1092 S. 500 W.

Russiaville, IN 46979

Cell: 765-863-5111

January 20, 2016

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, NightHawk Productions LLC, 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.

NightHawk Productions, LCC provides professional aerial solutions for all types of 

design and construction projects, mapping, inspection and photography of landfills, 

mining facilities, utilities, oil and gas facilities, agriculture, construction sites, real estate 

appraisals, forensic engineering inspections, damage assessments and fire investigation 

applications. 

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 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”):

NightHawk Productions, LLC

Attn: Seth L. Mote

1092 S. 500 W.

Russiaville, IN 46979

765-863-5111

Email: NightHawkPhantoms@gmail.com
U.S. Department of Transportation – Federal Aviation Administration 

Exemption Request – Section 333 of the FAA Reform Act

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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 NightHawk Productions to conduct 

commercial operations using the DJI Inspire 1 and DJI Phantom 3 for mapping, 

inspection and photography of landfills, mining facilities, utilities, oil & gas facilities, 

agriculture, real estate appraisals, construction sites, forensic engineering inspections, 

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 NightHawk Productions UAS Flight Operations Manual and Preflight 

Checklist (NightHawk Productions 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 

Inspire 1 User Manual and Phantom 3 User Manual, Phantom 3 Pilot Training Guide, and 

the Smart Flight Battery Safety Guidelines (hereafter collectively referred to as 

“Manufacturer’s Operations Manuals”).

All NightHawk Productions 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 NightHawk Productions’ UAS Pilot Training Program (the NightHawk 

Productions UAS Training Program Outline will be submitted separately if required and

NightHawk Productions 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 NightHawk Productions UAS 

operations are carried out with an equivalent or higher level of safety than currently

authorized manned aircraft operations. The details below regarding NightHawk 

Productions’s intended UAS applications provide clear evidence that approval of this 

exemption is in the public interest.

CHARACTERISTICS OF THE sUAS
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Exemption Request – Section 333 of the FAA Reform Act

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The Inspire 1 and Phantom 3 are all very similar UAS. The Inspire 1 has a diagonal 

motor-to- motor distance of approximately 438x451x301 mm. The Phantom 3 is 

approximately 27 inches across, measured diagonally and including the propellers. Both 

are constructed primarily of frangible materials (plastic). The Phantom 3 weighs less 

than 3 pounds and the Inspire weighs 6.5 pounds. The Inspire 1 is powered by a 

4700mAH LiPo battery and the Phantom 3 is powered by a 4480 mAh 4S LiPo battery. 

The max flight speed of the Inspire 1 is approximately 50 mph and Phantom 3 is 36 mph. 

Both 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. Both the Inspire 1 and the

Phantom 3 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 NightHawk Productions 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 NightHawk Productions 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 NightHawk Productions sUAS Flight Operations 

Manual. If the inspection reveals a condition that affects the safe operation of the UAS, 

the aircraft is removed from service and prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe 

flight. All NightHawk Productions UAS will comply with all applicable manufacturer 

safety bulletins.

The safety and reliability of the DJI Inspire 1 and Phantom 3 sUAS is further supported 

by the fact that numerous FAA exemptions have previously been approved for their use 

in commercial operations. 

UAS OPERATOR REQUIREMENTS

All NightHawk Productions 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 NightHawk Productions 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 
U.S. Department of Transportation – Federal Aviation Administration 

Exemption Request – Section 333 of the FAA Reform Act

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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 Inspire 1 

and Phantom 3 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 NightHawk Productions sUAS operators will hold a current 

FAA issued private, recreational, ore sport pilot certificate and 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 NightHawk Productions 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 5 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 NightHawk Productions. 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 NightHawk Productions. The letter of agreement from 

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

request.
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• 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 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. NightHawk Productions may update 

or revise its operating documents. However, it is NightHawk Productions responsibility 

to track such revisions and present updated and revised documents to the Administrator 

or any law enforcement official upon request. NightHawk Productions must also present 

updated and revised documents if it petitions for extension or amendment to the grant of 

exemption. If NightHawk Productions determines that any update or revision would 

affect the basis upon which the FAA granted the exemption, then NightHawk 

Productions 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 removed from service and 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.
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Exemption Request – Section 333 of the FAA Reform Act

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• 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.

• 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 NightHawk Productions to operate the DJI Inspire 

1 and Phantom 3 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, both DJI models 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 

create less than 75dB of noise.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

NightHawk Productions 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

NightHawk Productions respectfully requests that the FAA grant the exemption sought in 

this request. NightHawk Productions believes that considering the small size and weight 
U.S. Department of Transportation – Federal Aviation Administration 

Exemption Request – Section 333 of the FAA Reform Act

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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.

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,

NIGHTHAWK PRODUCTIONS, LLC

Seth L. Mote

President & Owner

765-863-5111 CELL

NightHawkPhantoms@gmail.com

APPENDIX A: REGULATIONS REQUIRING EXEMPTION

NightHawk Productions requests an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the Inspire 1 and 

Phantom 3 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.
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Exemption Request – Section 333 of the FAA Reform Act

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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.

Given the size, weight, speed, operational limitations, and range of the sUAS, 

NightHawk Productions 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 

Inspire 1 and Phantom 3 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.
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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.

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
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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

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, NightHawk 

Productions 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. NightHawk Productions 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.