625 Industrial Blvd 281.313.9700

Sugar Land, TX 77478 281.313.9707 fax

Haag3DSolutions.com

April 28, 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 solutions 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 

documentation 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 and 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 Transportation’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 Kianka, P.E.

625 Industrial Blvd

Sugar Land, TX 77478

TEL: 281-313-9700

FAX: 281-313-9707

Email: kkianka@haagglobal.com
U.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, agriculture, construction sites, forensic 

engineering assessments, damage assessments and fire 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 documents

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

include 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 Safety 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 completed 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 sUAS

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 diagonal 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 pounds 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 the 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 altitude 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. Repairs, 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 name 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 use 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-flight 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 operating 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, performance 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 previously 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 the 
U.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 allowing 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 operational 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 at 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-issued 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 specified 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 

between 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 

procedures 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 must 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 that 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 condition 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 critical 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 PIC 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 operated 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 accident. 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 UAS 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 completed 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 the 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 valuable 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 considering 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 national 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_v1.8en

Phantom_2_Vision_Plus_Pilot_Training_Guide_v1.1_en

Phantom_2_Vision_Plus_Quick_Start_Guide_en
U.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 

sUAS:

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 sUAS, 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 sUAS involved. An analysis of these different criteria demonstrates that

the sUAS operated without an airworthiness certificate, under 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 the 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 sUAS, 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 sUAS 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 sUAS 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 sUAS 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 sUAS.

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 allowing, 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 sUAS 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 current
U.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 sUAS

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

be available 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.