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TABLE OF CONTENTS 

I. Glossary of Abbreviations ............................................................................................... 2

II. Information Supporting This Petition as Specified in Title 14 CFR Part 11.81 ......... 3

A. Mailing Address and Contact Information ....................................................................................... 3

B. Sections of Title 14 CFR from which GGI Seeks an Exemption ..................................................... 3

C. Extent of Relief GGI’s Seeks ........................................................................................................... 3

D. The Reasons why Granting GGI’s Request Would Be in Public Interest ........................................ 4

E. The Reasons why Granting GGI’s Request Would Not Adversely Affect Safety ........................... 4

F. Summary .......................................................................................................................................... 4

G. Additional Information Supporting GGI’s Request ........................................................................ 4

III. Description of Petitioner .................................................................................................. 5

IV. Unmanned Aircraft System ............................................................................................. 5

A. UAS Performance ............................................................................................................................ 6

B. Pre-Flight Inspections, Maintenance, and Repair ............................................................................. 6

C. Radio Frequency .............................................................................................................................. 7

V. Unmanned Aircraft Pilot in Command .......................................................................... 7

VI. Operation of the Unmanned Aircraft ............................................................................. 8

A. Intended UAS Operations ................................................................................................................ 8

B. Limitations Of UAS Operations ....................................................................................................... 8

VII. Discussion of Requested Exemptions .............................................................................. 9

A. Title 24 CFR Part 21, Subpart H: Certification Procedures for Products and Parts, Airworthiness 

Certificates ................................................................................................................................................. 9

B. Title 14 CFR Parts 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements ......10

C. Title 14 CFR Parts 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

 10

D. Title 14 CFR Part 91.7(a): Civil Aircraft Airworthiness .................................................................10

E. Title 14 CFR Part 91.9(b)(2) and (c): Civil Aircraft Flight Manual in the Aircraft ........................10

F. Title 14 CFR Part 91.103: Preflight Action.....................................................................................11

G. Title 14 CFR Part 91.119: Minimum Safe Altitudes .......................................................................11

H. Title 14 CFR Part 91.121: Altimeter Settings .................................................................................11

I. Title 14 CFR Part 91.151(a)(1): Fuel Requirements for Flight in Visual Flight Rules Conditions .12

J. Title 14 CFR Parts 91.203(a) and (b): Civil Aircraft: Certifications Required ...............................12

K. Title 14 CFR Parts 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 91.417(a) and (b): Maintenance 

and Inspections ..........................................................................................................................................12

VIII. Privacy ............................................................................................................................. 13

Attachments 

DJI PHANTOM 3 Pro User Manual 

DJI PHANTOM Advanced Manual 

DJI PHANTOM Flying Flowchart 

DJI PHANTOM Pilot Training Guide 

DJI PHANTOM Quick Start Manual 

GGI UAS Flight Operations Manual (V1.0) 

GGI UAS Pre-Flight & Maintenance Operations Log (V1.0) 
2 / 13 

I. GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

CFR Code of Federal Regulations 

COA Certificate Of Authorization 

DJI DJI Phantom 3 Pro 

FAA Federal Aviation Administration 

FCC Federal Communications Commission 

GCS Ground Control Station 

GGI Guardian Group, Inc. 

GPS Global Positioning System 

PIC Pilot In Command 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Sight 

VMC Visual Meteorological Conditions 

VO Visual Observer 
3 / 13 

II. INFORMATION SUPPORTING THIS PETITION AS SPECIFIED IN TITLE 14 CFR 

PART 11.81 

A. Mailing Address and Contact Information 

Guardian Group, Inc.

2350 W. 205th Street 

Torrance, CA 90501-1460 

Phone: (310) 320-0320 

Fax: (310) 320-0120 

B. Sections of Title 14 CFR from which GGI Seeks an Exemption 

Title 14 CFR Part Summary of Regulation 

Part 21 Airworthiness Certification 

21 Subpart H Certification procedures for products and parts, Airworthiness Certificates 

Part 45 Identification and Registration Marking 

45.23(b) Display of marks; general 

45.27(a) Location of marks on nonfixed-wing aircraft 

Part 61 Certifications: Pilots, Light Instructors, and Ground Instructors 

61.113(a) and (b) Private pilot privileges and limitations: Pilot in command 

Part 91 General Operating and Flight Rules 

91.7(a) Civil aircraft airworthiness 

91.9(b)(2) and (c) Civil aircraft flight manual, marking, and placard requirements 

91.103 Preflight action 

91.119 Minimum safe altitudes 

91.121 Altimeter settings 

91.151(a)(1) Fuel requirements for flights in VFR conditions 

91.203(a) and (b) Carry civil aircraft certification and registration 

91.405(a) Maintenance required 

91.407(a)(1) Operation after maintenance 

91.409(a)(2) Inspections 

91.417(a) and (b) Maintenance records 

C. Extent of Relief GGI’s Seeks 

GGI seeks exemption from several provisions of Title 14 CFR Parts 21, 45, 61, and 91 to the 

extent necessary to engage in commercial operations of a small UAS on sites where GGI 

conducts building inspections. If these exemptions are granted, GGI would operate the UAS with 

the permission of the property owner. GGI intends to use a UAS for the following: 

- Surveying hard-to-reach areas of building, 

- Rooftop inspection, 

- Building exterior envelope inspection. 

Sections III to VIII detail the measures GGI will be taking during the UAS operations to meet or 

exceed the level of safety authorized by the FAA, and demonstrate that GGI’s operations will not 

adversely affect the safety of persons or property in the air or on the ground and do not pose a 

threat to national security. 
4 / 13 

D. The Reasons why Granting GGI’s Request Would Be in Public Interest 

The proposed UAS operations in this petition significantly improve safety and reduce risk by 

alleviating the public's exposure to danger associated with traditional inspection methods. 

GGI will use the UAS as an alternative to large and inherently dangerous high-reach equipment 

such as lifts or scaffolds. 

Moreover, by using a UAS, GGI will reduce the risk of harm to employees by avoiding accidentprone, dangerous situations such as rooftop inspections or building envelope inspections above 

ground level. This would have a positive trickledown effect to families of GGI’s employees 

which ultimately benefits the public. 

The UAS that GGI intends to use is battery powered and does not release greenhouse gas

emissions. 

GGI’s UAS will be capable of documenting conditions that may have been otherwise inaccessible 

using traditional inspection and survey methods. 

E. The Reasons why Granting GGI’s Request Would Not Adversely Affect 

Safety 

GGI’s UAS operations will provide a level a safety that meet or exceed the level of safety 

authorized by the FAA. The operating procedures that will be implemented by GGI are detailed 

in sections III to VIII of the petition. 

F. Summary 

GGI seeks exemption from the requirements of Title 14 CFR Parts: 21 Subpart H, 45.23, 

45.27(a), 61.113(a) and (b), 91.7(a), 91.9(b)(2) and (c), 91.103, 91.119, 91.121, 91.151(a)(1), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) to the extent 

necessary to operate a UAS to perform aerial inspections of buildings within the United States. 

G. Additional Information Supporting GGI’s Request 

Sections III to VIII provide additional information supporting GGI’s request. 
5 / 13 

III. DESCRIPTION OF PETITIONER 

For over twenty years, GGI has served the surety, insurance, construction, legal, and banking 

industries with distinction. Our demonstrated proficiency with surety claims consulting, property 

claims consulting, construction claims, and construction consulting includes many of the world’s 

most challenging projects. GGI’s construction management and construction defect service value 

is grounded in that same surety claims and surety consulting experience. 

GGI provides clients a complete suite of construction defect services including, but not limited to: 

- Field investigative inspection and testing, 

- Defective construction analyses, 

- Architectural and engineering failure analyses, 

- Remedial repair scope and strategies. 

GGI seeks to use UAS—assisted photography and video to survey hard-to-reach areas of 

building, inspect rooftops, and building exterior envelopes. The use of a UAS would allow GGI 

to better address its client’s needs. It will provide a safer and more efficient mean to perform field 

investigative inspections. 

IV. UNMANNED AIRCRAFT SYSTEM 

The UAS proposed by GGI is the DJI Phantom 3 Pro (“DJI”). The DJI Phantom 3 Pro is a 

battery-operated lightweight quadcopter with on-board equipment and controlled via radio 

transmission from a separate Ground Control Station (“GCS”) used. See Figure 1.

The on-board flight computer is in constant communication with the GCS and transmits live data 

such as speed, compass direction of flight, and altitude levels. 

The UAS contains a Global Positioning System (“GPS”) tracking device and an on-board gimbalmounted camera capable of capturing full color high definition photos and videos. 

The UAS is also equipped with a set of LEDs and aircraft status indicators which not only 

provide an enhanced visual from the ground but also assist the Pilot In Command (“PIC”) to 

confirm battery, GPS, and other functionalities of the UAS. 

Figure 1: DJI Phantom 3 Pro 
6 / 13 

A. UAS Performance 

Below are the DJI Phantom 3 Pro Aircraft specifications: 

Metric Imperial 

Weight (Including Battery 

and Propellers) 1280 g 2.8 lb 

Diagonal Size (Including 

Propellers) 590 mm 23.2 in 

Max Ascent Speed 5 m/s 9.7 knots (11.2 mph) 

Max Descent Speed 3 m/s 5.8 knots (6.7 mph) 

Hover Accuracy 

Vertical: +/- 0.1 m (when Vision 

Positioning is active) or +/- 0.5 m 

Vertical: +/- 4 in (when Vision 

Positioning is active) or +/- 20 in 

Horizontal: +/- 1.5 m Horizontal: +/- 59 in 

Max Speed 16 m/s (ATTI mode, no wind) 31.1 knots (35.8 mph) (ATTI 

mode, no wind) 

Max Altitude Above Sea 

Level 6000 m 3.73 mi 

Operating Temperature 0°C to 40°C 32°F to 104°F 

GPS Mode GPS/GLONASS

Ref.: http://www.dji.com/product/phantom-3/spec

DJI Phantom 3 Pro is equipped with the FAILSAFE feature: If the aircraft battery is running low, 

or if the DJI loses the connection with your remote controller for any reason, the aircraft will 

automatically return to the takeoff point and land safely. 

Operation Conditions and Limitations – UAS Performance 

- The DJI Phantom 3 Pro will weigh less than 3 pounds including payload. 

- The speed of the DJI Phantom 3 Pro will not exceed 87 knots (100 miles per hour). The 

DJI Phantom 3 Pro will be operated at airspeeds greater than the maximum Unmanned 

Aircraft operating airspeed recommended by the manufacturer. 

- If the UAS loses communications or loses its GPS signal, the DJI Phantom 3 Pro will

return to a pre-determined location within the private or controlled-access property. 

B. Pre-Flight Inspections, Maintenance, and Repair 

GGI will implement all necessary procedures, such as pre-flight inspections, maintenance, and 

repair to ensure that the DJI Phantom 3 Pro is in a condition for safe flight. 

Operation Conditions and Limitations – Pre-Flight Inspections, Maintenance, and Repair 

[Continued on next page]

- If the DJI Phantom 3 Pro is to undergo maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, the 

UAS will undergo a functional test flight prior to conducting further operations. 

Functional test flights will only be conducted by a PIC with a Visual Observer (“VO”) 

and must remain at least 500 feet from people. The functional test flight will be 

conducted in such a manner so as to not pose an undue hazard to persons and property. 
7 / 13 

Operation Conditions and Limitations – Pre-Flight Inspections, Maintenance, and Repair 

- GGI will be responsible for maintaining and inspecting the DJI Phantom 3 Pro to ensure 

that it is in a condition for safe operation. 

- Prior to each flight, the PIC will 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 will not be operated 

until necessary maintenance has been performed and the UAS is found to be in a 

condition for a safe flight. 

- GGI will follow the DJI Phantom 3 Pro manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

Please find attached GGI UAS Flight Operations Manual (V1.0) and GGI UAS Pre-Flight & 

Maintenance Operations Log (V1.0). 

C. Radio Frequency 

The operating frequency of the Remote Controller (i.e. GCS) ranges from 2.400 GHz to 2.483 

GHz. 

The radio frequency used for control of the UAS associated equipment (camera, sensors, etc.) is 

2.4 GHz ISM. 

The DJI Phantom 3 Pro complies with the Federal Communications Commission (“FCC”) 

regulations. 

V. UNMANNED AIRCRAFT PILOT IN COMMAND 

A designated pilot will be operating the DJI Phantom 3 Pro. GGI designated pilot will: 

- Hold a private pilot’s license, 

- Hold a current third-class medical certificate, 

- Have a deep knowledge and thorough understanding of the UAS and its operation, 

- Have experience in operating the DJI Phantom 3 Pro. 

The PIC will be assisted by a VO at all times during the DJI Phantom 3 operations. 

Operation Conditions and Limitations – PIC Qualifications and Training 

[Continued on next page]

- The PIC will be designated before the flight and will not transfer his or her designation 

for the duration of the flight. 

- The PIC will hold a private pilot certificate and a FAA airman medical certificate. 
8 / 13 

Operation Conditions and Limitations – PIC Qualifications and Training 

- GGI will not permit any PIC to operate unless the PIC demonstrates 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 persons, vessels, vehicles, and structures. PIC qualification flight hours 

and currency will be logged in a manner consistent with Title 14 CFR Part 61.51(b). 

Training operations will be conducted during dedicated training sessions. 

- All operations will utilize a visual observer (VO). 

VI. OPERATION OF THE UNMANNED AIRCRAFT 

A. Intended UAS Operations 

GGI intends to use the DJI Phantom 3 Proto perform forensic evaluations and building condition 

assessments. 

GGI’s operations will provide a superior level of safety. Please refer to sections VI.B: Limitations 

of UAS Operations, and VII: Discussion Of Requested Exemption, and attached document: GGI 

UAS Flight Manual (V1.0). 

B. Limitations Of UAS Operations 

Operation Conditions and Limitations – UAS Operations [Continued on next page]

- The speed of the DJI Phantom 3 Pro will not exceed 87 knots (100 miles per hour). The 

DJI Phantom 3 Pro will be operated at airspeeds greater than the maximum Unmanned 

Aircraft operating airspeed recommended by the manufacturer. [Section IV.A] 

- The DJI Phantom 3 Pro will not be operated at an altitude of no more than 400 feet 

Above the Ground Level (“AGL”). [Section IV.A] 

- The DJI Phantom 3 Pro will be operated at an altitude of no more than 400 feet AGL. 

- The DJI Phantom 3 Pro will be operated within the visual line of sight (“VLOS”) of the 

PIC and VO at all times. The VO and PIC will be able to communicate verbally at all 

times. The PIC will ensure that the VO can perform the duties required of the VO. 

- UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (“VMC”). 

- The DJI Phantom 3 Pro will not operate within 5 nautical miles of an airport having an 

operational control tower unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a Certificate Of Waiver or Authorization (“COA”) 

issued to GGI. 

- The DJI Phantom 3 Pro will 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. 

- The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 
9 / 13 

Operation Conditions and Limitations – UAS Operations 

- The PIC will be prohibited from flying unless (considering wind and forecast weather 

conditions) there is enough available power for the UAS 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. 

- The DJI Phantom 3 Pro will remain clear and give way to all manned aviation operations

and activities at all times. 

- The UAS will not be operated by the PIC from any moving device or vehicle. 

- All 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. GGI will 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 UAS, flight operations will cease immediately in a manner ensuring 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 objects and determined 

that it does not present an undue hazard. 

- All operations will be conducted over private or controlled-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. 

VII. DISCUSSION OF REQUESTED EXEMPTIONS 

A. Title 24 CFR Part 21, Subpart H: Certification Procedures for Products 

and Parts, Airworthiness Certificates 

The FAA has stated that no exemption is needed from this section if a finding is made under the 

Reform Act that the UAS selected provides an equivalent level of safety when compared to 

aircraft normally used for the same application. See granted exemption to Astraeus Aerial, Docket 

No. FAA-2014-0352 at 13-14, 22. If, however, the FAA determines that there are some 

characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an 

exemption is requested. 

The UAS operated will have a gross weight less than 55 pounds and will be flown at speeds less 

than 87 knots (100 miles per hour). It will not carry a pilot or passengers, or flammable fuels and 

will be operated in well-defined locations using a PIC and a VO. All operations will be conducted 

in compliance with the limitations and conditions stated in this petition for exemption. 

The characteristics and conditions under which the UAS will be operated, as outlined in this 

petition, given the size, weight, speed, operation capability and proximity to airports and 

populated areas, achieve or exceed the equivalent level of safety over a manned aircraft with an 

airworthiness certificate used for the purposes outlined in this petition. 
10 / 13 

B. Title 14 CFR Parts 45.23(b) and 45.27(a): Aircraft Marking and

Identification Requirements 

GGI seeks an exemption from the aircraft marking and identification requirements contained in 

Title 14 CFR Parts 45.23(b) and 45.27(a). In a previous grant of exemption, the FAA determined 

that exemption from these requirements was warranted, under the following conditions: the 

aircraft shall “have identification (N-Number) markings in accordance with 14 C.F.R Part 45, 

Subpart C if the markings are as large as practicable.” FAA Docket No. FAA-2014-0352. 

C. Title 14 CFR Parts 61.113(a) and (b): Private Pilot Privileges and 

Limitations: Pilot in Command 

GGI seeks exemption from Title 14 CFR Parts 61.113(a) and (b) which restricts private pilot 

certificate holders from flying aircraft for compensation or hire and would also require a Class II 

medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC 

matches the airspace in which the PIC will be operating, as well as requiring certifications if the 

private pilot is carrying passengers or cargo for hire. In this case, while the UAS will be operated 

as part of a commercial operation, it carries neither passengers nor cargo. 

In the Grant of Exemption to Astraeus Aerial, the FAA determined that the unique characteristics 

of UAS operation outside of controlled airspace did not warrant the addition cost and restrictions 

attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II medical 

certificate. The fulfillment of the additional requirements for a private pilot to become qualified 

as a commercial pilot would not lead to any additional safety benefits when UAS operations are 

involved. Furthermore, while helpful, a pilot license will not ensure remote control piloting skills. 

The risks associated with the operation of small UAS are far less than the risks associated with 

the commercial activities outlined in Title 14 CFR Parts 61.113 (a) and (b). 

D. Title 14 CFR Part 91.7(a): Civil Aircraft Airworthiness 

GGI seeks an exemption from Title 14 CFR Part 91.7(a), which requires that a civil aircraft be in 

airworthy condition to be operated. The FAA has stated that no exemption is required for Title 14 

CFR Part 91.7(a) to the extent that the requirements of Part 21 are waived or found inapplicable. 

See Docket No. FAA-2014-0352 at 13-14, 22. 

E. Title 14 CFR Part 91.9(b)(2) and (c): Civil Aircraft Flight Manual in the 

Aircraft 

GGI seeks exemption from Title 14 CFR Part 91.9(b)(2) and (c). Given the small size and 

configuration of the UAS, it would be impossible to keep airworthiness documents and other 

aircraft manuals on board because there is simply no room, and the UAS has no cabin or cockpit. 

The UAS flight manual, registration certificate, and other documentation will be kept at the 

control station with the operator during flight. This alternate method constitutes full compliance 

with the regulations. 
11 / 13 

F. Title 14 CFR Part 91.103: Preflight Action 

GGI seeks an exemption from Title 14 CFR Part 91.103, which requires the PIC to become 

familiar with specific information before each flight, including information contained in the 

FAA-approved Flight Manual on board the aircraft. 

The PIC will review information prior to flight to maintain the safety of the operation, including 

but not limited to, the weather, battery levels, landing and takeoff distances, and aircraft 

performance data. The PIC will refer to the manufacturer supplied UAS manual and GGI Flight 

Operations Manual for technical data and information as provided. The manual will be kept at the 

GCS during operations. 

While the PIC will be familiar with all information necessary to safely conduct the flight, an 

exemption is requested to the extent that an FAA-approved Flight Manual is required. 

G. Title 14 CFR Part 91.119: Minimum Safe Altitudes 

GGI seeks an exemption from the minimum safe altitude requirements of Title 14 CFR Part 

91.119. This section prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in 

non-congested areas. See Title 14 CFR Part 14 C.F.R. 91.119(c). 

Title 14 CFR Part 91.119(d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated “without hazard to persons or property on the surface” provided 

that “each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA.” An exemption is required because the proposed UAS 

operations will occur below 400 feet AGL. Additionally, due the nature of the proposed 

operations, the PIC and/or VO may need to be less than 500 feet away from the UAS. 

The UAS operated by GGI are far smaller than manned aircraft, such as rotorcraft and fixed 

winged aircraft. Additionally, the UAS do not carry a pilot or passengers, weigh less than 55 

pounds, do not carry flammable fuel, will not exceed 87 knots (100 mph), and it will not be 

operated over non-participating persons. The UAS will be operated below 400 feet AGL with the 

use of a PIC and a VO to avoid risk to aircraft, persons and property. This provides an equivalent 

or greater level of safety than achieved with conventional aircraft currently performing similar 

operations. 

H. Title 14 CFR Part 91.121: Altimeter Settings 

GGI seeks an exemption from Title 14 CFR Part 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is required to the extent 

that the UASs do not have a barometric altimeter but rather GPS altitude display. 

The operator will confirm the elevation of the launch site prior to launch. This will be compared 

to the GPS sensor or barometric sensor derived altitude as displayed on the UAS reading at the 

GCS. The operator will then determine the maximum permissible altitude to maintain flight 

below 400 feet AGL and will not exceed this altitude. The maximum permissible altitude will 

also be monitored and estimated by visual means through the use of the PIC and VO. This 

provides a level a safety equal to or exceeding the regulation. 
12 / 13 

I. Title 14 CFR Part 91.151(a)(1): Fuel Requirements for Flight in Visual 

Flight Rules Conditions 

GGI seeks an exemption from Title 14 CFR Part 91.151(a)(1): Fuel Requirements for Flight in 

Visual Flight Rules (“VFR”) Conditions. The technological limitations on UAS battery power 

means that no meaningful flight operations can be conducted while still maintaining a 30-minute 

battery reserve. An exemption from the fuel requirements of Title 14 CFR Part 91.151(a) is 

therefore required. 

The UAS flight will be terminated with at least 20% reserve power. This allows the UAS to 

return to its landing zone with adequate power remaining to conduct a safe and controlled 

landing. Given the UAS’s size, weight, and speed, the UAS when operated with this limitation 

provides an equivalent or greater level of safety than manned aircraft represented by this 

regulation. 

J. Title 14 CFR Parts 91.203(a) and (b): Civil Aircraft: Certifications 

Required 

Title 14 CFR Part 91.203(a) states that: “No person may operate a civil aircraft unless it has [...] 

an appropriate and current airworthiness certificate.” Furthermore, Title 14 CFR Parts 91.203(b) 

states that: “No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under §91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” 

In regard to Title 14 CFR Part 91.203(a), an equivalent level of safety is achieved through the

methods and characteristics as outlined in the request for exemption from Title 14 CFR Part 21, 

Subpart H. 

In regard to Title 14 CFR Part 91.203 (b), the UAS does not carry a pilot or passengers, does not 

have a cabin or cockpit entrance, and does not have on-board storage in which to carry

certification and registration documents. An equivalent level of safety will be achieved by 

maintaining the proper documentation at the GCS readily available. This alternate method 

constitutes full compliance with the regulations. 

K. Title 14 CFR Parts 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), 

91.417(a) and (b): Maintenance and Inspections 

GGI seeks an exemption from the maintenance inspection requirements contained in Title 14 

CFR Parts 91.405(a), 91.407(a)(1) and (2), 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to Title 14 CFR Part 43. An exemption from 

these regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS to be operated under this grant of exemption will not 

have. 

The UAS will be maintained and inspected in accordance with the manufacturer-supplied manual 

and GGI UAS Pre-Flight & Maintenance Operations Log. This includes maintenance, overhaul, 

replacement and inspection requirements for the UAS. The PIC, prior to the first flight of the day 

and as deemed necessary otherwise, will undertake preflight inspection procedures in order to 

ensure the UAS is in a condition for safe operation. Discrepancies that may affect the safety of 

flight will be addressed and repaired if required. The PIC and GGI will maintain the UAS in a 

condition for safe operation. 
13 / 13 

Given the size, characteristics, and operating limitations of UAS as described herein, this 

provides a level of safety equivalent to or greater than manned aircraft performing similar 

operations. 

VIII. PRIVACY 

GGI’s UAS operations will be conducted in accordance with applicable federal, state, or local 

laws regarding privacy. All operations shall be conducted over private or controlled-access 

property with permission from the land/building owner/controller or authorized representative. 

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

flight to be conducted. Notification of inspection activities (including UAS operations) will be 

delivered via land/building owner/controller or authorized representative a minimum of 24 hours 

prior to inspection day/UAS operations.