1 / 13

**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 Int erest ........................................ 4 E. The Reasons why Granting GGI’s Request Would Not Adversely Aff ect 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 P roducts and Parts, Airworthiness Certificates ..........................................

................................................... ................................................... . 9 B. Title 14 CFR Parts 45.23(b) and 45.27(a): Aircraft Marking an d Identification Requirements ......10 C. Title 14 CFR Parts 61.113(a) and (b): Private Pilot Privileg es 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 Fligh t in Visual Flight Rules Conditions .12 J. Title 14 CFR Parts 91.203(a) and (b): Civil Aircraft: Certif ications Required ...............................12 K. Title 14 CFR Parts 91.405(a), 91.407(a)(1), 91.409(a)(1) an d (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 Observer3 / 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. 205 th

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 Certifica tes 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 comma nd 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 site s where GGI conducts building inspections. If these exemptions are granted, GGI would operate the U AS 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 ope rations to meet or exceed the level of safety authorized by the FAA, and demonstrate that GGI’s operat ions 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 red uce risk by alleviating the public's exposure to danger associated with traditional inspe ction methods.

GGI will use the UAS as an alternative to large and inherently dangerous hi gh-reach equipment such as lifts or scaffolds.

Moreover, by using a UAS, GGI will reduce the risk of harm to employees by avoiding acci dentprone, dangerous situations such as rooftop inspections or building envelope inspection s above ground level. This would have a positive trickledown effect to families o f 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 ina ccessible 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 lev el of safety authorized by the FAA. The operating procedures that will be implemented by GGI a re 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 Uni ted 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 th e world’s most challenging projects. GGI’s construction management and construction defect s ervice value is grounded in that same surety claims and surety consulting experience.

GGI provides clients a complete suite of construction defect services incl uding, 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 r adio 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 liv e 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 whi ch 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 Pro6 / 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 i s running low, or if the DJI loses the connection with your remote controller for any reason, the air craft 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 Unma nned 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 prop erty.

B. Pre-Flight Inspections, Maintenance, and Repair

GGI will implement all necessary procedures, such as pre-flight inspections, m aintenance, 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 UA S operation or flight characteristics, e.g. replacement of a flight critical compone nt, 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 pote ntial discrepancies, e.g. inoperable components, items, or equipment. If the inspection rev eals a condition that affects the safe operation of the UAS, the aircraft will not be o perated 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 P re-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, e tc.) 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 designat ion for the duration of the flight.

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

Operation Conditions and Limitations – PIC Qualifications and Training

- GGI will not permit any PIC to operate unless the PIC demonstrates ability to saf ely operate the UAS in a manner consistent with how the UAS will be operated under th is exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles, and structures. PIC qualification fl ight 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 cond ition assessments.

GGI’s operations will provide a superior level of safety. Please refer to sect ions 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 a t 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 ma nagement 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 emergenci es.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 pow er 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 nonparticipa ting 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 protecti on. 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 ensur ing the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects, and the PIC has made a safety assessment of the risk of operating closer to those objects and d etermined 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. Permissi on from property owner/controller or authorized representative will be obtained for e ach flight to be conducted.

**VII. DISCUSSION OF REQUESTED EXEMPTIONS** 

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

The FAA has stated that no exemption is needed from this section i f a finding is made under the Reform Act that the UAS selected provides an equivalent level o f 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 requirem ents 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 wi ll be conducted in compliance with the limitations and conditions stated in this petition fo r exemption.

The characteristics and conditions under which the UAS will be ope rated, as outlined in this petition, given the size, weight, speed, operation capability and proximit y 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 a nd Limitations: Pilot in Command

GGI seeks exemption from Title 14 CFR Parts 61.113(a) and (b) which restr icts private pilot certificate holders from flying aircraft for compensation or hire and woul d also require a Class II medical certificate. The purpose of Part 61 is to ensure that the s kill and competency of any PIC matches the airspace in which the PIC will be operating, as wel l as requiring certifications if the private pilot is carrying passengers or cargo for hire. In this case, whi le 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 addit ion cost and restrictions attendant with requiring a the PIC to have a Commercial Pilot Cer tificate and Class II medical certificate. The fulfillment of the additional requirements for a pri vate 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 air craft 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 inappl icable. See Docket No. FAA-2014-0352 at 13-14, 22

.

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

GGI seeks exemption from Title 14 CFR Part 91.9(b)(2) and (c). Given th e 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 documentat ion will be kept at the control station with the operator during flight. This alternate method const itutes 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 tak eoff distances, and aircraft performance data. The PIC will refer to the manufacturer supplied UAS ma nual 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 t o safely conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is requi red.

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 a ircraft may not operate, including 500 feet above the surface and away from any person, vessel, vehi cle, 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 alt itudes 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 t he 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 pas sengers, 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 fee t 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 c urrently 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 refe rence to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is re quired to the extent that the UASs do not have a barometric altimeter but rather GPS altitude di splay.

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 displa yed on the UAS reading at the GCS. The operator will then determine the maximum permissible alti tude 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 P IC 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 Vi sual Flight Rules Conditions

GGI seeks an exemption from Title 14 CFR Part 91.151(a)(1): Fuel Requ irements for Flight in Visual Flight Rules (“VFR”) Conditions. The technological limitat ions on UAS battery power means that no meaningful flight operations can be conducted while stil l maintaining a 30-minute battery reserve. An exemption from the fuel requirements of Title 14 CFR P art 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 operate d 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: Certifi cations 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 i s displayed at the cabin or cockpit entrance so that it is legible to passeng ers 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 wi ll be achieved by maintaining the proper documentation at the GCS readily available. This alt ernate 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 a pply 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 include s 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 pr ocedures in order to ensure the UAS is in a condition for safe operation. Discrepancies t hat may affect the safety of flight will be addressed and repaired if required. The PIC and GGI wil l maintain the UAS in a condition for safe operation.13 / 13

Given the size, characteristics, and operating limitations of UA S as described herein, this provides a level of safety equivalent to or greater than manned ai rcraft performing similar operations.

**VIII. PRIVACY**  GGI’s UAS operations will be conducted in accordance with applicable federal, s tate, or local laws regarding privacy. All operations shall be conducted over private or controll ed-access property with permission from the land/building owner/controller or authorized represe ntative. Permission from land owner/controller or authorized representative will be obtained for ea ch flight to be conducted. Notification of inspection activities (including UAS operat ions) will be delivered via land/building owner/controller or authorized representative a minimum of 24 hours prior to inspection day/UAS operations.