June 1, 2015

Exemption No. 11731

Regulatory Docket No. FAA–2015–0061

Mr. F. B. (Ben) Harvie, Jr.

Counsel for D&C Inspection Services, Inc.

12600 North Featherwood

Suite 120

Houston, TX 77034

Dear Mr. Harvie:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated January 12, 2015,

1 you petitioned the Federal Aviation Administration (FAA) 

on behalf of D&C Inspection Services, Inc. (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct inspections of industrial complexes, transportation facilities, and other structural 

entities.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received seven comments in support of the petition made to the docket.

 

1 On May 11, 2015, the petitioner responded to the FAA’s request for information.
2

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision, DJI Phantom 2 Vision +, 

Steadydrone QU4D, DJI S1000, DJI Inspire 1, and DJI Flamewheel F550.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

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

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

14 CFR part 21 and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

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

2 The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

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

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

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

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

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

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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delegated to me by the Administrator, D&C Inspection Services, Inc. is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

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

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

Conditions and Limitations

In this grant of exemption, D&C Inspection Services, Inc. is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision, DJI Phantom 2 Vision +, Steadydrone QU4D, DJI S1000, DJI Inspire 1, and 

DJI Flamewheel F550 when weighing less than 55 pounds including payload. 

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

amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 
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duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

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

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

the operator must petition for an amendment to its grant of exemption. The FAA’s 

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

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

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

safety bulletins.
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13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

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

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

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

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

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

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

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

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

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 
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intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

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

activities at all times. 

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

26. All Flight 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 UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or 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.
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28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

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

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

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

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

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

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

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

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

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

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

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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NOVELLI, HARVIE & ASSOCIATES,

Attorneys at Law, P.L.L.C.

12600 North Featherwood, Suite 120

Houston, Texas 77034

Tel. (281) 484-9500

Fax (281) 484-9519

www.nhapllc.com

F.B. Harvie, Jr. 

(Attorney) bharvie@nhapllc.com

January 12, 2015

United States Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Attn: Bill Crozier, Assistant Manager, UAS Integration Office, AFS-80

Re: 

Dear Mr. Crozier:

1. Applicant’s name, address and contact number are:

D&C Inspection Services, Inc.

2215 Repsdorph Rd., Seabrook, Texas 77586

Attn: Daniel Harry

Email: dan@dcinspection.com

Phone No.: (281) 326-1800

2. Applicant’s agent:

F.B. (Ben) Harvie, Jr., Attorney At Law

12600 N. Featherwood, Suite 120, Houston, Texas 77034

Email: bharvie@nhapllc.com

Phone No.: (281) 484-9500

3. Purpose for Request:

To secure an exemption to operate a sUAS under controlled 

conditions in defined airspace which would provide an enhanced 

level of safety to the successful operation of Applicant’s business 

which includes, but is not limited to, inspection of industrial 

complexes, transportation facilities and other structural entities that 

are subject to and in need of periodic or routine safety inspections 

by persons authorized either by regulation or by industry standard 

1) Applicant: D&C Inspection Services, Inc.

2) Request for exemption Under Section 333 of the FAA Modernization 

and Reform Act of 2012 (Reform Act)
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to determine the condition of the objects being inspected and to 

assure and establish a level of safe use and operations for which the 

inspected items are intended.

4. Regulation:

The exemptions requested and/or required are from 14 CFR and are 

as follows:

Part 21

45.23(b)

61.113 (a) & (b)

91.7 (a)

91.9 (b) (2)

91.103

91.109

91.119

91.121

91.151 (a)

91.203 (a) & (b)

91.405 (a)

407 (a) (1)

409 (a) (2)

417 (a) & (b); and

Any other provisions out of Title 14, Code of Federal 

Regulations, that may be applicable to Applicant’s specific 

use and not listed above. 

5. Public Interest:

Enhancement of Industry Safety. 

The exemption requested is in the public interest because the 

intended purpose of the operation of sUAS will enhance the safety 

of the inspection process presently utilized by Applicant which may 

have required, from time-to-time, inspectors to be on scaffold

structures or other dangerous environments, or other hazardous 

conditions, in order to perform the inspections which are necessary 

and required to comply with industry standards or governmental 

regulations.

Development of Firefighting Techniques

The public interest would also be enhanced because 

Applicant intends to develop a heat-sensing device for use by

firefighting agencies that would detect dangerous hotspots, thereby 

reducing the hazardous work environment of firefighters and 

enhancing their rescue operations. 
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Protection of Privacy

Applicant has adopted a privacy policy that requires the 

operator to assure that no information or data of persons not engaged 

in the intended operation is collected, used, or disseminated so as to 

achieve the public’s expectation of privacy. 

6. Previous exemptions:

The FAA has previously granted exemptions under Section 333 for 

similar operations in Exemption Nos.:

1. 11063

2. 11064

3. 11065

4. 11066

5. 11067

6. 11080

7. Conditions and limitations:

A. Applicant proposes to adopt:

1. A Pilot Operating Handbook (POH) and/or

2. Flight Operations and Procedures Manual (FOPM) 

3. Manufacturers Pilot Training Guide (MPTG)

4. UAV Check-List

B. Applicant proposes the following conditions and/or limitations:

1. UA must weigh less than 55 pounds;

2. UA airspeed not to exceed 50 knots;

3. UA flights may not operate at more than 400 AGL and 

Altitudes reported to ATC must be in feet AGL;

4. UA must be operated within visual line of sight (VLOS) of 

the PIC;

5. All operations will utilize a visual observer (VO). The VO

may be utilized as long as the PIC maintains VLOS 

capability and can communicate with the VO at all times;

6. The conditions and limitations will be added or amended in 

the operator’s manual;

7. The PIC will inspect the UAS to ensure it is safe for flight, 

along with the Ground Control Station (GCS) if utilized. All 

maintenance and alterations must be properly documented.

8. A functional test flight must be performed for any UAS that 

has undergone maintenance or alterations and be performed 

by the PIC and added to the operator’s manual;

9. The operator must follows the manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement 

inspection and life limit requirements. The following must 
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be included in the operator’s manual;

A. Actuators / Servos;

B. Transmission (single rotor);

C. Power plant (motors);

D. Propellers;

E. Electronic speed controller;

F. Batteries;

G. Mechanical or dynamic components (single 

rotor);

H. Remote command and control;

I. Ground control station (if used); and

J. Any other component(s) as determined by the 

operator.

10. The PIC must possess a private pilot certificate, a current 

third-class medical certificate and meet the flight review 

requirements specified in 14 CFR § 61.56;

11. A PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of 200 flight 

hours and 25 hours as a UAS rotorcraft pilot and at least ten 

hours logged as a UAS pilot with a similar UAS type;

12. A PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of five hours 

as a UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three takeoffs and three landings in the preceding 90 days. The PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119;

13. The PIC and VO must have completed a qualification 

process;

14. A flight demonstration, administered by an operatorapproved and -qualified pilot must be completed and 

documented in accordance with the operator’s manual;

15. The UA may not be operated directly over any person, 

except authorized and consenting inspection personnel, 

below an altitude that is hazardous to persons or property;

16. All participating persons must be essential and consent to the 

UAV operation which should require no further FSDO or 

ASI approval;

17. The operator must ensure that no persons are allowed within 

500 feet of the area except those consenting to be involved 

and who are necessary for the on-going operation of the 

entity being inspected;

18. If the UAS loses communications or loses its Global 

Positioning System (GPS) signal, the UA must return to a 
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pre-determined location within the security perimeter and 

land or be recovered in accordance with the operator’s 

manual;

19. The UAS must abort the flight in the event of unpredicted 

obstacles or emergencies in accordance with the operator’s 

manual;

20. Each operation must be completed within 30 minutes flight 

time or with 25% battery power remaining, whichever 

occurs first;

21. The operator must contain an Air Traffic Organization 

(ATO) issued Certificate of Waiver or Authorization (COA) 

prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to 

request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but no less than 48 hours prior to the 

operation; 

22. All aircraft operated in accordance with this exemption must 

be identified by serial number, registered in accordance with 

14 CFR part 47and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. 

Markings must be as large as possible;

23. The operator must develop procedures to document and 

maintain a record of the UAS maintenance, alterations, 

status of replacement/overhaul component parts, and the 

total time in service of the UAS.

24. Each UAS operated under this exemption will comply with 

all manufacturing safety bulletins; 

25. The operator will develop UAS technician qualification 

criteria. And the criteria will be in the operator’s manuel;

26. The pre-flight inspections section of the operator’s manual 

will include the requirement that the pre-flight inspection 

will account for all discrepancies, i.e. inoperable 

components, items, or equipment; 

27. Before conducting operations, the radio frequency spectrum 

used for operation and control of the UA will comply with 

the FCC or other appropriate government oversight agency 

requirements;

28. At least three days before a scheduled inspection the 

operator of the UAS affected by this exemption will submit 

a written plan of activity to the local FSDO with jurisdiction 

over the area of the proposed inspection. The 3-day 

notification may be waived with the concurrence of the 

FSDO. The plan of activities will include the following:

A. Dates and times for all flights 
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B. Name and phone number of the operator for the UAS 

inspection conducted under this grant of exemption 

C. Name and phone number of the person responsible 

for the on-site operation of the UAS 

D. Make, model, and serial or N-number of UAS to be 

used

E. Name and certificate number of UAS PIC s involved 

in the inspection process 

F. A statement that the operator has obtained 

permission from property owners and/or local 

officials to conduct the inspection; the list of those 

who gave permission shall be made available to the 

inspector upon request

G. Signature of exemption-holder or representative 

H. The description of the flight activity, including maps 

or diagrams of any area, city, town, county, and/or 

state over which the inspection will be conducted and 

the altitudes essential to accomplish the operation.

29. The documents required under 14 CFR §§91.9 and 91.203 

must be available to the PIC at the ground control station of 

the UAS any time the aircraft is operating. These documents 

must be made available to the Administrator or any law 

enforcement official upon request; 

30. The UA must remain clear and yield the right of way to all 

other manned operations and activities at all times (including, 

but not limited to ultra-light vehicles, parachute activities, 

parasailing activities, hand gliding, etc.);

31. UAS operations may not be conducted during night, as 

defined in 14 CFR § 1.1 All operations must be conducted 

under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized;

32. The UAS cannot be operated by the PIC from any moving 

device or vehicle;

33. The UA may not be operated less than 500 feet below or less 

than 2000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC;

34. The UA may not be operated in class B, C, or D airspace 

without written approval from the FAA. The UA may not 

operate within 5 nautical miles of the geographic center of a 

non-towered airport as denoted on a current FAA- published 

aeronautical chart unless a letter of agreement with the 

airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the 

operator’s COA. The letter of agreement with the airport 
management must be made ava ilable to the administrator 

upon request. 

35. Any I) Incident, 2) Acc ident, or 3) Flight operation that 

transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be 

reported to the Federal Aviation Administration's (FAA) 

UAS Integration Office (AFS-80) within 24 hour. Accidents 

must be reported to the National Transportation Safety Board 

(NTSB) per instruction contained on the NTSB '.-veb site: 

www. ntsb.gov. Further fl ight operations may not be 

conducted unti I the incident, accident, or transgression is 

reviewed by the A FS-80 and authorized to resume operations 

is provided. 

36. The UAS, PIC and operator will comply with all applicable 

parts of 14 CFR including, but not limited to, parts 

45,47,6 1.9 1. 

The criteria proposed in this application are believed to have previously been reviewed and 

approved with prior exemptions and given the public need for the inspections mandated by 

regulation or suggested by industry standards provides the assurance sought by the Federal Aviation 

Act of 1958 and the FAA modernization and reform act of 20 12 to ensure the safe operations 

anticipated in this request of the aircraft in the national airspace system. 

Your review and reply are greatly appreciated. My office is adjacent to the FSDO offi ce 

on Featherwood in Houston, Texas and would faci litate our in person communication should it be 

necessary. 

Very Truly Yours, 

NOVELLI, HARV IE & A. 

Attorneys at law, PLLC 

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