2. Maximum total flight time for each operational flight will be twenty (20) minutes. Fliehts will be 

terminated at twenty five percent (25%) battery power reserve should that occur prior to the 

twen (20) minute limit. 

3 Flights will be operated at an altitude of no more than four hundred (400) feet AGL. 

4. Minimum crew for each operation will consist of the UA Pilot and may include a Visual Observer 

"VO" 

5. The UAs will only operate within a safe area. 

6. A briefing will be conducted with regard to the planned UA operations prior to flieht operations. It 

will be mandatory that all personnel who will be performing duties with regard to the flight 

operations be present for this briefing. 

7. The Pilot and VO will have been trained in operation of UAs generally and received up-to-date 

information on the particular UA to be operated and the UA will be operated in conformity with Roger 

Conatser protocols. 

8. The PILOT and VO when used will at all times be able to communicate via voice communication. 

9. Written and/or oral permission from the relevant property holder(s), or their authorized 

representative(s), will be obtained, when needed. 

10. AII reguired permissions and permits will be obtained from territorial, state, county or city 

iurisdictions, including local law enforcement, fire, or other appropriate governmental agencies, when 

needed. 

11. If the UA loses communications or loses its GPS signal, the UA will return to the launch site of the 

UA, or another more aQpropriate site, and land. 12. The UA will have the capability to abort a flight in 

case of unpredicted obstacles or emereencies. 14 C.F.R. PART 21, SUBPART H: AIRWORTHINESS 

CERTIFICATES 14 C.F.R. §91.203 (A) (1) Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) 

(1)_ Given the size and limited operating area associated with the aircraft to be utilized by Roger 

Conatser, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 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 particular UA. In all cases, an analysis of these criteria 

demonstrates that the UA operated without an airworthiness certificate, in the restricted environment 

and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed. The UAs to be operated hereunder is less than five (5) pounds at (1280g) fully loaded, carries 

neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area. Unlike other civil aircraft, operations under this 
exemption will be tightly controlled and monitored by both the operator, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area of operation as 

is now done with conventional aerial videography and photography. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the UAs, due to its 

size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external 1oad. 

14 C.F.R. § 45.23 (B). MARKING OF THE AIRC 

The regulation requires: When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. 

Even though the UAs will have no airworthiness certificate, an exemption may be needed as the U As 

will have no entrance to the cabin, cockpit or pilot station on which the words "limited," "restricted," 

"light-sport," "experimental," or "provisional," may be placed. Given the size of the UAs, two-inch 

lettering will be impossible. The word "experimental," or any other term as is so required, will be placed 

on the fuselage of the UAs in compliance with §45.29 (t). 

The equivalent level of safety will be provided by having the UAs marked on its fuselage as required by 

§45.29 (t) where the pilot, observer and others working with the UAs will see the identification of the 

UAs as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions 

Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113(A) &(B); 61.133(A): PRIVATE PILOT PRIVILEGES AND LIMITATIONS; PILOT IN 

COMMAND - COMMERCIAL PILOT PRIVILEGES AND LIMITATIONS: PILOT IN COMMAND 

Section 61.113(a) &(b) limit private pilots to non-commercial operations. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, the UA in this case is remotely controlled with no passengers 

or property of others on board. Section 61.133(a) requires an individual with a commercial pilot's license 

to be pilot in command of an aircraft for compensation or hire. Roger Conatser respectfully proposes 

that operator requirements should take into account the characteristics of the particular UA. Roger 

Conatser's UAs have various built-in technical capabilities that strictly limit the potential for operation 

outside of the operating conditions set forth in the exemption application including a fly back to launch 

point to terminate the flight. Since hobbyists are not required to have a pilot license, Roger Conatser 

requests exemption for the need of the pilot to be licensed as a pilot by the FAA. 
•Detection of lost GPS or of insufficient satellites initiates an immediate return to launch location. 

• Low power on the aircraft triegers escalating afarms at 30% and 15% levels. 

• The aircraft weighs less than five (5) pounds at (1280g), fully loaded. 

Given these safety features, Roger Conatser notes that the FAA has found that safety factors 

permitted operation of UAs by operators with these quaiifications in the case of operations pursuant 

to public COAs where the mandatory operating conditions specified above are present. Please see 

Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational 

Approval, at 20-21(July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) 

to waive the pilot requirements for commerciat operations. Given these conditions and restrictions, 

an equivalent level of safety will be provided by allowing operation of Roger Conatser UAs without a 

private or commercial pilot's license, under the conditions set forth herein. The risks associated with 

the operation of Roger Conatser UAs (given its size, speed, operational capabilities, and lack of 

combustible fuel) are so diminished from the level of risk associated with private pilot operations or 

commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), 

that allowing operations of the UAs as set forth above meets or exceeds the present level of safety 

provided under 14 C.P.R. § 61.113(a) &(b) and does not rise to the level of requiring a commercial 

pilot to operate the aircraft under §61.133(a). 

Sections 61.113 (a) &(b) limit private pilots to non-commercial operations. Because the UAs will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PILOT operating the aircraft to have a private pilot's license rather 

than a commercial pilot's license to operate these small UAs. Unlike a conventional aircraft that 

carries the pilot and passengers, the UAs are remotely controlled with no living thing on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated in advance. 

The level of safety provided by Roger Conatser exceeds that provided by a single individual hofding a 

private or commercial pilot's certificate operating a conventional aircraft. The risks associated with 

the operation of the UAs are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the UAs as requested 

with a private pilot as the PILOT exceeds the present level of safety achieved by 14 C.P.R. §61.113 (a) 

& (b). 

14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS 
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements for maintenance and use of safety check lists prior to each flight. 

14 C.F.R. § 91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT 

Section 91.9 (b) (2) provides: No person may operate a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in 

the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAs, given their size and configuration has no 

ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, 

but because there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping at the ground control point where the pilot 

flying the UAs will have immediate access to it. The FAA has issued the following exemptions to this 

regulation: Please see FAA Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167A, 10602,32827, and 10700. 

14 C.F.R. § 91.103: PREFLIGHT ACTION 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. An equivalent level of safety will be provided. The PILOT will take all actions including 

reviewing weather, flight battery requirements, landing and takeofF distances and aircraft performance 

data before initiation of flight. 

14 C.F.R. §91.109: FLIGHT INSTRUCTION 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. UAs and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. Please see FAA 

Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided as neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft. 
14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for UAs that are a heficopter and the exemption requests authority to operate at altitudes up to three 

hundred (300) feet AGL, an exemption may be needed to allow such operations. As set forth herein, 

except for the limited conditions, the UAs will never operate at higher than four hundred (400) feet AGL. 

It will however be operated in a restricted area with security perimeter, where buildings and people will 

not be exposed to operations without their pertained consent 

The equivalent level of safety will be achieved given the size, weight, speed of the UAs as well as the 

location where it is operated. No flight will be taken without the permission of the property owner or 

local officials. Because of the advance notice to the property owner(s), or their authorized 

representative(s), all affected individuals will be aware of the planned flight operations. When one 

compares the flight operations proposed herein with aircraft or rotorcraft weighing far in excess of the 

less than five ( 5) pounds at (1280g) and the lack of flammable fuel, any risk associated with these 

proposed operations is far less than those presently presented with conventional aircraft operating at or 

below five hundred (500) feet AGL. In addition, the low altitude operations of the UAs will ensure 

separation between these small UAs operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

14 C.F.R. §91.121 ALTIMETER SETTINGS 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the UA may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 
Section 91.151 (a) prohibits an individual from beginning "a fiight in an airplane under VFR conditions 

uniess (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing, and, assuming normal cruising speed- 

(1) During the day, to fiy after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes." Roger Conatser beiieves that an equivalent level of 

safety can be achieved by limiting flights to fifteen (15) minutes or thirty percent (30%) of battery power 

whichever happens first. This restriction would be more than adequate to return the UAs to their 

pianned landing zone from anywhere in its limited operating area. Similar exemptions have been 

granted to other operations, inciuding Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (A) AND (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION 

The reguiation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) an appropriate and current airworthiness certificate.... 

(b) No person may operate a civil aircraft uniess the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is dispiayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew. 

The UAs fully loaded weieht is no ereater than five (5) pounds at (1280g) and is operated without an 

onboard pilot. As such, there is no abiiity or piace to carry certification and reeistration documents or 

to_dispiay them on the UA. An eguivalent level of safety will be achieved by keeping these documents 

at the ground control point where the piiot flying the UA wiil have immediate access to them to the 

extent they are appiicabie to the UA. The FAA has issued numerous exemptions to this reguiation. A 

representative sampie of other exceptions inciudes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 

9797A, 9816A, and 10700. 

14 C.F.R._§91.405 (A); 407 {A) (1); 409 (A) (2); 4171A) &(B): MAINTENANCE INSPECTIONS 
These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," 

and others shall inspect or maintain the aircraft in compliance with Part 43 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Roger Conatser. Maintenance will be accomplished by the operator pursuant 

to the flight manual and operating handbook. An equivalent level of safety will be achieved because 

these small U As are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If inechanical issues arise the UAs may land immediately and will be 

operating from no higher than four hundred (400) feet AGL. The operator will ensure that the UAs are in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.. 

Pursuant to 14 C.F R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed Roger Conatser seeks an exemption from the 

following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) &(b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) 

(2); 91.409 (a) (2) and 91.417 (a) &(b) to operate commercially a small unmanned vehicle weighing less 

than fifty-five (55) pounds (25 Kg) in its operations. 

Approval of exemptions allowing commercial operations of UAs in the purposes outlined above (or 

similar operations) will enhance safety by reducing risk. Conventional aerial videography and 

photography operations, using jet or piston power aircraft, operate at extremely low altitudes just feet 

from the object being photographed and often in extreme proximity to people and structures; and 

present the risks associated with vehicles that weigh in the neighborhood of four thousand (4,000) 

pounds, carrying large amounts of jet A or other fuel (one hundred and forty (140) gailons forjet 

helicopters). Such aircraft must fly to and from the site's location. In contrast, a UA weighing less than 

five (5) pounds at (1280g) and powered by batteries eliminates virtually all of that risk given the reduced 

mass and lack of combustible fuel carried on board. The UA is carried to the site of the purposes 

outlined above (or similar operations) and not flown to the site. The UA will carry no passengers or crew 

and, therefore, will not expose them to the risks associated with manned aircraft flights. 

The operation of small UAs, weighing less than five (5) pounds at (1280g), conducted in the strict 

conditions outiined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting Roger Conatser from the requirements 
of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close 

to the ground, and in a sterile environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and people. 

PRIVACY 

AII flights will occur over private, controlled or approved property with the property owner's, or their 

authorized representative, prior consent and knowledge. The aerial videography and photography will 

be of structures and property whose owner, or authorized representative, has consented to the aerial 

videography and photography or otherwise have agreed to be in the area where aerial videography and 

photography will take place. The grant of this exemption request will provide improved safety in all 

operations. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012- size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security- provide more than adequate justification for the granting of the requested 

exemptions allowing commercial operation of Roger Conatser Photography's UAs. 

SUMMARY OF ROGER CONATSER'S REQUEST FOR AN FAA EXEMPTION 

1. Roger Conatser UAs must weigh less than five (5) pounds at (1280g), including energy source(s) and 

equipment. Operations authorized by the grant of an exemption are limited to the following aircraft: 

Roger Conatser UA aircraft variant, bearing serial # P79DCG28020288Any proposed operations of any 

other aircraft will require a new petition or a petition to amend this grant. 

2. Roger Conatser UAs may not be flown at a ground speed exceeding thirty (30) knots. 

3. Roger Conatser flights must be operated at an altitude of no more than Four hundred (400) feet 

above ground level (AGL), as indicated by the procedures. AII altitudes reported to ATC must be in feet 

AG L. 

4. Roger Conatser UAs must be operated within the VLOS of the PILOT at all times. This requires the 

PILOT to be able to use human vision unaided by any device other than corrective lenses. 
5. AII Roger Conatser operations must utilize a VO. The VO may be used to satisfy the VLOS requirement 

as long as the PILOT always maintains VLOS capability. The VO and PILOT must be able to communicate 

verbally at all times. 

6. Prior to each flight the PILOT must inspect the UA to ensure it is in a condition for safe flight. If the 

inspection reveals a condition that affects the safe operation of the UA, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the UA is found to be in a condition 

for safe flight. A Ground Control Station, if utilized, must be included. in the preflight inspection. AII 

maintenance and alterations must be properly documented in the aircraft records. 

7. Any UA that has undergone maintenance or alterations that affect the UA's operation or flight 

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

PILOT who conducts the functional test flight must make an entry in the UA's aircraft records of the 

flight. 

8. Roger Conatser must follow the manufacturer's UA aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be 

established and identified. At a minimum, requirements for the following may be included in protocols 

and controls to be established by Roger Conatser: 

a. Actuators/Servos; 

b. Transmission (single rotor); 

c. Power plant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

I. Ground control station (if used); and 

J. Any other components as determined by Roger Conatser. 

9. Prior to operations conducted for the purposes outlined above (or similar operations), the PILOT must 

have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of twenty-five 

(25) hours of total time as a UA rotorcraft pilot (single blade or multirotor) and at least ten (10) hours 

logged as a UA pilot with multi -rotor U A which is similar to the UA to be utilized pursuant to this 

exemption. Prior documented flight experience that was obtained in compliance with applicable 

regulations may satisfy this requirement. Training, 
proficiency, and experience-building flights must be conducted under an exemption to accomplish the 

required flight cycles and flight time. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PILOT must operate 

the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

10. Prior to operations conducted for the purposes outlined above (or similar operations), the PILOT 

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a minimum of five 

(5) hours as a UA pilot operating the make and model of UAs to be utilized for operations under the 

exemption and three (3) take-offs and three (3) landings in the preceding ninety (90) days. Training — 

proficiency, experience-building, and take-off and landing currency flights can be conducted under the 

grant of exemption to accomplish the required flight time and ninety (90) day currency. During training, 

proficiency, experience-building, and take-off and landing currency flights all persons not essential for 

flight operations are considered nonparticipants, and the PILOT must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

11. Roger Conatser shall not permit the PILOT to operate the UAS for the purpose of aerial videography 

or photography (or similar operations), unless the PILOT has demonstrated and logged in a manner 

consistent with 14 CFR 61.51(b), the ability to safely operate the UAS in a manner consistent with how 

the UAS will be operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

12. The UA may not be operated directly over any person, except authorized and consenting personnel 

and persons, below an altitude that is hazardous to persons or property on the surface in the event of a 

UA's failure or an emergency. 

13. At all times, those persons must be essential to the purposes outlined above (or similar operations). 

Because these procedures are specific to participating persons, no further FSDO or aviation safety 

inspector approval is necessary for reductions to the distances specified in Roger Conatser manuals. 

14. Roger Conatser flight operations must be conducted safely away from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

of the UA, flight operations must cease immediately and/or; 
b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PILOT has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an undue 

hazard, and; 

c. Operations nearer to the PILOT, VO, operator trainees or essential persons do not present 

an undue hazard to those persons per§ 91.119(a). 

15. If the UAs lose communications or loses its GPS signal, the UAs must return to a predetermined 

location within the security perimeter and land or be recovered. 

16. The UAs must abort the flight in the event of unpredicted obstacles or emergencies. 

17. Each UA operation must be completed within twenty (20) minutes flight time or with twenty-five 

percent (25%) battery power remaining, whichever occurs first. 

18. Roger Conatser must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA will also 

require Roger Conatser to request a Notice to Airman (NOT AM) not more than seventy-two (72) hours 

in advance, but not less than forty eight ( 48) hours prior to the operation. 

19. AII aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

20. Roger Conatser has developed procedures to document and maintain a record of the UA`s 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, 

and the total time in service of the UAs. 

21. Each UA operated under this exemption must comply with all manufacturer Safety Bulletins. 

22. The preflight inspection section in Roger Conatser Confidential Protocols and Controis Exhibit 

includes the following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection. 
23. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

24. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PILOT at the 

Ground Control Station, if utilized, of the UA at any time the UA is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

25. Roger Conatser UAs must remain clear and yield the right of way to all other manned operations and 

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

activities, hang gliders, etc.). 

26. Roger Conatser UA operations may not be conducted during night, as defined in 14 CFR § 1.1. AI1 

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

flight rules (SVFR) are not authorized. 

27. Roger Conatser UAs may not be operated by the PILOT from any moving device or vehicle. 

28. Roger Conatser UAs may not be operated less than five-hundred (500) feet below or less than twothousand (2,000) feet horizontally from a cloud or when visibility is less than three (3) statute miles from 

the PILOT. 

29. Roger Conatser UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within five (5) nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a NOT AM as 

required by the UAV Dudes LLC COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request. 

30. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UA Integration Office 

(AFS-80) within twenty-four (24) hours. Accidents must be reported to the National Transportation 

Safety Board (NTSB) per instructions contained on the NTSB Web site: w ww.ntsb.gov. 

31. Roger Conatser UAs, the UA's PILOT, and the UA's operations must comply with all applicable parts 

of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

As mentioned above, the FAA has already granted a previous exemptions which are essentially identical 

to the exemption being sought by Roger Conatser in this petition for an exemption.