UA V Certification, LLC 

100 Ha14 Drnc • \1)111< ll<a<h, SC 29519• !'hone: :IQ-L 119.'~111 • h.: :!<12.90.).0.'1.~7 

i:, \1ad: jOhn ~«'rtlftc.t.OOnJ.k-.rom \\ ·~b: """"'.WI\TCrtlfKalKH~:.t"UCH 

( ktol><:J 1!1!, 2015 

I Ionorahlc Michael lluena, Admini;u;uor 

Fcclcml A' ialion Ad l"ninistration 

t · .S. Dcpal'tJncnt ofTransportaLic>•• 

Dorkel t:u m~emcnt System 

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liA V Ccnilir;IIJou, I.I.C, (l'ctitioncr) • Delaware limited liability ~Oilll""'l' hereby applie< lm "" nempuou from the 

listed FcdcraJ A,-i:ttjuu llcgulaLious ('"F'AH, ") tu allcm i1 to opt'I':Ue a ~mall umrumed .\i1 <'1 ah ~y~h.·•n ("s l ·AS"') under 

the <·onclitioltl't and litl'litmion.s set ((wt.h in tl1 ~ Jlc1ition. 

Applicoull Jw·thcr l'CCJUCsts consideration fot a .. SumuliU ~ C ro;ml " a\ lJiis petition i-. iclcntkal to the followiuJ,;" petitions: 

• In tftt• 1/WII<'t ol Lhig ~ Bry7ut. Cirru_, fUcgu/,1/m} /)()('k<'l .\'o. J-:4.4-2015-01 60. £\emptiont»tt<'tl , \pt if 20. 201 5) 

-1u tlt< fiWII<"rol Oougi.1S Tivde.1u. He.'litot (llctrul.Jtory Dorkct.\'n. F.U-20/ 1-0181. E..t·mptiuu ;,w,·d}.1mmry·S, 201S) 

Pt..:UI.JoiiCI tCltUC\h t.hatthe administrator waive the publishmtt a Swnm;;U)- of the pctlllonm tltl' h.·d .. ·t;tl Kq;j,lct tb the~ 

issues lm•e ahead\' been ~o•ered and. delays ou a~tin!J on ~'" peution '"""d be dct.rimen~u to the l'ctiuoucr. 

For your C"'om-cmen<"C, 1\-e endosed a L)\'D '\ill a ..dJ 'UPIMu1m~ documents as well as the Petition in \\"ortl fmmaL 

l'lease feel f1cc to ton~'lCt me if I r.m be of scmre. 

Sinc·crcly, 

Jolin (.l. '""c' 

Chief l'1lot & D1rcnnr of Operations 

If.\\ (nuli<i!IIUII, f.f.C 
Identification of Petitioner 

Petition for Exemption 

(Pursuant to 14 CFR Section 11.81) 

This petition for exemption is submitted on behalf of UAV Certification, LLC by John Q. Nunes, 

(collectively referred to as "UAV CERTIFICATION"), 106 Haig Drive, Myrtle Beach, SC 29579 (via 

email at: john@uavcertificationlic.com). 

Petition Based Upon Prior Exemption 

This petition is based, in part, upon prior exemption granted pursuant to In the matter of Douglas 

Trudeau, Realtor (Regulatory Docket No. FAA-2014-0481, Exemption issued January 5, 2015) and, 

In the matter of Craig E. Bryan, Cirrus (Regulatory Docket No. FAA-2015·0160, Exemption issued 

April20, 2015). 

Request for Exemption 

UAV CERTIFICATION respectfully requests relief from the following regulations for the purpose of 

conducting commercial "aerial work" flight operations (as defined by 14 CFR Section 119.1 (e)(1) 

Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power line or pipe line patrol) Unmanned 

Aerial Systems ("UAS"): 

Part 21 prescribing the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals. (UAV 

CERTIFICATION believes relief from this section is not necessary under the statutory criteria 

provided in Section 333 of Public Law 112-95 [P.L. 112-95] in reference to 49 USC Section 

44794 given the size, weight, speed, and limited operating area associated with the proposed 

UAS) 

Section 45.23(b) prescribing that 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. (UAV CERTIFICATION believes relief from this section is not 

1 
necessary as the proposed UAS is not certificated under Section 21.191 and this petition is 

submitted in connection with proposed operations as a Civil UAS) 

Section 61.31 (a) prescribing that a person who acts as a pilot in command of any of the 

following aircraft must hold a type rating for that aircraft for other aircraft specified by the 

Administrator through aircraft type certificate procedures: 

(1) Large aircraft (except lighter-than-air). 

(2) Turbojet-powered airplanes. 

(3) Other aircraft specified by the Administrator through aircraft type certificate 

procedures. 

(UAV CERTIFICATION believes relief from this section is not necessary under the statutory criteria 

provided in Section 333 of P.L. 112-95 in reference to 49 USC Section 44794 given the size, weight, 

speed, and limited operating area associated with the proposed UAS) 

Section 61.31 (c) prescribing that unless a person holds a category, class, and type rating (if a class 

and type rating is required) that applies to the aircraft, that person may not act as pilot in command of 

an aircraft that is carrying another person, or is operated for compensation or hire. That person also 

may not act as pilot in command of that aircraft for compensation or hire. (UA V CERTIFICATION 

believes relief from this section is not necessary under the statutory criteria provided in Section 333 of 

P.L. 112-95 in reference to 49 USC Section 44 794 given the size, weight, speed, and limited 

operating area associated with the proposed UAS) 

Section 61.31 (d) prescribing that to serve as the pilot in command of an aircraft, a person must-

(1) Hold the appropriate category, class, and type rating (if a class or type rating is required) 

for the aircraft to be flown; or 

(2) Have received training required by this part that is appropriate to the pilot certification level, 

aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to 

be flown, and have received an endorsement for solo flight in that aircraft from an authorized 

instructor. 

(UAV CERTIFICATION believes relief from this section is not necessary under the statutory criteria 

provided in Section 333 of P. L. 112-95 in reference to 49 USC Section 44 794 given the size, weight, 

2 
speed, and limited operating area associated with the proposed UAS or, alternatively, requests relief 

from this section by Pilot in Command (PIC) compliance with the applicable operational documents 

published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 9t. 7(a) prescribing that no person may operate a civil aircraft unless it is in an airworthy 

condition. (UA V CERTIFICATION requests relief from this section by Pilot in Command (PIC) 

compliance with the applicable operational documents published by the manufacturer and the 

Proposed Conditions and Limitations set forth in this petition) 

Section 91.7(b) prescribing that the pilot in command of a civil aircraft is responsible for determining 

whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. (UAV CERTIFICATION requests relief 

from this section by Pilot in Command (PIC) compliance with the applicable operational documents 

published by the manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91.9(b)(2) prohibits operation of U.S. registered civil aircraft 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. (UA V CERTIFICATION believes relief from this section is 

not necessary as the FAA has previously determined relief is not required provided the relevant 

materials published by the manufacturer are kept in a location accessible to the PIC in compliance 

with the regulations) 

Section 91.103(b) prescribing that a pilot shall for any flight, become familiar with runway lengths at 

airports of intended use, and takeoff and landing distance information. (UA V CERTIFICA T/ON 

believes relief from this section is not necessary provided the PIC complies with the Proposed 

Conditions and Limitations set forth in this petition) 

Section 91.1 09(a) prescribing, in pertinent part, 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. (UAV CERTIFICA T/ON believes relief from this section is not necessary provided the 

PIC complies with the Proposed Conditions and Limitations set forth in this petition or utilizes the 

UAS' dual control feature) 

3 
Section 91.119 prescribing that, except when necessary for takeoff or landing, no 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. (UA V CERTIFICATION believes relief from this 

section is not necessary provided the Pilot in Command (PIC) complies with the applicable 

operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

(b) Over congested areas. Over any congested area of 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. (UA V CERTIFICATION believes relief from this 

section is not necessary provided the Pilot in Command (PIC) complies with the applicable 

operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

(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. (UAV CERTIFICATION 

requests relief from this section by Pilot in Command (PIC) compliance with the applicable 

operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

Section 91.121 requires, in pertinent part, 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." (UAV CERTIFICATION believes relief from 

this section is not necessary provided the PIC complies with the Proposed Conditions and Limitations 

set forth in this petition) 

Section 91.151 (a) prescribing that no person may begin a flight in an airplane under VFR conditions 

unless (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 fly after that for at 

least 30 minutes [emphasis added). (UAV CERTIFICATION requests relief from this section by Pilot 

4 
in Command (PIC) compliance with the applicable operational documents published by the 

manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; and (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). (UAV CERTIFICATION believes relief 

from this section is not necessary, as the FM has previously determined relief is not required 

provided the relevant materials published by the manufacturer and the Proposed Conditions and 

Limitations are kept in a location accessible to the PIC in compliance with the regulations) 

Section 91.203(b) prescribing, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate 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. 

(UAV CERTIFICA T/ON believes relief from this section is not necessary, as the FAA has previously 

determined relief is not required provided the relevant materials published by the manufacturer and 

the Proposed Conditions and Limitations are kept in a location accessible to the PIC in compliance 

with the regulations) 

Section 91.405{a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall, between required inspections, 

except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed 

in part 43 of the chapter. (UA V CERTIFICATION requests relief from this section by Pilot in 

Command (PIC) compliance with the applicable operational documents published by the 

manufacturer and the Proposed Conditions and Limitations set forth in this petition) 

Section 91 .407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under§ 43.7 of the same chapter. (UAV 

CERTIFICATION requests relief from this section by Pilot in Command (PIC) compliance with the 

applicable operational documents published by the manufacturer and the Proposed Conditions and 

Limitations set forth in this petition) 

5 
Section 91.409(a) prescribing that no person may operate an aircraft unless, within the preceding 12 

calendar months, it has had- {1) an annual inspection in accordance with part 43 of this chapter and 

has been approved for return to service by a person authorized by §43. 7 of this chapter; or (2) that no 

person may operate an aircraft unless, within the preceding 12 calendar months, it has had an 

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

(UAV CERTIFICATION requests relief from this section by Pilot in Command (PIC) compliance with 

the applicable operational documents published by the manufacturer and the Proposed Conditions 

and Limitations set forth in this petition) 

Section 91.417(a) and (b) prescribing, in pertinent part, that-

(a) Each registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

1 00-hour, annual, progressive, and other required or approved inspections, as appropriate, for 

each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an 

aircraft. The records must include-

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii)The current status of life-limited parts of each airtrame, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last 

Inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

6 
(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date 

when the next action is required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service. 

(UAV CERT/FICA TION requests relief from this section by Pilot in Command (PIC) compliance with 

the applicable operational documents published by the manufacturer and the Proposed Conditions 

and Limitations set forth in this petition) 

Extent of and Reasons for Relief Sought 

UAV CERTIFICATION intends to operate the following commercially available UAS types: 

• DJI Inspire 1 

• DJI Phantom 2 

• DJI Phantom 3 

• Draganflyer Guardian 

• Draganflyer X4-P 

• Draganflyer X4-ES 

• Draganflyer Commander 

• Altus Delta XS 

• Altus Delta LRX 

for the purpose of aerial work under the provisions of 14 CFR Section 119.1 (e)(4}(iii) Aerial 

photography or survey, and Section 119.1 (e)(4)(vi) Power line or pipe line patrol. UAV 

CERTIFICATION intends to offer commercial "aerial work" services utilizing UAS under the 

exemptions to 14 CFR Section 135 granted under 14 CFR 119.1 (e) as set forth above. Additionally, 

7 
UAV CERTIFICATION's pilot, John 0. Nunes, holds a Private Pilot Certificate (Airplane Single & 

Mulliengine Land) and a current 2nd Class Medical with an excess of 1000 hours of flight time. 

Public Interest and Benefit 

The above "aerial work" services, normally provided in manned aircraft, may be provided with 

increased safety and at significantly lower cost in situations where the use of unmanned UAS aircraft 

would supplement or replace the use of manned aircraft as a result of safety or economic 

considerations in certain applications where extended operational range and limited time aloft are not 

a factor. The proposed UAS operations will pose no threat to the public given its small size and lack 

of combustible fuel when compared to larger manned aircraft, minimize potential ecological affects or 

damage, and promote economic growth by providing data information to individuals or companies 

requiring aerial survey or imaging data. 

Exemptions Provide a Leyel of Satety Equal to or Greater than the Existing Level under 

Current Regulations 

The use of UAV operated under the requested exemptions as set forth above have the capacity to 

operate with less risk of accident or injury and the associated loss of property or life while performing 

the same aerial work services offered in manned aircraft in certain situations where extended 

operational range and limited time aloft are not a factor. 

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The 

listed UAVs carry no fuel, and therefore the risk of fire following an incident or accident due to fuel 

spillage is eliminated. 

This petition for exemption does not propose an electronic means to monitor and communicate with 

other aircraft, such as transponders or sense and avoid technology at this time. Rather the risk is 

mitigated by placing limits on altitude, requiring stand-off distance from clouds, permitting daytime 

operations only, and requiring that the UAVs be operated within VLOS and yield right of way to all 

manned operations. Additionally, the Proposed Conditions and Limitations provide that UAV 

CERTIFICATION will request a notice to airmen (NOT AM) prior to operations to alert other users of 

the NAS. 

8 
UAV CERTIFICATION's UAS' have the capability to operate safely after experiencing certain in-flight 

contingencies or failures and uses an auto-pilot system to maintain UAS stability augmentation and 

control. The UAS is also able to respond to a loss of GPS or a lost-link event with pre-coordinated 

automated flight maneuvers. These safety features provide an equivalent or higher level of safety 

compared to a manned aircraft holding an airworthiness certificate (restricted or otherwise) 

performing a similar operation. 

Federal Rea later Summary 

UAV CERTIFICATION, including its pilot John Q. Nunes, seeks exemption from the following 

regulations for the purpose of conducting commercial "aerial work" flight operations utilizing 

Unmanned Aerial Systems ("UAS") as set forth under the provisions of 14 CFR Section 119.1 

(e)(4)(iii) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Powerline or pipeline patrol 

Relief Considered (14 CFR) 

Part 21 

45.23(b) 

61.31(a) 

61 .31(c) 

61.31(d) 

91. 7(a) 

91.7(b) 

91 .9(b)(2) 

91.103(b) 

91 .109(a) 

91.119 

91.121 

91.151(a) 

91.203(a) and (b) 

91.405(a) 

91.407(a)(1) 

91.409(a)(1) and (2) 

91.417(a) and (b) 

FAA Consideration or Action Requested 

Relief not necessary pursuant to prior exemptions • 1 

Relief not necessary pursuant to prior exemptions "I 

Relief not necessary (Section 333 of P.L. 112-95) '2 

Relief not necessary (Section 333 of P.L. 112-95) '2 

Relief not necessary (Section 333 of P.L. 112-95) '2 

Relief granted in prior exemption with conditions and limitations '1 

Relief not necessary pursuant to prior exemptions ·I 

Relief not necessary pursuant to prior exemptions ·I 

Relief not necessary pursuant to prior exemptions • 1 

Relief not necessary pursuant to prior exemptions '1 

Relief (paragraph c) granted in prior exemption with conditions and limitations 

"I 

Relief granted In prior exemption with conditions and hm1tations ·I 

Relief (paragraph 91.15 I (a)(1 ), day) granted in prior exemptiOn with 

conditions and limitatiOns "1 

Relief not necessary pursuant to prior exemptions ·I 

Relief not necessary pursuant to prior exemptions "1 

Relief not necessary pursuant to prior exemptions ·I 

Relief not necessary pursuant to prior exemptions •t 

Relief not necessary pursuant to prior exemptions •t 

'1 in the matter of Douglas Trudeau, Realtor, Regulatory Docket No. FAA-2014-()481 

"2 Relief from this section is not necessary under statutory criteria provided in Section 333 of P.L. 112-95 

in reference to 49 USC Section 44794 given the size, weight, speed, and limited operating area 

associated with the proposed UAS 

9 
Additional Information Offered in SuPport of this Petition for ExemPtion 

UAV CERTIFICATION's Chief Pilot, John Q Nunes ("John"), operated various manned 

aircraft, including fixed-wing aircraft s10ce 1976. Additionally, John has operated 

commercially available UAS vehicles for the past 12 months for non-commercial and 

commercial use (under exemption #11874) in order gain flight experience and familiarity with 

the operating characteristics and limitations of the UAS and its videography and photography 

systems. Additionally, John has always contacted the local airport and/or air traffic manager 

and/or tower manager as a courtesy. As Standard Operating Procedure, UAV 

CERTIFICATION's will monitor local aircraft traffic utilizing an iCom IC-A22 Transceiver. 

As a result, it is believed there are certain aerial work situations, where the range and time 

aloft limitations of UAS are not a factor, whereby aerial work may be conducted with greater 

safety and less risk to persons or property on the ground while offering the same or improved 

level of aerial work product. Manned aircraft platforms such as airplanes and helicopters 

often subject the occupants as well as persons and property on the ground to higher levels of 

risk for accident or injury even while being operated pursuant to all of the applicable federal 

aviation regulations. 

The above listed UAVs are commercially produced and a widely available aerial 

videography and photography platform utilizing advanced GPS enabled stability 

augmentation and control systems including "failsafe" features allowing the operator to 

manually take control of the aircraft or initiate an automated "return to home• feature in the 

event of adverse inflight events. The UAS also incorporates automated "failsafe" features to 

initiate "return to home" or "auto land" commands in the event of loss of control signal link or 

diminished battery output or capacity. 

The manufacturers provide comprehensive operational and safety manuals for both UAS and 

all flights will be conducted in accordance with the requirements and guidance issued in 

these manuals. 

10 
UAV CERTIFICATION states that§ 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. UAV CERTIFICATION's asserts that since there is currently no 

certificate applicable to his operation, this regulation is inapplicable. 

UAV CERTIFICATION states that§ 91.9(b)(2) requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board his aircraft and given its size, this 

regulation is inapplicable. UAV CERTIFICATION further indicates an equivalent level of 

safety will be achieved by maintaining a safety/flight manual with the UAS ground station. 

Prooosed Conditions and Limitations 

UAV CERTIFICATION (also hereafter referred to as the operator) proposes the following 

Proposed Conditions and Limitations in the form of a proposed Grant of Exemption: 

The following documents, including any updates or revision by the manufacturer, provided by 

the operator in its petition are incorporated by reference, and are hereinafter referred to as 

operating documents: 

Manuals are attached in digital media format 

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 following aircraft 

described in the operating documents, which are quad-rotor aircraft weighing less 

than 55 pounds: 

a) DJ I Inspire 1 

b) DJI Phantom 2 

c) DJI Phantom 3 

d) Draganflyer Guardian 

e) Draganflyer X4-P 

f) Draganflyer X4-ES 

g) Draganflyer Commander 

h) Altus Delta X8 

i) Altus Delta LRX 

11 
Proposed operations of any other aircraft will require a new petition or a petition to amend 

this grant. 

2) The UAS may not be flown at an indicated airspeed exceeding 87 knots. 

3) The UAS must be operated at an altitude of no more than 500 feet above ground 

level (AGL), as indicated by the procedures specified in the operating documents. All 

altitudes reported to ATC must be in feet AGL. 

4) The UAS must be operated within visual line of sight (VLOS) of the Pilot in 

Command (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. 

5) All operations commercial "aerial work" flight operations [as defined by 14 CFR 

Section 119.1 (e)(1) Aerial photography or survey, and Section 119.1 (e)(4)(vi) Power 

line or pipe line patrol] must utilize a visual observer (VO). The UAS must be operated 

within the visual line of sight (VLOS) of the 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. 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 functions prescribed in 

the operating documents. 

6) The operating documents and this grant of exemption must be accessible during 

UAS operations and made available to the 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 revised documents to the Administrator upon request. The 

12 
operator must also present updated and revised documents if he petitions for 

extension or amendment to this grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted this exemption, 

then the operator must petition for amendment to its grant of exemption. The FAA's 

UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

7) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the UAS is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations 

must be properly documented in the aircraft records. 

8) Any UAS 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. The PIC who conducts the functional test flight must make an 

entry in the aircraft records. 

9) The pre-flight inspection section in the operating documents must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already covered 

in the relevant sections of the operating documents. 

1 0) The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

11) The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

and alterations must be noted in the aircraft records, including total flight hours, 

description of work accomplished, and the signature of the authorized person returning 

the UAS to service. 

13 
12) Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

13} The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

14) UAS operations must be conducted by a PIC possessing at least a sport pilot 

certificate and at least a current third-class medical certificate. The PIC must also meet 

the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC 

is rated on his or her pilot certificate. 

15} Prior to operations conducted for the purpose of flight instruction or aerial work as 

defined by 14 CFR Section 119.1 (e}(4}(iii) Aerial photography or survey, and Section 

119.1 (e}(4)(vi) Power line or pipe line patrol, the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51 (b), a minimum of 25 hours of total 

time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight time. However, said training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights the PIC is required to operate the UAS with appropriate 

distances in accordance with 14 CFR 91.119. 

16) Prior to operations conducted for the purpose of aerial work as defined by 14 CFR, 

Section 119.1 (e)(4)(iii) Aerial photography or survey, and Section 119.1 (e}(4)(vi) 

Power line or pipe line patrol, the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51 (b), a minimum of 5 hours as UAS pilot operating 

the make and model of the UAS to be used in operations under the exemption; 5 

hours make and model time may be included in the 10 hours of multi-rotor time 

prescribed above. The PIC must accomplish 3 take-offs and landings in the preceding 

90 days (for currency purposes). Training, proficiency, experience-building, and take14 
off and landing currency flights can be conducted under this grant of exemption to 

accomplish the required flight time and 90 day currency. However, said training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights the PIC is required to operate the UAS with 

appropriate distances in accordance with 14 CFR 91.119. 

17) The operator may not permit the PIC to operate the UAS for the purpose of aerial 

work as defined by 14 CFR Section 119.1 (e)(4)(iii) Aerial photography or survey, and 

Section 119.1 (e)(4)(vi) Power line or pipeline patrol, unless the PIC 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. 

18) 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). 

19) The UAS may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless, prior to such operation, 

the PIC coordinates and obtains authorization and airspace clearance from any 

National Airspace System (NAS) controlling authority having jurisdiction over the 

affected airspace and establishes and maintains continuous verbal communication or 

contact with said authority (ATC) through radio or telephonic methods for the duration 

of flight. 

20) The UAS 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. 

21) If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

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22)The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents. 

23) The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the 

intended landing point and land the UAS with 30% battery power remaining. 

24) The operator 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 the operator to request a Notice to Airman 

(NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. 

25) 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable. 

26) Before conducting operations, the radio frequency spectrum used for operation 

and control of the UAS must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

27) The 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 UAS is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

28) The UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times 

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

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30) The UAS may not be operated over congested or densely populated areas. 

31) Flight operations 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 UAS and/or debris in the event of an accident. The operator 

must ensure that non-participating persons remain under such protection. If a 

situation arises where non-participating persons leave such protection and are 

within 500 feet of the UAS, 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 PIC 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 PIC, VO, operator trainees or essential persons do 

not present an undue hazard to those persons per§ 91.119(a). 

32) All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission 

from land owner/controller or authorized representative will be obtained for each flight 

to be conducted. 

33) Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable GOA must be reported 

to the FAA'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 

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. 

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Respectfully submitted, 

UAV Certification, LLC 

~ Chief Pilot & Director of Operations 

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