will not conduct flight operations of any kind without a minimum of three 

dedicated personal. A PIC, SIC and observer will be present and functioning as a 

cohesive flight team for each mission. 

Airframe 

DJI Inspire 1 

Product profile 

The inspire 1 is a quadracopter capable of capturing 4k video and transmitting a HD 

video signal to multiple devices. Equipped with retractable landing gear, an 

unobstructed 360 degree view from the camera is made possible by moving the landing 

gear out of sight. The built in camera has been integrated with a gimbal to minimize 

space and maximize weight efficiency. Optical flow enhances the hovering precision 

when GPS is not available. 

Aircraft 

Model-T600 
Weight (Battery Included)-2935 g 

Hovering Accuracy (Gps Mode)-Vertical: 0.5 m Horizontal: 2.5 m 

Max Angular Velocity-Pitch: 300°/s Yaw: 150°/s 

Max Tilt Angle-35° 

Max Ascent Speed-5 m/s 

Max Descent Speed-4 m/s 

Max Speed-22 m/s (ATTI mode, no wind) 

Max Flight Altitude-4500 m 

Max Wind Speed Resistance-10 m/s 

Max Flight Time-Approximately 18 minutes 

Motor Model-DJI 3510 

Propeller Model-DJI 1345 

Indoor Hovering-Enabled by default 

Operating Temperature Range -10° to 40° C 

Diagonal Distance-559 to 581 mm 

Dimensions-438x451x301 mm 

Gimbal 

Model-ZENMUSE X3 

Output Power (With Camera)- Static: 9 W- In Motion: 11 W 

Operating Current-Station: 750 mA Motion: 900 mA 

Angular Vibration Range ±0.03° 
Mounting-Detachable 

Controllable Range- Pitch: -90° to +30° Pan: ±320° 

Mechanical Range- Pitch: -125° to +45° Pan: ±330° 

Max Controllable Speed-Pitch: 120°/s Pan: 180°/s 

Camera 

Name-X3 

Model-FC350 

Total Pixels-12.76M 

Effective Pixels-12.4M 

Image Max Size-4000x3000 

Iso Range-100~3200 

Fov (Field Of View)-94° 

Cmos-Sony EXMOR 1/2.3” 

Lens 

f/2.8 (20 mm equivalent) 

9 Elements in 9 groups 

Aspherical lens element 

Anti-distortion filter 

UV filter 

Still Photography Modes 

Single shoot 

Burst shooting (BURST: 3/5/7 frames,AEB: 3 or 5 bracketed frames at 0.7EV Bias) 

Time lapse 

Hd Video Recording Modes 

UHD (4K): 4096x2160p24/25,3840x2160p24/25/30 

FHD: 1920x1080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG,DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

Supported Sd Card Types 

SD/SDHC/SDXC Micro SD 

Max capacity: 64 GB. Speed: Class 10 or higher 

Operating Temperature Range 

0° to 40° C 
Remote Controller 

Name-C1 

Operating Frequency 

922.7~927.7 MHz (Japan Only) 

5.728~5.850 GHz 

2.400~2.483 GHz 

Transmitting Distance (Outdoor And Unobstructed)-2 km 

Eirp-10dBm@900m,13dBm@5.8G,20dBm@2.4G 

Video Output Port 

USB, mini-HDMI 

Power Supply 

Built-in battery 

Charging 

DJI charger 

Dual User Capability-Host-and-Slave connection 

Mobile Device Holder-Tablet or Phone 

Max Mobile Device Width 

170mm 

Output Power 

9 W 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 

0-40° C 

Battery 

6000 mAh LiPo 2S 

Charger 

Model-A14-100P1A 

Voltage-26.3 V 

Rated Power-100 W 

Battery (Standard) 

Name 

Intelligent Flight Battery 

Model 

TB47 

Capacity 

4500 mAh 

Voltage 

22.2 V 

Battery Type 
LiPo 6S High voltage battery 

Energy 

99.9 Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° C to 28° C 

Charging Temperature Range 

0° to 40° C 

Max Charging Power 

180 W 

Battery (Optional) 

Name 

Intelligent Flight Battery 

Model 

TB48 

Capacity 

5700 mAh 

Voltage 

22.8 V 

Battery Type 

LiPo 6S 

Energy 

129.96 Wh 

Net Weight 

670 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

Charging Temperature Range 

0° to 40° C 

Max Charging Power 

180 W 

Vision Positioning 

Velocity Range 

Below 8 m/s (2 m above ground) 

Altitude Range 

5-500 cm 
Operating Environment 

Brightly lit (lux > 15) patterned surfaces 

Operating Range 

0-250 cm 

UAV Crew

Personnel qualifications Pilot in Command (PIC) 

The PIC shall be the individual with responsibility for all other personnel involved with 

the operation. For clarification, this section will include both the Pilot in Command and 

the Pilot at the Controls although they may both be interchangeable in most 

circumstances. The PIC shall have the minimum qualifications; 

1. Knowledge of general aviation practices and FARs ( optional private rating) 2. 

National Incident Management System Certification 100, 300, & 700 level 3. 20/20 

corrected vision

4. Familiarity and operations of DJI inspire 1 aircraft to include; 

a. At least three events utilizing the inspire 1 

b. At least three take offs and landings within 90 days with the inspire 

c. Familiar with the latest revision of ground control software

d. Emergency recovery procedures in failed link situations 

5. Familiar with the qualification requirements of all other personnel 

6. Familiar with communications protocols in an NIMS/ICS environment 

7. Familiar with mission planning and preflight procedures

7. Versed in emergency procedures and contingency operations 

8. Familiar with acceptable field repair and maintenance procedures 

Pilot at controls (PAC) 

1. Knowledge of general aviation practices and FARs ( optional private rating) 

2. 2. National Incident Management System Certification 100, 300, & 700 level 
3. 20/20 corrected vision

4. Familiarity and operations of inspire 1 aircraft to include; 

a. At least three events utilizing the inspire 1 

b. b. At least three take offs and landings within 90 days with type 

c. Familiar with the latest revision of ground control software

d. Emergency recovery procedures in failed link situations 

5. Familiar with mission planning and preflight procedures

6. Versed in emergency procedures and contingency operations

7. Familiar with acceptable field repair and maintenance procedures 

Ground System Crew 

1. National Incident Management System Certification 100, 300, & 700 level 

2. 2. 20/20 corrected vision

4. Familiarity and operations of Spectra and Stryker aircraft to include; 

a. Familiar with the construction and configuration of each UA 

b. Familiar with GCU electronics and configuration

c. Familiar with field repair procedures for each UA

d. Familiar with the latest revision of ground control software 

Observers 

1. National Incident Management System Certification 100, 300, & 700 level 

2. 20/20 corrected vision

3. Familiar with emergency recovery procedures in failed link situations 

Mission Selection 

RPSearch Services recognizes that each mission has its’ own unique circumstances 

that may affect the operation of the UA, safety factors, and personnel involved. 
Search and Rescue/Recovery 

Search and Rescue operations range from small singly controlled units to multi agency 

units requiring coordination and close dissemination of information. The PIC will 

consider the following factors before authorizing any launch of either UA for the purpose 

of Search and Rescue; 

1. Weather 

When possible, the RPSS PIC shall contact the closest flight service station for 

weather in the immediate area of operations. In lieu of that source, the local source of 

weather may be utilized through the internet, or may be observed on site. The PIC shall 

have final determination of risk due to weather and authority over launch of any RPSS 

aircraft 

2. Hazards to the public 

The RPSS PIC shall make every effort to ensure that flight operations will not pose any 

undue risk to the public not directly involved with the effort. The PIC shall have final 

determination of risk to the public and authority over launch of any RPSS aircraft 

3. Hazards to property 

The RPSS PIC shall make every effort to ensure that flight operations will not pose any 

undue risk to any property in the area involved with the effort. The PIC shall have final 

determination of risk to the property and authority over launch of any RPSS aircraft 

4. Hazards to personnel 

The RPSS PIC shall make every effort to ensure that flight operations will not pose any 

undue risk to the personnel directly involved with the effort. The PIC shall have final 

determination of risk to the public and authority over launch of any RPSS aircraft 

5. Proximity to controlled airspace 

The PIC shall ensure that all unreported operations take place at least three (3) miles 

from any controlled airspace. Operations inside any controlled airspace shall be 

performed with permission of, and in constant communication with, the controlling 

authority of the airspace. The PIC shall have final authority over launch after clearance 

has been granted by the controlling authority. The controlling authority maintains the 

right to abort any RPSS flight operation regardless of the stage that operation is in. 

Law Enforcement Support 

In addition to the above stated considerations for Search and Rescue, additional 

considerations for law enforcement support shall be: 
1. Covert operations affecting safety 

The PIC shall have final authority of launches and flight operations involved in covert 

operations that could preclude any safety consideration to maintain the missions 

secrecy. No convert operations shall be conducted that subvert any stated safety 

consideration. 

2. Evidence handling and security 

RPSS personnel directly involved with evidence gathering shall not subvert any of the 

safety rules stated to perform flight operations. 

Fire Support 

RPSS fire support activities are confined generally to wildland fire control and post fire 

mop up. In the event that an Incident Command is established, the RPSS PIC shall 

report directly to the Incident Commander and defer resource authority to that position. 

Additional considerations for fire support include: 

1. Safety of full size aircraft involved in support operations 

Fire incidences typically involve the use of spotter aircraft and aircraft that deliver 

fire retardants and water at altitudes operated in by RPSS aircraft. The PIC shall defer 

to any incoming aircraft reported by the Incident Command, Air Boss, or RPSS 

observers. All RPSS UA flight operations shall cease and aircraft will land until the full 

size aircraft are clear of the area. 

2. Safety of RPSS personnel 

At no time shall the PIC allow any RPSS personnel to place themselves or any RPSS 

resource in danger. The PIC shall defer to the Incident Commander in all situations 

when an ICS situation exists. 

Disaster Recovery Support 

Almost all Disaster Recovery Support operations shall be controlled by a NIMS Incident 

Command System. The RPSS PIC shall report to the Incident Commander with a list of 

all resources that can be made available for the situation. Regardless of authority, the 

RPSS PIC has final authority for all launches of RPSS UA. 

Other agency missions 

Other agencies could include NTSB, DOT, Dept. Agriculture, DEA, etc. and could pose 

additional safety considerations. The PIC shall have final authority over the execution or 

attempt of any flight operations by RPSS personnel and UA. 
Incident Command Interface 

ICS accountability 

If an Incident Command structure is implemented on any mission involving UAV 

personnel, the PIC shall report directly to the situation Incident Commander with a full 

disclosure of assets available. The PIC shall defer authority for flight clearance to the 

Incident Commander unless a safety situation that the Incident Commander may not be 

aware of arises. In that case, the PIC must halt flight operations and report immediately 

to the IC for further instructions. Regardless of authority, no UAV operators shall 

impinge, interfere, or hinder any full size aircraft entering into proximity of the operation. 

ICS communications 

All communications in a IC structure shall be the prescribed method of the incident 

which may two radio, cell phone, or face to face. Irregardless of method, communication 

between the PIC, ground crews, and incident command shall be conducted in plain 

English. All personnel should reduce the amount of codes and jargon to an absolute 

minimum to ensure clarity of information transmitted. UAV flight personnel shall not 

disclose any information to parties outside the responding agency concerning the 

mission or the payload unless it has been approved by the ICS Public Information 

Officer (PIO) 

Permissions 

In order of hierarchy, flight authorizations will come from the following: 

1. Area Command – in a multi-agency oriented incident 

2. Situation Incident Command – in a local incident 

3. Pilot in Command – in an independent operation. 
Public interest Granting the petition would be in the public interest because: 

1. The Congress of the United States has determined that early accommodation of 

sUAS into the National Airspace System advances the public interest. The Committee 

Report leading the House to adopt H.R. 658 said: "The successful integration of 

unmanned aircraft systems (UAS) into the National Airspace System (NAS) can support 

more than 23,000 high paying jobs in the United States. . . . The absence of a plan to 

integrate UASs into the NAS is a barrier to such job creation . . . ."1 Granting the 

Petition represents a step toward such integration, in the absence of a comprehensive 

regulatory regime for sUAS, and thus would serve the Congressional goal and the 

public interest. 

2. Granting the Petition will facilitate a new era in Emergency Response activities, one 

in which the responders themselves have a tool to safely, quickly and remotely assess a 

situation without placing lives in harm’s way. In comparison, the EOD robots have saved 

countless lives since their inception, a feat that will become common place for aerial 

assessments. 

3. Granting the Petition will enable Petitioner to demonstrate the commercial viability of 

creating new safety techniques and tactics with new aeronautical technology, thereby 

improving the efficiency of Emergency Responders around the world and making for a 

safer society. The rules from which Petitioner seeks exemption artificially and irrationally 

limit the effective use of new technologies to expand Emergency Response safety and 

improve the efficiency of markets, thereby subverting the public interest. 

______________________________________

1. H. R. Rep. 11229 on H.R. 658, 112th Cong., 1st Sess. at 116. The HouseSenate 

Conference Committee on the FAA Modernization and Reform Act of 2012 

recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. 

Conference Report to Accompany H.R. 658, H.R. Rep. 112381, 112th Cong., 2d Sess., 

at p. 1 (Feb. 1, 2012). 

4. Granting this Petition will enable the Petitioner to help demonstrate that the FAAs 

sUAS FARs are indeed a safe and effective means in which to govern the NAS. He will 

serve as an advocate for the practice of lawful sUAS operations. 

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging new 

aviation technologies advances the public interest. The FAA itself has recognized the 

public interest in its role of "Encouraging and developing civil aeronautics, including new 

aviation technology."2 Granting the Petition will enhance FAA fulfillment of that 

commitment, thereby serving the public interest. Air commerce flourishes in the United 
States because of the rapid pace of innovation in aeronautical and associated 

technologies, followed by their commercialization and their introduction into the 

marketplace. The drone technology that the Petitioner uses exemplifies the latest 

innovative leap forward in aeronautical technology. Preventing it from using this in air 

commerce subverts achievement of the goal. 

6. Granting the Petition will fulfill the Congressional determination that integrating sUAS 

technology into the NAS serves the public interest. Section 330 of the FAA 

Modernization and Reform Act of 2012, specifically recognizes the advantages to air 

commerce obtainable from the deployment of sUAS technologies. It mandated several 

steps by the FAA to accelerate the availability of these technologies in the National 

Airspace System, thereby representing a congressional determination that the public 

interest is served by making these technologies more widely available at the earliest 

practicable date. The Petition represents a way for the 

4 

FAA to move incrementally, while still satisfying its congressional mandate and meeting 

its obligation to enhance the public interest by making new technologies available by 

allowing the use of sUAS technologies in a manner that protects the public and the rest 

of the aviation community from significant risk. 

The commercial activities by Petitioner proposed in the Petition represent contributions 

to new forms of air commerce, thereby fulfilling the FAA’s statutory mandate under the 

2012 Act. 

7. Granting the Petition will enhance aviation safety, thereby advancing the public 

interest. The Petitioner has committed itself in the Petition to safety practices that 

reduce or eliminate hazards to aircraft in the National Airspace System and to persons 

and property on the ground. Many others are flying sUAS without regard to these 

hazards. Granting the Petition will offer the Petitioner up as an example of how the FAA 

is willing to accommodate the new technology when it is constrained by appropriate 

limitations to enhance safety. It will also allow the Petitioner to be a role model for safe 

commercial sUAS operations. 

Users of the National Airspace System are confronted by mushrooming threats from 

sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some flexibility to 

accommodate lawful and safe operation of sUAS for legitimate commercial purposes, 

the level of defiance will increase, intensifying the hazards to manned aircraft and to 

persons and property on the ground. 

Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from certain parts of the FARs. 

Thank you very kindly for exemption consideration. Sincerely 

Christopher DiBona 
APPENDIX A

FAR SUBJECT Justification

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle

Insufficient space on 

vehicle 

14 CFR Part 21 Aircraft certification 

requirements and 

procedures

Designed for manned 

aircraft; not suitable for off 

the shelf sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS; petition 

describes training for sUAS 

operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for off 

the shelf sUAS 

14 CFR § 91.9 (b) (2) Requirement for manual to 

be available in the cockpit

No one aboard to read 

manual

14 CFR § 91.103(b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one aboard to operate 

controls

14 CFR § 91.119 Minimum altitudes for safe 

flight 

Safety requires operation 

below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness certificates to 

be onboard

No one aboard to read 

certificates

14 CFR § 91.205(b) Cockpit instruments No one to read

14 CFR § 91.417 Maintenance records not applicable

FAR
14 CFR § 91.409 Inspections designed for manned 

aircraft

14 CFR § 91.407 operation after maintenance designed for manned aircraft

14 CFR § 91.405 Maintenance required normal UAS maintenance will 

be followed

FAR SUBJECT Justification