625 Industrial Blvd 281.313.9700

Sugar Land, TX 77478 281.313.9707 fax

Haag3DSolutions.com

April 2 8 , 2015

U.S. Department of Transportation

Federal Aviation Administration

Document Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

RE: Exemption Request

– Section 333 of the FAA Report Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95,

126 Stat.11 (amending 49 U.S.C.) (hereinafter, the “Reform Act”) and 14 C.F.R. Part 11, Haag 3D

Solutions LLC (“H3DS”), a developer and operator of small unmanned aircraft systems (singularly

a “sUAS” or cumulatively “sUASs”) seeks an exemption from the Federal Aviation Regulations

listed below, to allow commercial operation of its sUASs.

Haag 3D Solutions, LLC a division of Haag Engineering Co. , Forensic Engineers & Consultants

since 1924, provides professional 3D geospatial s olutions for all types of design and construction

projects. Haag 3D Solutions, LLC (H3DS) is a technology and services company specializing in

the application of 3D imaging and BIM technologies delivering highly accurate and reliable as built

documentatio n for both public and private sector clients. Having completed hundreds of 3D Laser

Scanning , mapping and BIM assignments throughout North America, the Haag 3D Solutions team

has gained a uniquely practical familiarity with 3D Laser Scanning technology an d processes and

offers real solutions to a wide variety of measurement and physical documentation tasks.

As described more fully below, the requested exemption would permit the operation of small,

unmanned sUAS under controlled condition in airspace that ( a) is limited, (b) is predetermined, (c)

is controlled as to access, and (d) would provide safety enhancements to the already safe

operations in the mapping industry. Approval of this exemption would thereby enhance safety and

fulfill the Secretary of Tra nsportation’s responsibilities to “... establish requirements for the safe

operation of such aircraft systems in the national airspace system.” Reform Act 333 (c).

The name and address of the applicant (“Applicant”):

Haag 3D Solutions, LLC

Attn: Kevin Kian ka, P.E.

625 Industrial Blvd

Sugar Land, TX 77478

TEL: 281

- 313

- 9700

FAX: 281

- 313

- 9707

Email: kkianka@haagglobal.comU.S. Department of Transportation

– Federal Aviation Administration Page 2

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

The Applicant hereby requests exemption from the following FARs:



### • 14 C.F.R. 21, subpart H



### • 14 C.F.R. 61.3



### • 14 C.F.R. 61.113(a)&(b)



### • 14 C.F.R. 61.133(a)



### • 14 C.F.R. 91.9(b)(2)



### • 14 C.F.R. 91.103(b)



### • 14 C.F.R. 91.105



### • 14 C.F.R. 91.109(a)



### • 14 C.F.R. 91.119



### • 14 C.F.R. 91.121



### • 14 C.F.R. 91.151(a)



### • 14 C.F.R. 91.203(a) & (b)



### • 14 C.F.R. 91.319(a)(1)



### • 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

The requested exemption would authorize H3DS to conduct commercial operations using the DJI

Phantom 3, DJI Phantom 2 Vision+, and DJI Phantom 2 for mapping, inspection and photography

of landfills, mining facilities, utilities, oil & gas facilities, agricu lture, construction sites, forensic

engineering assessments, damage assessments and fi re investigation applications.

In order to ensure at least an equivalent level of safety to currently authorized operations using

manned aircraft, all operations will be subject to the strict operating requirements defined in the

H3DS UAS Flight Operations Manual and Preflight Checklist (H3DS will provide these document s

if required, but requests that the FAA treat the m a s proprietary under 14 C.F.R. 11.35(b) and not

inclu de this document in the public docket). Additionally, this petition for exemption is supported by

the information contained in the Phantom 2 Vision+ User Manual, Phantom 2 User Manual,

Phantom 2 Vision Pilot Training Guide, and the Smart Flight Battery Saf ety Guidelines (hereafter

collectively referred to as “Manufacturer’s Operations Manuals”).

All H3DS UAS will be operated only by individuals who hold at least an FAA issued private,

recreational, or sport pilot certificate and who have successfully comple ted H3DS’s UAS Training

Program (the H3DS UAS Training Program Outline will be submitted separately if required and

H3DS requests that the FAA treat this document as proprietary under 14 C.F.R. 11.35(b) and not

include this document in the public docket).

The characteristics of the sUAS, detailed sUAS operator requirements, and sUAS operating

parameters given below will ensure that all H3DS UAS operations are carried out with an

equivalent or higher level of safety than currently authorized manned aircraft operations. The

details below regarding H3DS’s intended UAS applications provide clear evidence that approval

of this exemption is in the public interest.U.S. Department of Transportation

– Federal Aviation Administration Page 3

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

CHARACTERISTICS OF THE s UAS

The Phantom 3, Phantom 2 Vision+, and Phantom 2 are all very similar UAS. One exception is

that the Phantom 3 and Vision+ include an integrated camera, while a third party camera can be

affixed to the Phantom 2. The Phantom 2 Vision+ and Phantom 2 have a d iagonal motor

- to

- motor

distance of approximately 14 inches. The Phantom 3 is approximately 27 inches across, measured

diagonally and including the propellers. All three UA are constructed primarily of frangible materials

(plastic) and weigh less than 3 po unds each. The Vision+ and Phantom 2 are powered by a 5200

mAh 3S LiPo battery. The Phantom 3 is powered by a 4480 mAh 4S LiPo battery.

The max flight speed of the Phantom 2 Vision+ and the Phantom 2 is approximately 34 mph, while

the max flight speed of t he Phantom 3 is approximately 36 mph. All three UA contain an on

- board

GPS and an inertial measurement unit for flight stabilization and automatic failsafe return to home

in case of a lost control signal. Additionally, these UAS offer geo

- fencing and max a ltitude features

to restrict the maximum vertical and horizontal distance the aircraft will fly from its home point. The

Phantom 3 and Vision+ offer the added feature of displaying real time flight data, including battery

status, altitude and distance from home, within the DJI App.

Each sUAS operated by H3DS for commercial use will be registered in accordance with 14 C.F.R

Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart C, in a size as large

as practical for the size of the sUAS.

All sUASs operated by H3DS will be maintained in accordance with the manufacture’s

maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and

aircraft components and all pertinent instructions in the user manuals. Rep airs, component

changes, and software/firmware updates will be recorded in the sUAS’s maintenance log.

Maintenance log entries will include the date, sUAS ID number, registration number, current sUAS

flight time, a description of work performed, and the na me of the individual who completed the

work. Any UAS that has undergone maintenance or alterations that affect the sUAS operation or

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test

flight, prior to us e in any commercial operations. The functional test flight must be conducted in

such a manner so as to not pose an undue hazard to persons and property. The PIC who conducts

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

- fligh t inspection of the

sUAS will be completed by the PIC prior to each flight operation as specified in the H3DS sUAS

Flight Operations Manual. If the inspection reveals a condition that affects the safe operation of the

UAS, the aircraft is prohibited from o perating until the necessary maintenance has been performed

and the UAS is found to be in a condition for safe flight. All H3DS UAS will comply with all applicable

manufacturer safety bulletins.

Additional information on the aircraft specifications, perfor mance limitations, operating procedures,

and pre

- flight inspections is contained in the attached documents. The safety and reliability of the

DJI Phantom 2 Vision+ and DJI Phantom 2 sUAS is further supported by the fact that numerous

FAA exemptions have pr eviously been approved for their use in commercial operations. As noted

above, the DJI Phantom 3 is very similar to these sUAS and incorporates additional safety features.

UAS OPERATOR REQUIREMENTS

All H3DS sUAS operators will hold at least an FAA issued private, recreational, or sport pilot

certificate and will have successfully completed H3DS’s UAS Training Program. Completion of theU.S. Department of Transportation

– Federal Aviation Administration Page 4

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

H3DS sUAS Training Program will ensure safe operations by not all owing any PIC to operate a

sUAS unless that PIC has demonstrated, that he/she is able to safely operate the sUAS in a

manner consistent with the exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from people, vessels , vehicles and structures. All operators will

either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete

and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering

regulations and issues pertinent to commercial operation of the Phantom 3, Phantom 2 Vision+

and Phantom 2 sUAS.

The individual acting as PIC of a sUAS will be identified prior to any flight and will not change once

the flight has begun. The PIC is the individual in opera tional control of the flight operation from

beginning to end and is responsible for safe flight of the sUAS. All PIC flight hours used to

demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR §

61.51(b).

In order to act as PIC, all H3DS sUAS operators will hold a current FAA airman medical certificate

or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory,

a possession, or the Federal government.

UAS OPERATING PARAMETERS

In order to provide for a level of safety at least equivalent to operations conducted using manned

aircraft, all H3DS commercial sUAS operations will be conducted in accordance with the following

specific operating limitations:



### • The sUAS may not be operated a t a speed exceeding 30 knots (34 miles per hour). In no

case will the sUAS be operated at airspeeds greater than the maximum sUAS operating

airspeed recommended by the aircraft manufacturer.



### • All operations shall be conducted in accordance with an ATO

- issue d COA.



### • All sUAS operations will occur at or below 500 ft AGL or the maximum altitude specified

in the COA limitations, unless the purpose of the flight is to inspect a building or

structure which is taller than 500 ft. If the purpose of the flight is to inspect a building or

structure which is taller than 500 ft then the max altitude of the sUAS will be restricted to

20 ft above the highest point of that building or structure. All altitudes must be reported in

feet AGL.



### • No sUAS will be operated within 3 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with

an ARP, the center of the airport symbol as denoted on the current FAA published

aeronautical chart, unless a letter of agreement with that airport’s management is

obtained or otherwise permitted by a COA issued to H3DS. The letter of agreement with

the airport management must be made available to the Administrator or any law

enforcement official upon request.



### • No sUAS will be operated within class B, C, D or E airspace unless a letter of agreement

from the controlling ATC office is obtained or the flight is otherwise permitted by a COA

issued to H3DS. The letter of agreement from ATC must be made available to the

Administrator or any law enforcement official upon request.U.S. Department of Transportation

– Federal Aviation Administration Page 5

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015



### • The sUAS must be operated within visual line of sight (VLOS) of the PIC at all times. This

requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as s pecified on the PIC’s FAA

- issued airman medical certificate or U.S.

driver’s license.



### • All operating documents and a grant of exemption must be accessible during sUAS

operations and made available to the Administrator upon request. If a discrepancy exists

b etween the conditions and limitations in the grant of exemption and the procedures

outlined in the operating documents, the conditions and limitations in the grant of

exemption take precedence and must be followed. Otherwise, the PIC must follow the

proced ures as outlined in the operating documents. H3DS may update or revise its

operating documents. However, it is H3DS’s responsibility to track such revisions and

present updated and revised documents to the Administrator or any law enforcement

official upon request. H3DS must also present updated and revised documents if it

petitions for extension or amendment to the grant of exemption. If H3DS determines that

any update or revision would affect the basis upon which the FAA granted the exemption,

then H3DS m ust petition for an amendment to the grant of exemption.



### • sUAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights

under special visual flight rules (SVFR) are not authorized. The sUAS may not be

operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or

when visibility is less than 3 statute miles from the PIC.



### • Prior to each flight the PIC must inspect the sUAS to ensure t hat it is in a condition for

safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS,

the aircraft is prohibited from operating until the necessary maintenance has been

performed and the sUAS is found to be in a condi tion for safe flight. All maintenance and

alterations must be properly documented in the aircraft records.



### • Any sUAS that has undergone maintenance or alterations that affect the sUAS operation

or flight characteristics, e.g. replacement of a flight critica l component, must undergo a

functional test flight. The PIC who conducts the functional test flight must make an entry

in the aircraft records.



### • If the UAS loses communications or loses its GPS signal, the sUAS must return to a

predetermined location.



### • The P IC must abort the flight in the event of unpredicted obstacles or emergencies.



### • The PIC is prohibited from beginning a flight unless the sUAS’s battery level is at 75% or

higher. The PIC must begin returning the sUAS to the designated landing area when the

battery level drops below 25%.



### • Documents used by the operator to ensure the safe operation and flight of the sUAS and

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC

at the Ground Control Station of the sUAS any time the aircraft is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.



### • The sUAS must remain clear and give way to all manned aviation operations and

activities at all times.



### • The sUAS may not be ope rated by the PIC from any moving device or vehicle.U.S. Department of Transportation

– Federal Aviation Administration Page 6

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015



### • sUAS will not be operated directly over nonparticipating persons unless barriers or

structures are present that sufficiently protect nonparticipating persons from the UA

and/or debris in the event of an a ccident. UA will not be operated over any open

- air

assembly of people.



### • Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

the FAA's U AS Integration Office (AFS

- 80) within 24 hours. Accidents will be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB

Web site : www.ntsb.gov.

APPLICATIONS AND PUBLIC INTEREST

The requested exemption would allow H3DS to operate the DJI Phantom 3, Phantom 2 Vision+,

and Phantom 2 for the purposes of forensic engineering inspections and fire cause and origin

investigations. These inspections and investigations are complet ed on both residential and

commercial properties and are typically conducted in support of the property insurance industry.

Use of sUAS for these applications will offer significant advantages related to safety, time, and

cost. Most properties throughout t he country are insured, and property owners have an interest in

insurance underwriting, coverage, and claims processing; therefore it is clear that grant of this

exemption would be in the public interest.

Current options for gathering the data which under this exemption would be collected using sUAS,

include use of ladders, lifts, and manned aircraft. Use of ladders and lifts are inherently dangerous

and result in numerous injuries each year. Use of manned aircraft is typically not feasible and

therefore va luable information remains beyond the reach of the investigator. In most cases, use of

a sUAS is quicker and easier than any other alternative and often yields better information.

Due to their small size and the fact they carry no fuel, all three models of the DJI Phantom pose a

very low risk of damage to persons or structures on the ground. Because these sUAS are electric

powered, they create no harmful emissions and make very little noise.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

H3DS requests the grant of an exemption to the following specific sections of the Title 14 Code of

federal Regulations which would allow it to operate micro UAS for commercial use:

14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b) (2), 91.103(b),

91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407,

91.409, 91.417

CONCLUSIONS

H3DS respectfully requests that the FAA grant the exemption sought in this request. H3DS believes

that consider ing the small size and weight of the sUAS, along with the sUAS PIC training and

certification requirements stipulated above and the strict operating guidelines proposed herein, it

is clearly demonstrated that the sUAS will be operated safely in the nationa l air space (NAS) with

an equivalent or greater level of safety compared to manned aircraft.U.S. Department of Transportation

– Federal Aviation Administration Page 7

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

We are prepared to modify or amend any part of this request as deemed necessary by the FAA to

satisfy the need for an equivalent level of safety. Please contact us at any time if you require

additional information or clarification.

Respectfully Submitted

,

HAAG 3D SOLUTIONS, LLC

A DIVISION OF HAAG ENGINEERING CO.

Kevin A. Kianka, PE

Director of BIM/Modeling Program

281

- 201

- 6727 DIR

856

- 986

- 5434 CELL

kkianka@haagglobal.com

Attachments:

H3DS Phantom Pre

- Flight Checklist

Phantom_2_Vision_Plus_User_Manual_v1. 8 en Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1_en

Phantom_2_Vision_Plus_Quick_Start_Guide_enU.S. Department of Transportation

– Federal Aviation Administration Page 8

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

Appendix A

APPENDIX A: REGULATIONS REQUIRING EXEMPTION

H3DS requests an exemption from the following regulations as well as any additional regulations

that may technically apply to the operation of the Phantom 3, Phantom 2 Vision+, and Phantom 2

s UAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H,

entitled Airworthiness Certificates, establishes the procedural requirements for the issuance

of airworthiness certificates as required by FAR § 91.203(a). Given the size of the s UAS, its

light weight, and the limited operating area associated with its utilization, it is unnecessary

to go through the certificate of airworthiness process under Part 21 Subpart H in order to

achieve or exceed current safety levels.

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

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

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports and

populated areas of the s UAS involved. An analysis of these different criteria demonstrates that

the s UAS operated without an airworthiness certificate, und er the conditions proposed in that

exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness

certificate.

14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a civil

aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that

person's physical possession or readily accessible in th e aircraft when exercising the privileges of

that pilot certificate or authorization. However, when the aircraft is operated within a foreign

country, a pilot license issued by that country may be used.

The regulation provides also that no person that holds a private pilot certificate may act as pilot

in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to 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;



### (2) The aircraft does not carry passengers or property for compensation or hire.U.S. Department of Transportation

– Federal Aviation Administration Page 9

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

Appendix A

Given the size, weight, speed, operational limitations, and range of the s UAS, H3DS proposes

that operators of the UAS should not be required to hold a commercial pilot certification. Instead,

operators should be required to:

Hold at least an FAA issued private, recreational, or sport pilot certificate. All operators will either

meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log

at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations

and issues pertinent to commercial operation of the Phantom 3, Phantom 2 Vision+ and Phantom

2 UAS.

14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. H3DS proposes to provide an equivalent level of safety by maintaining

a copy of all documents used by the operator to ensure the safe operation and flight of the UAS

as well as documentation of an exemption and COA with the ground control station and accessible

to the PIC during flight operations.

14 C.F.R. § 91.103: Preflight action

This regulation requires that each pilot in command shall, before beginning a flight, become

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

lengths at airports of intended use, and the following takeoff and landing distance information.

This regulation is not applicable due to the fact H3DS s UAS operations will not occur at an airfield.

To provide an equivalent level of safety, the PIC will complete a preflight inspection as directed

by the manufacturer’s manuals and H3DS UAS operations manual before any flight.

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

The regulation provides that "No person may operate a civil aircraft that is being used for flight

instruction unless that aircraft has fully functioning dual controls."

The equivalent level of safety will be achieved through H3DS’s s UAS flight training program and

conducting flight training within controlled environments.

14 C.F.R § 91.105: Flight Crewmembers at Stations

The regulation states that required crewmembers must be at their stations in the aircraft during

specific portions of a flight.

This is not applicable since the s UAS carry no crewmembers. An equivalent level of safety will be

maintained by ensuring that the PIC is identified prior to any flight and that the PIC does not

change during a flight. The PIC will maintain control of the UAS for the duration of the flight.U.S. Department of Transportation

– Federal Aviation Administration Page 10

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

Appendix A

14 CFR § 91.119: Minimum Safe Altitudes

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Since the UA will be operating at a

maximum of 500 feet AGL, these operations cannot comply with this requirement.

The equivalent level of safety will be achieved given the size, weight and speed of the s UAS.

Additionally the sUAS will be operated in a defined and relatively small AOI. Moreover, the sUAS

will not be operated over any open

- air assembly of persons or over any person not involved with

the operation. The aircraft will be operated at an altitude all owing, if a power unit fails, an

emergency landing without undue hazard to persons or property on the surface.

14 CFR 91.121

– Altimeter settings

This section requires that 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 below 18,000 feet MSL to:



### • The current reported altimeter setting of a station along the route and within 100 nautical

miles of the aircraft;



### • If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station;



### • In the case of an aircraft not equipped with a radio, the elevation of the departure airport

or an appropriate altimeter setting available before departure.

To provide an equivalent level of safety, the s UAS utilize a GPS system, barometric pressure

sensors, and internal gyroscopes to calculate the altitude.

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

The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions

unless there is enough fuel to fly to the first point of intended landing and to fly after that for at

least 30 minutes.

Given the area of operation for the UAS, H3DS believes that an equivalent level of safety is

achieved by requiring at least 75% battery power in order to begin a flight and requiring the UA

to return to land when the battery power reaches 25%.

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

This regulation provides as follows:



### • No person may operate a civil aircraft unless it has an appropriate and currentU.S. Department of Transportation

– Federal Aviation Administration Page 11

Exemption Request

– Section 333 of the FAA Reform Act April 28, 2015

Appendix A

airworthiness certificate.



### • No person may operate a civil aircraft unless the airworthiness certificate required by

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

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

To obtain an equivalent level of safety and meet the intent of 91.203, H3DS proposes to maintain

a copy of all documents used by the operator to ensure the safe operation and flight of the s UAS

as well as documentation of an exemption and COA with the ground control station and these will

be a vailable to the Administrator or any law enforcement official upon request.

14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)

- Maintenance, Preventive

Maintenance, and Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409

require that the aircraft be "approved for return to service by a person authorized under 43.7"

after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection for the

issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep

records showing certain maintenance work that has been accomplished by certificated

mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to

service.

H3DS proposes that the maintenance, as well as preflight inspections of the sUAS will be

accomplished by the PIC. All maintenance will be conducted and logged in accordance with the

manufacturer’s specifications. An equivalent level of safety will be achieved because the sUAS

are small in size, are not complex mechanical devices, and will carry no external payload.