June 30, 2015

Exemption No. 11949 Regulatory Docket No. FAA

– 20 15

– 1416

Mr. Shaun Galang Cedarmeade Studios, LLC

429 Beechcroft Road Winchester, VA 22601

Dear Mr. Galang :

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated April 21, 2015 , you pe titioned the Federal Aviation Administration (FAA) on

behalf of Cedarmeade Studios, LLC ( hereinafter petitioner or operator ) for an exemption. The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct real estate/ architecture, mark eting, surveying/ mapping, industrial surveying, sporting events, and special events/ festivals operations

.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

aircraft and its operation, the Secretary of Transportation has determined that this aircraft

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from

14 CFR part 21

, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 20 14

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the peti tioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public i nterest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and

11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest.

Ther efore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Cedarmeade Studios, LLC is granted an exemption

from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a)

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (p articulate measurement, etc.), or any other gathering of data by

instruments aboard the UA.3

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data

collection. This exemption is subject to the conditions and limi tations listed below.

Conditions and Limitations

In this grant of exemption, Cedarmeade Studios, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion picture and television filming are

not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may us e either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the

aircraft manufacturer.

4. The UA must b e operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA 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.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLO S) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all document s needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS opera tions and made available to the4

Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and r evised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any up date or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conduc ting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at

least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue h azard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the

UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g.

, inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibi ted from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements fo r the aircraft and

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pil ot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner c onsistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons n ot essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS 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.

16. The UA may not operate 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 symbo l as denoted on the current

FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or o therwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below o r less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a

pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucte d in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.6

22. All 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.

23. Documents used by the operator to ensure the safe operation and flight of the UAS 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 UAS any time the aircraft is operating.

These documents must be made available to the Adm inistrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and

activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operatio ns must be conducted at least 500 feet 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 and are within 500 feet of the UA, flight operations must cease immediately in a manner ensur ing the safety of nonparticipating persons ; and

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objec ts and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight op eration that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported

to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

.7

If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this
exempt ion must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities

must incl ude at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS;

d. Ma ke, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city,
town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming productio n, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to,
parts 45, 47, 61, and 91.8

This exemption terminates on July 31, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

EnclosuresTuesday, April 21, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

by/for Cedarmeade Studios, LLC

429 Beechcroft Road Winchester, VA 22601

RE: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam,

This petition is being submitted with no legal counsel or consulting services.

This document constitutes an exemption Request under Section 333 of the

FAA Modernization and Reform Act of 2012 for Aviation Unmanned to perform Aerial Photography by/for Cedarmeade Studios, LLC. The main use of this UAS would be obtaining aerial video and still images for clients (categories listed below) and obtaining aerial still images for sale to the general public through online galleries. The UAS systems that I plan to use is a DJI Inspire 1 and will be referenced in this document and also in the

attached user manual.

The requested exemption would permit Cedarmeade Studios, LLC to pursue its commercial interests in providing services to clients using a small advanced UAS in the following areas:

• Real Estate /Architecture

• Marketing

• Surveying /Mapping

• Industrial Surveying

• Sporting Events

• Special Events /Festivals

Page of 1 8Regulations from which exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23(b) 14 C.F.R. 91.7(a) 14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

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. 91.401 – 91.417

Unmanned Aircraft System UAS are often seen as superior to helicopters as an aerial video gathering platform due to the smaller devices, more affordable equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety.

Cedarmeade Studios, LLC is petitioning for an exemption to operate a DJI Inspire 1 with a built-in stabilized HD camera and the following GPS safety

features :

• Restricts the height above ground level (AGL) to a specified usergenerated height.

• Restricts the radius of flight from the ground station to a user-generated

radius.

• Restricts operations within designated Class B, C and D airspace including a no-fly zone feature.

The DJI Inspire 1 also has a failsafe function that is triggered in the event

communications are lost between the UAS and the main controller transmitter. In the unlikely event this occurs, the UAS will return to its point of takeoff and land safety. If communications are restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards (AC 91-57) as set below:

1. The petitioner will only operate its UAS in line-of-sight of a pilot and/or observer and will operate at sites that are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations will ensure that the UAS will “not create a hazard to users of the national airspace system or the public.” The orientation of flights will

Page of 2 8be such that the pilot in command (PIC) always has a visual on the rear mounted LED flight Indicator. Additional safety features on the DJI Inspire 1 include, return to home, low battery energy level, enhanced failsafe along with operating in the less populated 5.8 GHZ frequency

range.

2. When flying the UAS within three (3) miles of an airport, airport operators will be notified and the operator will give the right-of-way to avoid flying in the proximity of full-scale aircraft.

3. Pre-flight inspection would be checking battery condition/level in both the transmitter and UAS, a visual/operational check of the propellers, a visual/operational check of the aircraft, a visual/operational check of the motors, a full compass and IMU calibration, a visual/operational check of the transmitting radio control unit, a visual/operational check of the camera and gimbal unit and a visual/operational check of the vision positioning system. A check for power-lines, antennas and other overhead objects would also be performed. Wind conditions would be monitored and be a factor for flying.

4. The radio frequency of the DJI Inspire 1 is in 5.725~5.825 GHz range the FC350 camera 2.400~2.483 GHz. Maximum take-off weight approximately 3000g. Max Ascent/decent speed 5 m/s. Maximum flight Velocity 22 m/s. The UAS operated by the petitioner weighs less than 15 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

5. The PIC will be only myself and I have a minimum of 55 hours flying time with DJI equipment, approximately 10 of those hours with this specific model (DJI Inspire 1). I’m a freelance video producer and photographer with over 10 years of photography/videography experience. Testing, updating and programming the DJI Inspire 1 firmware would be done on a monthly schedule

. 6. Flights will be terminated when battery energy levels reach 25%, allowing sufficient reserve flight time to safely land the UAS.

7. The UAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more than 150 feet above a significantly elevated geographic position from which videography/ photography is planned.

8. I’m in good medical health and sound mental health with no arrests or

felonies.

9. The intended use of this DJI Inspire 1 is to supplement my existing photography business with aerial photographs and video. The aerial vantage point/perspective would allow my studio to provide a service to local advertising clients that is different/unique and competitive.

Page of 3 810. All photo/video flights would have the date, time, GPS coordinates along

with the camera metadata recorded in an in-app flight log on the mobile device serving as the in-flight monitor. This flight log records flight path, altitude, flight time, number of images shot, amount of video shot, date, time, and total flight distance. Each individual flight has the capability of playing back (in-app) in real time and is synced across devices via DJI’s in-app User Center.

11. Given the small size of the UAS and the restricted sterile environment within which it will operate, Cedarmeade Studios, LLC’s operations will adhere to the Reform Act’s safety requirements.

12. The DJI Inspire 1 will never be flown in the flight path of manned aircraft. with the first condition listed, always keeping a visual line of sight, being of utmost importance to providing a significant level of public safety.

I respectfully request exemption under Section 333 to enable Cedarmeade Studios, LLC to operate efficient, limited, low-risk commercial UAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.

Respectfully,

Cedarmeade Studios, LLC

429 Beechcroft Road Winchester, VA 22601 Home/Cell: (540)533-3775

www.cedarmeadestudios.com

Page of 4 8EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY Cedarmeade Studios, LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the UAS System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the DJI Inspire 1 under either, or both, of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS

Page of 5 8does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in a placard on the top of the aircraft where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation.

Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or

banner that contains the words "Unmanned Aircraft Ground Station" in letters adhering to the specifications of at least 2 inches and less than 6 inches. Since the aircraft will operate in close proximity (not more than 1/2 NM) to the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 91.7 Prohibits the Operation of an aircraft without an

airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 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. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that the manual be kept in a digital format on a mobile device at the ground station. A hard copy will also be kept inside the equipment carrying case ( in the event the digital version is unavailable ) and available to the crew at the ground station anytime the aircraft is in, or preparing for, flight

.

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the UAS would be photography or survey of persons, vessels, vehicles or structures it would, at times, be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful

Page of 6 8pre-planning has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The UAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAS on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 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 pointof intended landing and to fly after that for at least 30 minutes and nightVFR conditions an additional 45 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAS is battery operated and the maximum duration of flight from a single battery charge is approximately 15 minutes with an additional 25% reserve. Since the aircraft will never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. The PIC has a visual reference to the remaining battery energy level and an estimated “return to home” energy requirement. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." At a maximum gross weight of 5.3 pounds, the UAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control station and available for inspection upon request. In order to identify the aircraft, we propose that the information

Page of 7 8found on airworthiness and registration certificates be permanently affixed to the aircraft containing such information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E 91.401- 91.417 - Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 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. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the

aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on-board computer. All other maintenance will be performed by the manufacturer or a

manufacturer- designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

Page of 8 8