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Kevin D Hubbard

Ravenwood HD Services, LLC

13870 East River Vista Circle

Palmer, AK

99645

(907)631-8791

Ravenwood.HD.llc@gmail.com

April 2, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Exemption Per PL 112-95 §333 from 14CFR 21 Part H, 14CFR 61.3, 

14CFR 61.113, 14CFR 91.119, 14CFR 91.121, 14CFR 91.151, 14CFR 91.405, 14CFR 

91.407, 14CFR 91.409, 14CFR 91.417

Please consider this a request for an exemption of the above applicable sections of 14 

CFR for Ravenwood HD Services, LLC (hereafter ‘Ravenwood’) for the purpose of 

conducting commercial aerial survey and photography operations with its small Unmanned 

Aircraft System (sUAS) within United States airspace. The employment of sUAS platforms for 

these missions should provide the FAA with good cause to find that these operations enhance 

safety by eliminating the need to use conventional aircraft in the sometimes unique 

environments where a small Unmanned Aerial Vehicle (sUAV) would be particularly adept, but 

a conventional aircraft may pose a hazard to its crew and those on the ground.

Ravenwood requests exemption from the following applicable regulations, pursuant to 

the Administrator’s authority to grant exemptions contained in 49 U.S.C. §106(f), 40113, 

and 44701:

14 CFR 21 Part H

14 CFR 61.3

14 CFR 61.113,

14 CFR 91.119,

14 CFR 91.121,

14 CFR 91.151,

14 CFR 91.405,

14 CFR 91.407,

14 CFR 91.409,

14 CFR 91.417
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CORPORATE EXPERIENCE

(14CFR 61.3 and 14CFR 61.113)

The operational staff of Ravenwood is comprised of aviation professionals with varying 

degrees of experience. All Ravenwood operators have at a minimum passed an FAA Private 

Pilot Ground School course, completed the Ravenwood sUAS training course, and hold at 

least an FAA third class flight physical. The principal (Chief) Operator is an FAA-trained air 

traffic controller with more than 22 years’ experience in aviation safety. He has been a 

certified professional controller at 3 Air Traffic Control Towers and Multiple radar facilities. 

He also has passed an FAA part 141 ground school at the University of Alaska Anchorage 

(UAA)(which included 2 hours in a full motion flight simulator) and is pursuing a Private Pilot 

Certificate and a Bachelor of Science degree in aviation management. He has more than 100 

hours of flight time in small aircraft in Alaska, although none of it was as Pilot-In-Command. 

(PIC) He also completed the first ‘Introduction to Unmanned Aircraft Systems’ course 

offered by UAA. A complete resume is available upon request. This combination of experience 

and education provides a greater level of understanding and safety for the operation of a 

sUAS in the National Airspace System (NAS) than simply possessing a Private Pilot 

Certificate.

OPERATIONS

Ravenwood operations utilize a sUAS in a manner that provides services not offered by 

manned aircraft and enhances the level of safety beyond which can be accomplished by 

manned aircraft. Examples of the proposed aerial photography operations include real estate, 

insurance damage assessment, and incident/accident documentation. Most operations restrict 

the use of the sUAS to a small area typically encompassing a limited number of residential and 

commercial properties at a time. The structures on these properties provide sufficient 

protection from the sUAV, and photography can be completed with much less risk than what 

would be incurred in a manned aircraft operation at low altitudes. Our intended film 

production operation would typically include both photography and videography for 

commercial purposes including wedding and corporate events. These events are restricted to 

only the invited participants and are closed to the general public, providing the opportunity to 

operate only in an area where informed, consenting participants and personnel are present. 

Ravenwood will be able to provide a level of safety equal to or greater than the manned 

aircraft that would typically provide these services.

Finally, our survey operation includes the orthomosaic mapping of agriculture, 

construction, and industrial sites utilizing our sUAS rotorcraft flying pre-programmed grids 

that can be interrupted and returned to a safe landing zone by our operators at any time. 

Currently these operations are executed by manned aircraft carrying hundreds of pounds of 

fuel and equipment flying at low altitudes and speeds in excess of 75 miles per hour. Our 

operation would greatly increase the level of safety, replacing manned aircraft with a sUAV 
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weighing less than 7.5 pounds which carries no fuel, and restricted to speeds no greater than 

40 knots. These sites are areas that can readily be secured by Ravenwood personnel and will 

not provide any additional risk to the general public.

Flight Safety

All Ravenwood HD Imaging operations will be performed by Ravenwood HD Services 

llc trained and certified operators that have at minimum passed an FAA Private Pilot Ground 

School and hold a current FAA class 3 medical certificate. Operators, Visual Observers and 

where necessary Site Security Coordinators will participate in a preflight safety briefing for 

each mission. The mission will be executed only after a safety assessment has been completed 

and Threat/Error Mitigations are in place. Any operations under the exemption will be 

conducted in accordance with the Ravenwood Flight Operations Manual. 

Aircraft

Ravenwood HD Imaging will operate variations of the 3D Robotics X8+, an eight motor 

rotorcraft. The X8+ is a commercially available, off-the-shelf sUAS. The X8+ is a rotorcopter 

configuration and will weigh no more than 7.5 pounds. The X8+ will operate no faster than 40 

knots groundspeed. The X8+ is agile, having the ability to hover, and move about its three 

axes simultaneously. The X8+ will be operated below 400 feet Above Ground Level (AGL) and 

continuously within the operator’s line of sight, so as not to create a hazard to users of the 

NAS or public. The X8+ is equipped with failsafe protocols that can either return the aircraft 

to a predetermined point and land, or land immediately if that action has been deemed safer 

by the operator in the preflight planning. Because of the X8+’s specifications and flight 

characteristics, it poses no threat to national security.
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Limitations

The limitations and conditions that Ravenwood HD Services, llc agrees to be bound to include:

1. The X8+ takeoff weight will be less than 7.5 lbs. unless operating under an 

approved modification.

2. The X8+ will be operated at less than 40 knots groundspeed.

3. Flights will be operated within unaided visual line of sight of an operator and 

observer.

4. The X8+ will never be operated directly over a person, and will remain at least 100 

feet from all persons.

5. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions.

6. Flights will be operated at an altitude of no more than 400 feet AGL.

7. Maximum total flight time for each operational flight will be 30 minutes.

8. Flights will be terminated at 20% battery power reserve should that occur prior to 

30 minutes.

9. Minimum crew for each operation will consist of the sUAS Operator, the Visual 

Observer and may include a security coordinator.

10. The sUAS operator will be a Ravenwood HD Services trained operator and will 

maintain at least an FAA third class medical certificate. The observer will be a 

Ravenwood HD Services trained observer.

11. A briefing will be conducted in regard to the planned sUAS operation prior to each 

flight. All Ravenwood personnel who will be participating in that flight shall be 

present for the preflight briefing.

12. When necessary, and at least 72 hours prior to flight, the operator will file FAA 

Form 7711-1, or its equivalent, with the appropriate Flight Standards District 

Office.

13. Observer and Operator will at all times be able to communicate by voice with each 

other.

14. When necessary, permission from relevant property owners will be obtained.

15. If the sUAS suffers a ‘lost link’, the X8+ will perform the predetermined flight 

maneuver to land as soon as practical as outlined in the preflight briefing. 

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

17. All accidents and incidents shall be recorded in the aircraft log and reported in 

accordance with FAA directives.
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X8+ CONTROL

The control of the X8+ will be through a Radio Transmitter and Receiver operating on 

frequency 915 Mhz. This frequency is FCC approved and provides more than adequate range 

for operations within line of sight of the operator. The X8+ sUAS is also equipped with flight 

telemetry radios for semi-autonomous operation using highly precise GPS data, while 

maintaining a constant link between the X8+ vehicle and the ground station. The semiautonomous mode of the X8+ is similar to a small manned aircraft operating with a 3 axis 

autopilot; operator input is still a function of the system. (Lost link procedures still apply)

X8+ PAYLOAD

The X8+ manufacturer’s payload capacity is listed at 800 grams, which equals 1.76 lbs. 

The X8+ vehicle weight with battery is listed at 2,560 grams which equals 5.64 lbs. Specific 

payload configurations will result in variable payloads. Every flight payload will be documented 

in the aircraft log. Without a manufacturer’s approved modification, the X8+ will not be 

operated outside parameters set forth in the manufacturer’s handbook.

AIRWORTHINESS CERTIFICATION

The X8+ operated by Ravenwood HD Imaging has a manufacturer’s maximum takeoff 

weight of 3,360 grams (7.50 lbs.) fully loaded. It carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within visual line of 

site of the operator. Operations under this exemption will be tightly controlled and monitored 

by the operator. The X8+ has the capability to safely fly and navigate after a total loss of 

power to one motor; this would be catastrophic to a typical 4 motor rotorcraft. By nature of 

its operation, the X8+ provides a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14CFR 

Part 21. 

NATIONAL SECURITY

There is no credible threat to national security posed by the UAS, due to its size, 

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

and inability to carry a substantial external load. 
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FLIGHT CREW 

(14CFR 21 Part H)

All flight crew members will successfully complete the Ravenwood HD Services training 

program and operators will maintain at least an FAA 3rd class medical certificate. The 

Ravenwood HD Services training program has been developed referencing the curriculum 

already in place by the U.S. Department of Interior (DOI) for training their sUAV pilots. This 

curriculum is currently accepted by the FAA as valid for the initial qualification of sUAS 

operators. The full Ravenwood HD Services llc training program is proprietary in nature and is 

available to the Administrator upon request.

The Ravenwood Operator will remain the individual in charge of each flight and will not 

transfer responsibility for operational control of the X8+ aircraft to any other person, unless 

the flight is specifically for training purposes and not for hire. Any flight for training purposes 

will include a visual observer that is fully qualified for that position. 

The Visual Observer will be trained in accordance with the Ravenwood HD Services llc

training program and will possess a current valid driver’s license issued in the United States.

Ravenwood HD Services llc requests an exemption from 14CFR 21 Part H until such a 

time that it has been established that the Ravenwood HD Services llc training program is 

capable of full compliance with the regulation (Number of successful graduates, certification of 

instructors, etc).

CREW RESOURCE MANAGEMENT (CRM)

All Ravenwood flight crew members will actively practice CRM in accordance with FAA 

guidelines. Further guidance and details are covered in the Ravenwood HD Services training 

program.

PREFLIGHT ACTION

Prior to each flight, the operator must conduct a pre-flight inspection and determine 

the sUAS is in a safe condition for 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 X8+, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the X8+ is found to be in a 

condition for safe flight. 

After the pre-flight inspection, the operator will conduct a pre-flight safety briefing 

with the observer and all other participants.
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MINIMUM SAFE ALTITUDES

(14CFR 91.119)

Ravenwood HD Services llc requests authority to operate at altitudes up to but not 

exceeding 400 feet AGL. Ravenwood HD Services llc will maintain a safe operating area in 

order to protect structures and people not associated with the operation. At no time will the 

X8+ be operated directly over a person. The X8+ will be operated at least 100 feet from all 

persons. The X8+ will be continuously operated at an altitude which will allow a safe descent 

and recovery should a mechanical issue arise.

ALTIMETER SETTING

(14CFR 91.121)

The X8+ utilizes a highly accurate GPS altimeter. An equivalent or greater level of 

safety is provided during preflight where the Ravenwood operator will compare the GPS 

altimeter with the pressure altimeter for the nearest FAA METAR report and verify accuracy 

to within 50 feet as indicated on the applicable VFR sectional chart.

FUEL REQUIREMENTS

(14 CFR 91.151)

The X8+ is powered by a battery, which provides up to 30 minutes of powered flight. 

Because of the absence of flammable operating fluids, an X8+ does not pose the same level of 

risk as a conventional aircraft. All Ravenwood operators will terminate flights when remaining 

battery power level reaches 25%, or 30 minutes flight time is reached, whichever comes first 

after takeoff.

Since no flights conducted by Ravenwood will require traditional petroleum based fuel, 

and those flights will be for less than 30 minutes, Ravenwood requests relief from 14CFR 

91.151.

X8+ MAINTENANCE

(14CFR 91.405, 14CFR 91.407, 14CFR 91.409, 14CFR 91.417)

Ravenwood HD Services llc requests exemption from 14CFR 91.405, 14CFR 91.407, 

14CFR 91.409, 14CFR 91.417. 

Ravenwood HD Services llc will conduct all maintenance on the X8+ in accordance 

with the flight operations manual, pilot operating handbook, and any guidance received from 

the manufacturer. Ravenwood HD Services llc will abide by all notices from the manufacturer 

governing the maintenance, preventive maintenance, and alterations of the X8+.
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All maintenance will be conducted by a Ravenwood associate according to guidance 

from the manufacturer.

There is no certified FAA inspection process for sUAS’s, therefore all inspections will 

be conducted by Ravenwood associates in accordance with manufacturer’s guidelines. These 

inspections will be conducted and documented after any maintenance and before every flight.

A functional flight test will be conducted after maintenance and before any flight for hire.

Summary

Ravenwood HD Services llc intends to comply with every applicable regulation to the 

operation of the X8+ sUAS. Each request for exemption has been made with the 

understanding that Ravenwood is able to conduct operations that are at least as safe as or

safer than those commercial operations that currently are conducted by manned aircraft. 

Ravenwood’s proposed exemptions and operational limitations are very closely aligned 

with other exemptions already granted, and also with pending proposed 14 CFR §91.107, 

which is specific to the operation of ‘micro’ unmanned aircraft. The proposed 14 CFR 

§91.107 has been attached for reference. 

Although the X8+ is above the weight restrictions for the proposed rule, it is 

applicable in nearly every other instance. In the event that 14 CFR §91.107 becomes 

effective, Ravenwood HD Services llc will be submitting a request to operate within those 

guidelines with minor exemptions to be addressed at a later date. 

I appreciate your assistance with this process, as I am aware of the massive 

undertaking that these exemption requests are. Please contact me at your convenience with 

any questions regarding this request.

Thank You,

Kevin D. Hubbard 

Managing Member and Chief Operator

Ravenwood HD Services llc

Attached: Proposed 14 CFR §91.107, per UAS America Fund, llc

X8+ Online Operating Manual: http://3drobotics.com/wp-content/uploads/2015/04/X8-Operation-Manual-vC.pdf
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UAS America Fund LLC

Micro Unmanned Aircraft

Proposed Part 107

§107.1 Applicability.

This part prescribes rules governing the operation of micro unmanned aircraft in the United States. For purposes 

of this part, a micro unmanned aircraft means a device capable of sustaining its own powered flight in the air, that 

is operated without the possibility of direct human intervention from within or on the device, and that:

a) Weighs 3 pounds or less gross takeoff weight, including power source and payload;

b) Is powered by an electric battery or other non-combustion power source;

c) Is operated for a business, commercial, scientific, academic, research or other non-recreational purpose; 

and is not a “model aircraft” subject to Public Law 112-95 § 336.

§107.3 Waivers.

No person may conduct operations that require a deviation from this part except

under a written waiver issued by the Administrator.

§107.5 Careless or reckless operations.

a) No person may operate a micro unmanned aircraft in a careless or reckless manner so as to endanger the 

life or property of another.

b) No person may allow an object to be dropped from a micro unmanned vehicle if such action creates a 

hazard to other persons or property.

§107.7 Certification, registration and other requirements.

c) Notwithstanding any other section pertaining to certification of aircraft or their parts or equipment, micro 

unmanned aircraft and their component parts and equipment (including ground station or radio control 

systems) are not required to meet the airworthiness certification standards specified for aircraft or to 

have certificates of airworthiness.

d) Notwithstanding any other section pertaining to registration and marking of aircraft, micro unmanned 

aircraft are not required to be registered or to bear markings of any type, except that the name, address, 

and telephone number of the owner or operator shall be affixed to at least two externally visible locations 

on the micro unmanned aircraft.

e) Notwithstanding any other section, micro unmanned aircraft operated pursuant to this part are not 

subject to any other federal aviation regulation, including any provision of parts 21, 45, 47, 61, or 91.

§107.9 Daylight operations.

a) No person may operate a micro unmanned aircraft except between the hours of sunrise and sunset.

b) Notwithstanding paragraph (a) of this section, micro unmanned aircraft may be operated during the 

twilight periods 30 minutes before official sunrise and 30 minutes after official sunset, or, in Alaska, 

during the period of civil twilight as defined in the Air Almanac, if:

1)The micro unmanned aircraft is equipped with an operating anti-collision light visible for 

at least 3 statute miles; and

2)All operations are conducted in uncontrolled airspace.
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§107.11 Operation near aircraft; right-of-way rules.

a) Each person operating a micro unmanned aircraft shall continually maintain vigilance so as to see and 

avoid aircraft and shall yield the right-of-way to all manned aircraft.

b) No person may operate a micro unmanned aircraft in a manner that creates a collision hazard with 

respect to any aircraft.

c) Each person operating a micro unmanned aircraft, upon hearing engine, rotor, or propeller sounds from 

an aircraft uninvolved in the operation, shall take precautionary steps to identify the altitude and flight 

direction of the uninvolved aircraft and yield right of way.

§107.13 Operating limitations: altitude, airspace and locations.

a) No person may operate a micro unmanned vehicle at an altitude greater than 400 feet above ground level 

(AGL).

b) No person may operate a micro unmanned vehicle within Class B, Class C, or Class D airspace or within the 

lateral boundaries of the surface area of Class E airspace designated for an airport, unless that person has 

prior authorization from the ATC facility having jurisdiction over that airspace. 

c) No person may operate a micro unmanned aircraft within 5 nautical miles of the geographic center of an 

airport as denoted on a current FAA-published aeronautical chart unless that person has prior written 

authorization from that airport’s management. This restriction does not apply to airports that are closed 

or abandoned.

d) No person may operate a micro unmanned aircraft beyond his or her visual line of sight (VLOS). During 

the flight operation, the operator must be able to view the micro unmanned aircraft at all times using his 

or her own natural vision (which includes the use of vision corrected by standard eyeglasses or contact 

lenses but excludes the use for flight navigation purposes of vision-enhancing devices such as binoculars, 

night vision goggles, powered vision magnifying devices, or video glasses designed to provide a “first 

person view” from a camera mounted on the micro unmanned aircraft), and must visually scan the 

surrounding airspace to see and avoid other air traffic. The maximum operating distance of a micro 

unmanned aircraft system from the operator under this subsection is 2,640 feet, regardless of the visual 

acuity of the operator.

e) No person may operate a micro unmanned aircraft closer than 100 feet from any persons uninvolved in 

the operation.

f) No person may operate a micro unmanned aircraft over an open-air assembly of persons.

g) No person may operate a micro unmanned aircraft in special use airspace designated under Part 73 unless 

that person has permission from the using or controlling agency, as appropriate.

h) No person may operate a micro unmanned aircraft over privately-owned property without the express or 

implied permission from the property owner, tenant in possession, or an authorized representative 

thereof.

i) No person may operate a micro unmanned aircraft system within 5 nautical miles of any forest fire 

without authorization from the incident commander.

j) Prior to operating a micro unmanned aircraft under this part, the operator shall become familiar with all 

pertinent information concerning the proposed operational location, including but not limited to review 

of relevant NOTAMs.

k) Any person intending to operate a micro unmanned aircraft within one mile of any active emergency shall 

first check for any NOTAMs with respect to restrictions on operations in that location.

§ 107.15 Meteorological conditions.

All flights under this part must be conducted under visual meteorological conditions. A micro unmanned aircraft 

may not be operated under this part 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 operator.

§107.17 Operating limitations: ground speed.

No person may operate a micro unmanned aircraft in excess of 40 knots ground speed.
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§107.19 Operator qualifications.

a) An operator of a micro unmanned aircraft system under this part must be at least 18 years of age.

b) No person may operate a micro unmanned aircraft system under this part without first passing the FAA 

private pilot written airman knowledge test administered by an FAA-accredited pilot school or test center. 

Prior to any operation under this part, the operator shall send written notification to the FAA evidencing 

the test results together with the operator's name and contact information, which submission the 

Administrator will acknowledge in writing as constituting the operator's micro unmanned aircraft pilot 

certificate for purposes of 49 USC § 44711. This subsection shall not apply to micro unmanned aircraft 

systems operated as public aircraft.

c) The FAA may pursue investigation and enforcement procedures set out in part 13 with respect to the 

operator of a micro unmanned aircraft systems, including potential suspension or revocation of a micro 

unmanned aircraft pilot certificate held by its operator.

d) Any other FAA pilot certificate that has as a requisite a written airman knowledge test may, if said 

certificate is current and in good standing, serve as a micro unmanned aircraft pilot certificate under 

subsection (b) even if the operator is unable to provide evidence of his or her written test results. Such 

pilot certificates will constitute the operator's micro unmanned aircraft pilot certificate for purposes of 49 

USC § 44711 and part 13.

e) No person shall operate a micro unmanned aircraft for hire or for a commercial purpose (other than 

research and development activates relating to the micro unmanned aircraft or its related systems and 

components), without first undertaking and documenting the following steps to gain experience and 

proficiency with the micro unmanned aircraft model:

1) Review of the micro unmanned aircraft manufacturer's operating manuals and any instructional 

videos provided by the manufacturer.

2) At least 5 hours of total operating flight time; and

3) At least 25 takeoff-and-landing sequences. 

f) All operations under this part (including training) shall be documented and recorded in a permanent place 

such as a log book. For the purposes of meeting the minimum requirements of this subsection, each 

person must record the following information for each micro unmanned aircraft flight:

1) Date and time

2) Micro unmanned aircraft type, make, model

3) Route and boundaries of flight

4) Total duration of flight

5) Weather conditions of flight

6) Number of landings

7) Total flight time and/or lesson time

8) Remarks or other pertinent details

§107.21 Alcohol or drugs.

a) No person may operate a micro unmanned aircraft —

1) Within 8 hours after the consumption of any alcoholic beverage;

2) While under the influence of alcohol;

3) While using any drug that affects the person's faculties in any way contrary to safety; or

4) While having an alcohol concentration of 0.04 or greater in a blood or breath specimen. Alcohol 

concentration means grams of alcohol per deciliter of blood or grams of alcohol per 210 liters of 

breath.
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§107.23 Insurance.

a) No person shall operate a micro unmanned aircraft for hire or for a commercial purpose (other than for 

research and development of the micro unmanned aircraft or its systems and components) unless he or 

she has in effect liability insurance coverage that at a minimum meets or exceeds the minimum motor 

vehicle insurance coverages for both property damage and bodily injury required in the state in which the 

operation occurs, and that has been issued specifically to insure against risks of the operation of the micro 

unmanned aircraft.

b) Insurance coverage to meet the requirements of this part shall be obtained from one or more of the 

following:

1) An insurer licensed to issue aircraft accident liability policies in any State, Commonwealth, or 

Territory of the United States, or in the District of Columbia; or 

2) Surplus line insurers named on a current list of such insurers issued and approved by the 

insurance regulatory authority of any State, Commonwealth, or Territory of the United States or 

of the District of Columbia. 

c) All person who have operated micro unmanned aircraft under this part must present their logbook, proof 

of insurance, and evidence of submission to the FAA Administrator their written test results or their valid 

pilot certificate, or any other record required by this part for inspection upon a reasonable request bya. The Administrator; 

b. An authorized representative of the National Transportation Safety Board; or 

c. Any Federal, State, or local law enforcement officer.

§107.25 Accident reporting.

In connection with any operation under this part, any incident involving $1,000 or more in third-party property 

damage, and any accident involving any bodily injury, must be reported to the nearest FAA Flight Standards District 

Office within three business days. Accidents involving a serious injury or death shall be reported to the NTSB 

pursuant to 49 CFR § 830.