U.S.	Department	of	Transportation Docket	Operations West	Building	Ground	Floor	Room	W12

- 140 1200	New	Jersey	Avenue	SE Washington,	D.C.	20590

Re:		Exemption	petition	to	operate	various	UAS	systems	for	commercial	purposes.

Dear	Sir	or	Madam,

Pursuant	to Section	333	of	the	FAA	Modernization	and	Reform	Act	and	14	sections

11.61

- 11.103,	Control	1	Communications,	LLC	hereby	petitions	for	an	exemption allowing	commercial	aerial videogr aphy	and	photography using	small	Unmanned Aerial	Systems	(UAS)

. Control	1	C ommunications	reques ts	exemptions	from	several

Federal Aviation	Regulations	(F.A.R.s)	as	detailed	in	Section	2	of	the	following	text. An	exemption	would	allow	Control	1	Communications,	LLC	to	utilize this	new technology	to	further	it’s	ability	to	bring	c r eative	and	innovative	photographs	and video	to	the	public. Specifically,	an	exemption	would	allow	Control	1 Communications,	LLC	to	survey,	record	and	broadcast	aerial	footage	for	it’s	clients. Control	1	Communications,	LLC	proposes	to	utilize	2	types	of UAS	systems	(DJI Inspire	1	and	DJI	Spreading	Wings	1000+)	for	aerial	video	and	photography	work	of real	estate	properties	around	the	suburban	Charlotte,	NC	and	surrounding	areas. All	proposed	operations	of	UAS	vehicles	will	be	within	both	the	manufactur er’s prescribed	recommendations	for	the	specific	UAS	model	and	any	additional restrictions	or	regulations	set	forth	by	the	FAA.			Additionally,	all	Pilot(s)	in Command	(PICs)	shall	hold	as	a	minimum	a	sport	pilot	class	(or	higher)	license	and

either	a	curr ent	third	class FAA me dical	certificate	or	a	valid	US	driver’s	license (if	in possession	of	a	Sport	Pilot’s	License)

. All	PICs	will	also	have	as	a	minimum	25	hours of	UAS	flight	time	and	a	minimum	of	10	hours’	flight	time	with	the	type	UAS	to	be

used	comm ercially. Additionally,	all	flights	will	be conducted	during	daylight times. The	PIC	shall	maintain	visual	line	of	sight	(LOS)	with	the	UAS	at	all	times. The	PIC will	work	in	tandem	with	an	Observer	to	facilitate	safe	operation	of	the	UAS.		The

PIC	an d	Observer	will	have	voice	communication	by	way	of 2	way	hands	free radio link	at	all	times	the	UAS	is	in	flight.			No	flights	will	be	conducted	over	crowds	of people,	or	over	private	property	without	the	appropriate	permission	from	the properties’	owners or	agents.		Flights	will	not	exceed	400’	alt itude	AGL,	nor	50	knots in	speed

. The	aircraft’s	battery	status	shall	be	monitored	while	in	flight	via telemetry	from	the	aircraft	to	the	contr oller	to	ensure	the	battery charge	is	adequate

to	allow	safe	recov ery	and	landing	of	the	UAS.		The	UAS	will	not	be	operated	at	less than	25%	battery	capacity. Control	1	Communications,	LLC	requests	exemptions for	the	following	aircraft :		DJI	Inspire	1, and	DJI	Spreading	Wings	1000+.

Section	1:		Contact	informat ion:Control	1	Communications,	LLC Attention:	Christopher	Kelley

3525	Centre	Circle Fort	Mill,	SC	29715
chris@control1comm.com

Section	2:		Sections	from	which	exemptions	are	requested:

14	C.F.R.	Part	21,	S ubpart	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	r equired	by	FAR	§91.203	(a)	(1).		Control	1

Communicat ions,	LLC	requests	an	exemption	from	this	regulation	on	the	basis	that: A;	the	UAS	cannot	present	a	danger	to	it’s	pilot	or	passengers	as	it	carries	no	living things	onboard	and	B;	the	small	mass	(under	55lbs	gross	takeoff	weight)	and	the

fact	that	it	carr ies	no	flammable	fuel	renders	it	a	far	lesser	danger	to	ground	based personnel	or	objects	in	the	event	of	an	in

- air	system	failure than	that	of	a	larger

manned	aircraft

. Control	1	Communications	LLC	believes	this	will	give	an equivalent	level	of	safety	to that	of	a	larger	manned	aircraft’s	regulation	under	this

part.

14	C.F.R.	§	45.23 (b).	Marking	of	the	Aircraft

The	regulation	states:

(b) “ When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration

number	is displayed	on	limited,	restr icted	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	inc hes	high,	the	words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or "provisional,"	as	applicable.”

The	UAS	in	question	have	no	cabin,	therefore	no	location	to	display	the	prescribed signage,	therefore	an	exemption is	requested.		The	word	“EXPER I MENTAL” will	be displayed	on	the	UAS’s	fuselage	utilizing	letter	as	large	as	practicable.		This	gives	an equivalent	level	of	saftey	in	that	the	Pilot	and	others	working	with	the	UAS	will clearly	see	the	marking.			The	FAA	has	issued	the	following	exemptio ns	to	this regulation	to	Exemptions	Nos.	10700,	8738,	10167	and	10167A.14	C.F.R.	§	45.29		(3)		Size	of	Marks

The	regulation	states:

“ Rotorcraft,	must	be	at	least	12	inches	high,	except	that	rotorcraft	displaying	before April	18,	1983,	marks	required	by §45.29(b)(3)	in	effect	on	April	17,	1983,	and rotorcraft	manufactured	on	or	after	April	18,	1983,	but	before	December	31,	1983, may	display	those	marks	until	the	aircraft	is	repainted	or	the	marks	are	repainted, restored,	or	changed.”

Due	to	the	small	si ze	of	the	UAS,	it	will	not	be	possible	to	mark	the	aircraft	using letters	of	the	size	prescribed	within	this	regulation.		Therefore	an	exemption	is requested.		The	equivalent	level	of	safety	will	provided	by	marking	the	UAS’s registration	(“N”	number)	util izing	letting	as	large	as	practicable	for	the	UAS.		This will	provide	a	clear	and	immediate	method	of	identifying	the	UAS’s	registration	in keeping	with	the	intent	of	this	regulation.

14	C.F.R.	§	61 .113 :	Private	Pilot	Privileges	and	Limitations:	Pilot in	Command

Section	61	establishes	the	certification	requirements	for	pilots. Section	61.113
states	“ §	61.113	Private	pilot	privileges	and	limitations:	Pilot	in	command. (a) Except	as	provided	in	paragraphs	(b)	through	(h)	of	this	section,	no	person

who	hold s	a	private	pilot	certificate	may	act	as	pilot	in	command	of	an aircraft	that	is	carrying	passengers	or	property	for	compensation	or	hire;	nor may	that	person,	for	compensation	or	hire,	act	as	pilot	in	command	of	an

aircraft. An	exemption	is	requested	to allow	a	PIC	licensed	holding	a	Sport	Pilot	License	or higher,	along	with	the	prescribed	Medical	Certificate	appropriate	to	that	license’s requirement	(or	valid	U.S.	issued	Driver’s	License,	in	the	case	of	a	Sport	Pilot License),	to	operate	the	UAS	in	comme rcial	activity.		The	equivalent	level	of	safety will	be	provided	in	that	the	UAS	carries	no	living	thing,	property	for	hire	(transport),

and	h as	a	mass	less	than	55lbs.			In	this	the	safety	factor	is	greater	than	utilizing	a manned	aircraft	in	the	same	cap acity.

14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness.

The	regulation	states:

“(a)	No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.	“

As	there	is	no	certificate	of airworthiness	issued	for	the	UAS	in	question,	an

e xemption	is	requested	from	this	regulation	insofar	as	the	regulation	requires	a “certificate	of	airworthiness”.		Should	this	petition	be	granted,	currently	no airworthiness	certification	exists	for	the	UAS	in	question,	thereby	obtaining	an

airworthiness	ce rtificate	is	not	currently	possible.		An	equivalent	level	of	safety	willbe	achieved	by	compliance	with	section	91.7	(b),	preflight	checks,	and	compliance with	the	manufacturer’s	recommended	maintenance	practices.

§91.9 (b)	(2) Civil	aircraft	flight	ma nual,	marking,	and	placard	requirements.

The	regulation	states:

“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.”

An	exemption	is	requested	with	regard	to	this	regulation.		Due	to	the	small	size	of the	UAS	and	the	fact	that	it	has	no	cabin	and	carries	no	pilot	or	passenger(s),	there	is

n either	the	carrying	capacity	nor	place	for	such	Flight	Manual.		An	equivalent	level of	safety	will	be	provided	by	maintaining	the	Flight	Manual	for	the	UAS	at	the

control	location	so	that	the	PIC	has	immediate	access	to	it.

14	C.F.R.	§	91.103		Preflight action

The	regulation	states:

“Each	pilot	in	command	shall,	before	beginning	a	flight,	become	familiar	with	all available	information	concerning	that	flight.	This	information	must	include

—

(a)	For	a	flight	under	IFR	or	a	flight	not	in	the	vicinity	of	an	a irport,	weather	reports and	forecasts,	fuel	requirements,	alternatives	available	if	the	planned	flight	cannot be	completed,	and	any	known	traffic	delays	of	which	the	pilot	in	command	has	been advised	by	ATC;

(b)	For	any	flight,	runway	lengths	at	airports of	intended	use,	and	the	following takeoff	and	landing	distance	information:

(1)	For	civil	aircraft	for	which	an	approved	Airplane	or	Rotorcraft	Flight	Manual containing	takeoff	and	landing	distance	data	is	required,	the	takeoff	and	landing

distance	data contained	therein;	and

(2)	For	civil	aircraft	other	than	those	specified	in	paragraph	(b)(1)	of	this	section, other	reliable	information	appropriate	to	the	aircraft,	relating	to	aircraftperformance	under	expected	values	of	airport	elevation	and	runway	slo pe,	aircraft gross	weight,	and	wind	and	temperature.	“

As	FAA	approves	flight	manuals	do	not	exist	for	the	UAS	in	question,	an	exemption	is requested	from	section	91.103	(b)	(1).		The	equivalent	level	of	safety	shall	be provided	by	utilizing	the	manufactur er’s	recommendations	regarding	preflight checks	for	the	UAS,	as	well	as	the	regulations	set	forth	in	section	91.103	(a).

14	C.F.R.	§91.109		Flight	instruction:

Section	91.103	regulates	that	no	person	may	operate	a	civil	aircraft	(except	a

manned	free	ba lloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has fully	functioning	dual	controls.

As	the	UAS	is operated	by	a	single	remote	radio	frequency	controller,	dual	controls

are	no t available.		Thereby	an	exemption	from	this	portion	of	th e	regulation requiring	dual	flight	controls	for	the	purpose	of	flight	instruction	is	requested.		An equivalent	level	of	safety	is	provided	in	that	the	UAS	carries	no	people	and	has	a relatively	small	mass	and	operates	at	a	low	speed	compared	to	manned	airc raft. In addition	the	UAS	has	a	GPS	based	“return	to	home/	auto	land”	failsafe	system	in	the event	of	loss	of	the	controller’s	RF	signal.

14	C.F.R.	§91.119		Minimum	safe	altitudes

The	regulation	states:

Except	when	necessary	for	takeoff	or	landing,	n o	person	may	operate	an	aircraft below	the	following	altitudes: (a) Anywhere. An	altitude	allowing,	if	a	power	unit	fails,	an	emergency	landing without	undue	hazard	to	persons	or	property	on	the	surface. (b) Over	congested	areas. Over	any	congested	area	o f	a	city,	town,	or	settlement,	or over	any	open	air	assembly	of	persons,	an	altitude	of	1,000	feet	above	the	highest obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft. (c) Over	other	than	congested	areas. An	altitude	of	500	feet	above	the surface,	except over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	may	not	be operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or	structure. (d) Helicopters,	powered	parachutes,	and	weight

- shift

- control	aircraft. If	the operation	is	conducted	without	hazard	to	persons	or	property	on	the	surface

— (1)	A	helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in paragraph	(b)	or	(c)	of	this	section,	provided	each	person	operating	the	helicoptercomplies	with	any	ro utes	or	altitudes	specifically	prescribed	for	helicopters	by	the FAA;	and (2)	A	powered	parachute	or	weight

- shift

- control	aircraft	may	be	operated	at	less than	the	minimums	prescribed	in	paragraph	(c)	of	this	section.

An	exemption	is	requested	from	this regulation,	given	that	all	UAS	operations	will take	place	at	an	altitude	of	no	more	than	400’	above	ground	level.		The	equivalent level	of	safety	provided	here	lies	in	that	keeping	the UAS	at	less	than	400’	AGL	is

needed	for the	PIC	to	maintain	visual	line of	sight	with	the	aircraft,	and	aids	in keeping	the	UAS separated	from	manned	aircraft.

14	C.F.R.	§91.121		Altimeter	Settings

As	section	91.121	was	written	in	reference	to	an	aircraft	fitted	with	a	barometric altimeter, and given	that	the	UAS	utilizes	a GPS	based	altimeter,	an	e xemption	may be	needed.		If	so, the	equivalent	level	of	safety	will	be	provided	by	“zeroing”	the UAS’s	altimeter	to	reflect	a	zero	value	at	the	point	of	take	off.		This	will	ensure	the PIC	has	the	ability	to	monitor	his/her craft’ s altitude in	flight and	thereby	ensure	the craft	is	flown	at	an	altitude	of	less	than	400’	AGL.		Furthermore,	software	within	the UAS’s	flight	controls may	be	enabled	to	“soft ware limit”	the	UAS’s	operational	ceiling

at	a	value	less	than	400’	AGL.

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

The	regulation	states:

“ No	person	may	begin	a	flight	in	a	rotorcraft	under	VFR	conditions	unless (considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to	the first	po int	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that

for	at	least	20	minutes.”

An	exemption	is	requested	to	accommodate	the	fact	that	the	average	flight	time provided	by	the	UAS’s	battery	system	is	less	than	20	minutes.		An	equiva lent	level	of safety	will	be	provided	by	conducting	flight	operations	in	such	a	manner	as	to maintain	a	minimum	of	5	minutes’	flying	time	or	landing	with	no	less	than	25% battery	capacity	remaining,	whichever	is	greater.		Given	that	the	UAS	carries	no

livi ng	thing	onboard,	is	of	relatively	small	mass	compared	to	a	manned	aircraft,	and shall	always	remain	within	visual	sight	of	the	PIC,	this	will	provide	an	adequately safe	time	and	battery	capacity	to	safely	land	the	aircraft.14	C.F.R.	§91.203	(a)	and	(b) Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	states:

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

has	within	it	t he	following: (1) An	appropriate	and	current	airworthiness	certificate.	Each	U.S.	airworthiness certificate	used	to	comply	with	this	subparagraph	(except	a	special	flight	permit,	a copy	of	the	applicable	operations	specifications	issued	under	§ 21.197(c) of	this chapter,	appropriate	sections	of	the	air	carrier	manual	required	by	parts 121 and 135	of	this	chapter containing	that	portion	of	the	operations	specifications	issued under	§ 21.197( c) ,	or	an	authorization	under	§ 91.611 )	must	have	on	it	the registration	number	assigned	to	the	aircraft	under	part 47	of	this	chapter .	However, the	airworthiness	certificate	need	not	have	on	it	an	assigned	special	identification number	before	10	days	after	that	number	is	first	affixed	to	the	aircraft.	A	revised airworthiness	certificate	having	on	it an	assigned	special	identification	number,	that has	been	affixed	to	an	aircraft,	may	only	be	obtained	upon	application	to	an	FAA Flight	Standards	district	office. (2) An	effective	U.S.	registration	certificate	issued	to	its	owner	or,	for	operation

within the	United	States,	the	second	copy	of	the	Aircraft	registration	Application	as provided	for	in	§ 47.31(c) ,	or	a	registration	certification	issued	under	the	laws	of	a foreign country. (b) 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.

An	exemption	to	section	91.203	(a)	is	requested	due	to	the	fact	that	airworthiness certificates	are	not	issued	to	the	UAS	in	question.		An	equivalent	level of	safety	will be	provided	by	conducting	maintenance	as	per	the	manufacturer’s recommendations	and	schedule.		A	copy	of	these	maintenance	records	will	be	kept in	the	PIC’s	possession	during	flight	operations. An	exemption	to	91.203	(b)	is	requested	in	t hat there	is	no	cabin	within	the	UAS	to display	an	airworthiness	certificate,	nor	does	it	carry	any	pilots	or	passengers	to view	them.		An	equivalent	level	of	safety	will	be	provided	by	keeping	applicable documents	related	to	the	UAS’s	maintenance	history in	the	possession	of	the	PIC.

14	C.F.R.	§91	sub	part	E Maintenance,	Preventive	Maintenance,	and	Alterations

An	exemption	is	requested	related	to	the	portions	of	section	91	sub	part	E	that requires	maintenance	to	be	performed	by a	certified	mechanic	o r	at	a	certified airframe	repair	station.		Maintenance	will	be	performed	by	the	PIC,	or	others familiar	and	experienced	with	the	type	UAS	to	be	maintained.			Moreover	an exemption	is	requested	for	portions	of	this	regulation	regarding	maintenance	that

may affect	the	aircraft’s	“airworthiness	certificate”.		Given	the	UAS	will	not	be	issuedan	airworthiness	certificate,	portions	of	this	regulation	will	not	apply.		Control	1 Communications,	LLC	will	maintain	the	UAS	in	accordance	with	the	manufacturer’s

recomm endations	and	keep	records	accordingly.		This,	and	the	fact	that	the	UAS	is unmanned,	lightweight,	operates	as	a	low	altitude,	and	capable	of	landing	in	a	small area	should	an	emergency	arise,	will	provide	an	equivalent	level	of	safety.

Section	3:		Publ ic	Interest	Considerations:

Control	1	Communications	believes	the	public’s	interests	will	be	served	by	granting our	request	in	part	by:

1) Increased	s afety	to	those	in	the	vicinity	of	the	UAS’	operation when compared	to	manned	aircraft	videography :		Conventio nal	aerial film/videography	utilizes	manned	aircraft	weighing	thousands	of	pounds.

Recent	advances	in videography	equipment	now	allow similar	film	and videography	using	smaller	cameras	that	can	be	mounted	on	UAS.		These smaller	UAS	provide	a	much	safer	en vironment	for	not	only	the	ground personnel	and	property,	but	also	negates	the	possibility	of	a	pilot	or	other onboard	crew	member	(such	as	a	camera	operator)	being	harmed	in	an accident.		While	injury	or	property	damage	arising	from	a	UAS	accident	is	an

i mportant	con sideration,	it	is	often	safer to	use	these	smaller	systems	when possible	rather	than	a	larger	manned	aircraft. 2) Environmental	concerns:		When	used	in	the	place	of	manned	aircraft	to provide	aerial	photography/	videography,	the	UAS	provides	simi lar	pictures while	maintaining	a	much	smaller	carbon	footprint.		The	UAS	is	battery powered,	thereby	releasing	no	pollutants	into	the	air.		Even	the	batteries	the UAS	systems	utilize	are	considerably	smaller	than	batteries	found	onboard

manned	aircraft. I n	the	event	of	a	crash,	no	petroleum	fuels	will	be	released.

The	risk	of	a	crash

- related	fire	is	greatly	reduced.			Finally,	n oise	pollution from	a	UAS	system	in	significantly	lowe r	than	that	of	a	manned	helicopter

.

Section	4:		Attachments

Submitted	a long	with	this	petition	are	attached	files	from	both	Control	1 Communications,	LLC	and	the	manufacturer	detailing	safe	operation	and

maintenance procedures for	each	of	the	UAS	types	for	which	permission	to	operate commercially	is	requested.

Section	5: Summary for	the	Federal	Register :Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	and	14	sections

11.61

- 11.103,	Control	1	Communications,	LLC	hereby	petitions	for	an	exemption allowing	commercial	aerial	videography	and	photography	using	small	Unmanned

Aerial	S ystems	(UAS).		Control	1	Communications	requests	exemptions	from	several Federal	Aviation	Regulations	(F.A.R.s)	as	detailed	in	Section	2	of	the	following	text. An	exemption	would	allow	Control	1	Communications,	LLC	to	utilize	this	new technology	to	furthe r	it’s	ability	to	bring	creative	and	innovative	photographs	and video	to	the	public. Specifically,	an	exemption	would	allow	Control	1 Communications,	LLC	to	survey,	record	and	broadcast	aerial	footage	for	it’s	clients. Control	1	Communications,	LLC	propo ses	to	utilize	2	types	of	UAS	systems	(DJI Inspire	1	and	DJI	Spreading	Wings	1000+)	for	aerial	video	and	photography	work	of real	estate	properties	around	the	suburban	Charlotte,	NC	and	surrounding	areas. All	proposed	operations	of	UAS	vehicles	will	be within	both	the	manufacturer’s prescribed	recommendations	for	the	specific	UAS	model	and	any	additional restrictions	or	regulations	set	forth	by	the	FAA.			Additionally,	all	Pilot(s)	in Command	(PICs)	shall	hold	as	a	minimum	a	sport	pilot	class	(or	higher) license	and

either	a	current	third	class	FAA	medical	certificate	or	a	valid	US	driver’s	license (if	in possession	of	a	Sport	Pilot’s	License) .		All	PICs	will	also	have	as	a	minimum	25	hours of	UAS	flight	time	and	a	minimum	of	10	hours’	flight	time	with	th e	type	UAS	to	be used	commercially.		Additionally,	all	flights	will	be conducted	during	daylight times. The	PIC	shall	maintain	visual	line	of	sight	(LOS)	with	the	UAS	at	all	times. The	PIC will	work	in	tandem	with	an	Observer	to	facilitate	safe	operati on	of	the	UAS.		The PIC	and	Observer	will	have	voice	communication	by	way	of 2	way	hands	free radio link	at	all	times	the	UAS	is	in	flight.			No	flights	will	be	conducted	over	crowds	of people,	or	over	private	property	without	the	appropriate	permission	fr om	the properties’	owners	or	agents.		Flights	will	not	exceed	400’	alt itude	AGL,	nor	50	knots in	speed

. The	aircraft’s	battery	status	shall	be	monitored	while	in	flight	via telemetry	from	the	aircraft	to	the	contr oller	to	ensure	the	battery charge	is	ad equate to	allow	safe	recovery	and	landing	of	the	UAS.		The	UAS	will	not	be	operated	at	less than	25%	battery	capacity.							Control	1	Communications,	LLC	requests	exemptions for	the	following	aircraft :		DJI	Inspire	1, and	DJI	Spreading	Wings	1000+.

Con trol	1	Communications,	LLC	requests	exemptions	from	the	following regulations:

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

Requirement	of	airworthiness	certificate

.

- 14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft

Requirement	for	aircraft’s	cabin	to	be	marked

.

- 14	C.F.R.	§	45.29		(3)		Size	of	Marks

UAS	too	small	to	comply	with	letter/	number	size	requirement

.- 14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command

Request	to	allow	non

- commer cial	pilot	license	holder	conduct	for

- profit	UAS

operations.

- 14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness

Request	exemption	as	no	current	airworthiness	certificates	for	UAS	exist

.

- §91.9	(b)	(2) Civil	aircraft	flight	manual,	marking,	and	placard	re quirements.

UAS	unable	to	carry	an	onboard	flight	manual

.

- 14	C.F.R.	§	91.103		Preflight	action

UAS	unable	to	carry	a	pre

- flight	manual

.

- 14	C.F.R.	§91.109		Flight	instruction

request	exemption	from	dual

- control	mandate	for	the	UAS

.

- 14	C.F.R.	§91.119		Min imum	safe	altitudes

Request	that	UAS	be	authorized	to	operate	under	minimum	safe	altitude	regulations.

- 14	C.F.R.	§91.121		Altimeter	Settings

UAS	use	a	GPS	altimeter	rather	than	a	barometric	altimeter

.

- 14	C.F.R.	§	91.151(b)		Fuel	Requirements	for	Flight	i n	VFR	Conditions

Request	exemption	to	allow	UAS	to	be	operated	with	less	than	20	minutes’	fuel	reserve.

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

Request	an	exemption	due	to	the	fact	that	an	airworthiness	certif icate	will	not	be issued	for	the	UAS,	nor	is	there	a	cabin	in	which	to	display	it.

- 14	C.F.R.	§91	sub	part	E Maintenance,	Preventive	Maintenance,	and	Alterations

Request	an	exemption	from	requiring	a	certified	mechanic/	certified	airframe	shop	to perfor m	maintenance	in	UAS.Sincerely,

Christopher	Kelley

- managing	member Control	1	Communications,	LLC