AFS-15-047-E Exemption No. 11184

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

LOWCOUNTRYRC, CORPORATION

for an exemption from part 21, Subpart H; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations Regulatory Docket No. FAA-2014-0803

GRANT OF EXEMPTION

By letter dated September 29, 2014, Mr. Anthony J. Marino, President of LowCountryRC, Corporation (hereinafter Pe titioner or Operator), 3104 River Drive, Thunderbolt, GA 31404, petitioned the Federa l Aviation Administration (FAA) for an exemption from part 21, Subpart H; §§ 45.23( b); 61.113(a) and (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203( a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The exemption would allow the petitioner to opera te the DJI S1000 unmanned aircraft system (UAS) to conduct high definition aerial phot ography for the inspection of towers and

structures.

The petitioner supports its request with the following information:

The petitioner proposes to operate the DJI S1000 UAS primarily to conduct high definition aerial photography primarily for the inspection of towers and structures, although a potential exists to aid law enforcement personnel and firs t responders in search and rescue operations. See Appendix A for the petition submitted to the FAA, including the regulations from which the petitioner seeks an exemption.

The petitioner has provided the following informa tion to support its requ est for an exemption, which includes proprietary supporting documents:2 1. A2 Flight Control System User Manual V1.20 2. A2 Product Release Notes 3. Low Country RC Flight Manual 12-14-2014 4. Low Country RC Maintenance Manual 12-14-2014 5. Low Country RC Futaba Specification sheet
6. DJI S1000 User Manual
7. DJI S1000 Product Release Notes 8. WooKong-M Quick Start Guide 9. WooKong-M Product Release Notes 10. Zenmuse Z15 User Manual 11. Zenmuse Z15 Product Release Notes

The FAA evaluated the petition and determined it was not precedent se tting. Therefore, a summary of the petition was not published in the Federal Register for public comment.

The FAA’s analysis is as follows:

The FAA has organized its analysis into f our sections: (1) UAS, (2) the UAS pilot in command (PIC), (3) the UAS operating para meters, and (4) the public interest.

UAS

The petitioner requested relief from 14 CFR part 21, Certification Procedures for Products and Parts ; specifically, Subpart H, Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of P.L. 112-95 in reference to 49 USC § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the S ecretary of Transportation has de termined that this aircraft meets the conditions of Section 333. Therefore, th e FAA finds that the re quested relief from 14 CFR part 21, and any associated noise certific ation and testing requirements of part 36, is not necessary.

Tower and structure inspections are hazardous and present unique difficulties for persons conducting inspections and maintena nce of this infrastructure. The inspections are normally conducted utilizing personnel to physically inspect the towe r and structure. Manned helicopters may also be used to transport inspection personnel to the top of the tower so that a physical inspection may be conducted. The petiti oner plans to utilize a UAS to provide high definition aerial photography to minimize the need for inspectors to personally climb such structures. Manned helicopters a ssisting in tower and struct ure inspections can weigh 6,000 pounds or more and are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s unm anned aircraft (UA) will weigh less than 55 pounds with no onboard pilot or crew . The pilot and crew will be remotely located from the aircraft. The limited weight and restricted sterile area significa ntly reduces the potential for harm to participating and nonpartic ipating individuals or property in the event of an incident or accident. The risk to an onboard pilot and crew during an incident or accident is eliminated3 with the use of a UA for the in spection operation. In addition, utilizing UAS to conduct tower inspections will reduce the need for inspecti on personnel to perform this hazardous activity.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The UA carries no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.

The petitioner’s UAS has the capability to operate safely after experiencing certain in-flight contingencies or failures and uses an auto-pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of gl obal positioning system (GPS) or a lost-link event with a pre-coordinated, predictable, au tomated flight maneuver, and manual flight control functionality as a backup. These safety feat ures provide an equivalent level of safety compared to a manned aircraft performing a similar operation.

This exemption does not require an electronic means to monitor and communicate with other aircraft, such as transponders or sense and a void technology. Rather the FAA is mitigating the risk of these operations by placing limits on a ltitude, requiring stand-off distance from clouds, permitting daytime operations only, and requiring that the UA be operated within visual line of sight (VLOS) and yield right of way to all other manned operations. Additionally, the exemption provides that the operator will reque st a notice to airmen (NOTAM) prior to operations to alert other users of th e National Airspace System (NAS).

Regarding the petitioner’s requested relief from 14 CFR § 45.23(b), Display of marks , the petitioner requests this relief stating that the UA does not have a cabin, co ckpit or pilot station on which to mark certain words or phrases. Furt her, two-inch lettering is difficult to place on such small aircraft. The petitioner’s UAS will not be certificated under § 21.191, and therefore the “experimental” marking is not re quired. Since the petitioner’s UAS will not be certificated under § 21.191, a grant of exempti on for § 45.23(b) is not necessary. Markings must be as large as practicable per § 45.29(f).

Regarding the petitioner’s requested relief from 14 CFR §§ 91.405(a) Maintenance required

, 91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration

, 91.409(a)(2) Inspections , and 91.417(a) and (b) Maintenance records , the FAA has determined that relief from § 91.409(a)(1) is also necessary, because it is an alternate inspection requirement of § 91.409(a)(2). As provided in the operating documents, the operator will ensure that the UAS is in work ing order prior to init iating flight, perform required maintenance, and keep a l og of any maintenance performed.

Therefore, the FAA finds that adherence to the petitioner’s operating documents and the conditions and limitations below, describing th e requirements for maintenance, inspection, and recordkeeping, are sufficient to ensure that safety is not adversely affected. Accordingly, the FAA finds that exemption from 14 CFR §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) is warranted.4 UAS PIC

Regarding the petitioner’s requested re lief from 14 CFR § 61.113(a) and (b) Private pilot privileges and limitations , the FAA must consider the appropriate level of pilot certification for the petitioner’s proposed ope rations. The petiti oner proposed to operate its UAS with pilots having been vetted and trained through a self-administered flight training program, based upon completion of an FAA-approved ground school. The petitioner states that “while helpful, a pilot license will not ensure remo te control piloting skills.” Although Section 333 provides limited statutory fl exibility rela tive to 49 USC § 44704 for the purposes of airworthiness certific ation, it does not provide flexibility relative to ot her sections of title 49. The FAA does not possess the aut hority to exempt from the stat utory requirement to hold an airman certificate, as prescrib ed in 49 USC § 44711. For furt her information see Exemption No. 11110 (Trimble Navigation, Ltd).

The FAA is also requiring a pilot certificat e for UAS operations becau se pilots holding an FAA issued private or commercial pilot certificate are subject to security screening by the Department of Homeland Secu rity that certific ated airmen underg o. As previously determined by the Secretary, th e requirement to have an airman certificate ameliorates security concerns over civil UAS operations conducted in accordance with Section 333. Given these grounds, the FAA must determine the appropriate level of pi lot certification for the petitioner’s proposed operation.

Under current regulations, civi l operations for compensation or hire require a PIC holding a commercial pilot certificate pe r 14 CFR part 61. Based on the private pilot limitations in accordance with pertinent parts of 14 CFR § 61.113( a) and (b), a pilot holding a private pilot certificate cannot act as a PIC of an aircraft for compensation or hire unless the flight is only incidental to a business or employment. However, in Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a pr ivate pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. A dditionally, as previously determined by the Secretary of Transportation, the requirement to ha ve an airman certificate ameliorates security concerns over civil UAS operations conducted in accordance with Section 333.

The petitioner proposes to operate with a pilot who does not possess an FAA issued pilot certificate. This is similar to other petiti ons for exemption previously filed with and considered by the FAA. As in Exempti on Nos. 11062 (Astraeu s) and 11138 (Douglas Trudeau), the FAA has analyzed the petitioner’s proposed oper ation and determined it does not differ significantly from these grants of ex emption. The petitioner plans to operate in the NAS over controlled access property with the permission of the property owner/controller, while also limiting property access to consenting participants while ope rations are underway. Given: 1) the similar nature of the petitioner’s proposed opera ting environment to that of Astraeus and Trudeau, 2) the parallel nature of private pilot ae ronautical knowledge requirements to those of commercial require ments [ref: Exemption No. 11062], and 3) the airmanship skills necessary to operate the UAS, the FAA finds that the additional manned5 airmanship experience of a commercially cer tificated pilot would not correlate to the airmanship skills necessary for the petitioner’ s proposed operations. Therefore, the FAA finds that a PIC holding a private pilot certificate a nd a third-class airman medical certificate is appropriate for the proposed operations.

With regard to the airmanship skills necessary to operate the UAS, the petitioner has proposed a training program, as well as in-field operations in preparation for operating the UAS for the purpose of conducting the operations described in the operating documents. The petitioner states that the PIC must have accumulated a nd logged a minimum of twenty hours as the UAS pilot operating the make and model of the UAS to be utilized for the operations and three take-offs and three landings in the preceding 90 days. The conditions and limitations require that the PIC must maintain an understanding of all operational feat ures including normal, abnormal, and emergency procedures of the UAS, as well as material in the operating documents. These and other requirements ar e included in the conditions and limitations below.

Additionally, the conditions and limitations below stipulate that the petitioner may not permit any PIC to operate unless that PIC has demons trated through the peti tioner’s training and currency requirements that the PIC is able 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 dist ances from people, vessels, vehicles, and

structures.

In conclusion, the FAA finds that a PIC holdi ng a private pilot certificate and a third-class airman medical certifi cate, and who has completed the peti tioner’s pilot vetting and training programs, can conduct the proposed UAS operations without adversely aff ecting the safety of the NAS and persons or property on the ground. Upon consideration of the overall safety case presented by the petitioner, the FAA finds that granting the requested relief from 14 CFR § 61.113(a) and (b), is warranted.

The petitioner indicates it will supplement its proposed operation(s) with a camera operator, “such that, at a minimum, two LOCORC pers onnel govern the safe flight of an LOCORC aircraft at all times.” However, the petitioner did not indicate whether it will supplement its proposed operation(s) with a visual observ er (VO). The FAA notes that one of the determinations for operations under section 333 is operation within visual line of sight (VLOS). As the PIC is determined to be in command of the UA, he or she must maintain VLOS while operating the UA. The FAA also not es that a visual observer complements the PIC’s capability to see and avoid other aircraft (per § 91.113), including when the PIC may be momentarily attending to other flying tasks (e.g., maneuvering the aircraft close to structures, vehicles, or other objects). The VO provides an additional le vel of operational safety. The conditions and limitations below stipulate that the PIC must ensure that the VO can perform the functions prescribed in the operating documen ts. Additionally, as discussed in Exemption No. 11109 to Clayco, Inc. there are no regulator y requirements for visual observer medical certificates. Although a medical certificate is not required for a VO, the UA must never be operated beyond the actual visual capabilities of the VO, and the VO and PIC must have the6 ability to maintain VLOS with the UA at all times. It is the re sponsibility of the PIC to be limit operations of the UA to distances within the visual capabilities of both the PIC and VO. Therefore, as in Grant of Exemption No. 11062 to Astraeus, the FAA does not consider a medical certificate necessary for the VO.

The FAA considers the PIC to be designated for the duration of the fli ght. Therefore, per the conditions and limitations below, the PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight.

UAS Operating Parameters

Regarding the petitioner’s requested relief from 14 CFR § 91.7(a) Civil Aircraft Airworthiness , the petitioner’s request states that “no such certificate will be applicable in the form contemplated by the” FAA’s regulations. As such, the petitioner states the regulation is inapplicable. While the petitioner’s UAS will no t require an airworthiness certificate in accordance with 14 CFR part 21, Subpart H, th e FAA considers the petitioner’s compliance with its operating documents to be a sufficien t means for determining an airworthy condition. Therefore, relief from § 91.7(a) is granted. The petitioner is still require d to ensure that its aircraft is in an airworth y condition – based on compliance with the operating documents prior to every flight, and as stated in the conditions and limitations below.

Additionally, in accordance with 14 CFR § 91.7(b) , the PIC of the UAS is responsible for determining whether the aircraft is in a condition for safe fli ght and the FAA finds that the PIC can comply with this requirement.

Regarding the petitioner’s requested relief from 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking, and placard requirements and 14 CFR § 91.203(a) and (b) Civil aircraft: Certifications required , the FAA has previously determin ed, as in grant of Exemption No.11062 to Astraeus, that relief fr om these sections is not necessary. Relevant materials may be kept in a location acce ssible to the PIC in compliance with the regulations.

The petitioner requested relief from 14 CFR § 91.103(b), Preflight Action . The petitioner’s operating documents require the PIC to take certain actions before flight to ensure the safety of the flight. Although there will be no appr oved Airplane or Roto rcraft Flight Manual available, the FAA believes that the petiti oner can comply with the other applicable requirements in 14 CFR § 91.103(b)(2). The proce dures outlined in th e operating documents, address the FAA’s concerns regarding complia nce with § 91.103(b). The PIC will take all actions including reviewing w eather, flight battery require ments, landing, and takeoff distances/conditions, and aircraft performance data before initiation of flight. The FAA has imposed stricter requirements with regard to visi bility and distance from clouds; this is to both keep the UA from departing VLOS and to pr eclude the UA from c onflicting with other aircraft operating in the NAS. The FAA also notes the risks a ssociated with sun glare; the FAA believes that the PIC’s and VO’s ability to s till see other air traffic, combined with the PIC’s ability to initiate a return-to-home sequen ce, are sufficient mitigations in this respect.7 The PIC will also account for all relevant site-s pecific conditions in his or her preflight procedures. Therefore, the F AA finds that exempti on from 14 CFR § 91.103 is not necessary.

Additionally, the petiti oner requested relief from 14 CFR § 91.109 Flight instruction; Simulated instrument flight and certain flight tests . The petitioner did not describe training scenarios in which a dual set of controls woul d be utilized or required, i.e. dual flight instruction, provided by a flight instructor or other company- designated individual requiring that individual to have fully functioning dual controls. Rather, the pe titioner intends to accomplish training as referenced in the operating documents. Furthermore, the FAA is requiring that the petitioner’s PICs possess at le ast a private pilot’s ce rtificate. Also, this exemption will require that training operations only be conducted during dedicated training sessions. The FAA finds that safety will not be adversely impacted if the petitioner follows the self-administered training a nd internal procedures outlined in the operating documents, in conjunction with the PIC meeting 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. As such, the FAA finds that the petitioner can conduct its operations without the requested relief from § 91.109.

Regarding the petitioner’s request ed relief from 14 CFR § 91.119, Minimum safe altitudes

, the petitioner did not specify the paragraph(s) of 14 CFR § 91.119 from which they require relief. Relief from § 91.119(a), wh ich requires operating at an al titude that allows a safe emergency landing if a power unit fails, is not granted. The FAA expects the petitioner to be able to perform an emergency landing without undue hazard to persons or property on the surface if a power unit fails. Relief from 14 CFR § 91.119(b), operation over congested areas, is not granted because the peti tioner did not provide sufficient information necessary for the FAA to determine whether the operation poses an adverse impact to safety.

The petitioner proposes operations in tightly controlled and limited airspace with predetermined, specifically marked areas of ope ration in sectioned off locations. Additionally, the petitioner will always “obtain all necessary permissions and permits” prior to each UAS operation. The petitioner also st ipulates all operations be conducted within visual line of sight. With regard to persons not directly invol ved in the flight operati on, the petitioner did not provide an explanation for exposing those persons to increas ed risk. Therefore, the FAA is requiring that prior to conduc ting UAS specific operations, all pe rsons not essential to flight operations (nonparticipating persons) must remain at appropriate distances. In open areas this requires the UA to remain 500 feet from all person s other than essential flight personnel (i.e. the PIC and VO).

The FAA has also considered that the UA in this case will weigh 55 pounds or less. If barriers or structures are pres ent that can sufficiently protec t nonparticipating persons from debris in the event of an accident, then the UA may operate closer than 500 feet to persons afforded such protection. The operator must ensure that nonparticipating persons remain under such protection. If a s ituation arises where nonpartic ipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately. When considering how to immediately cease operations, the primary concern is the safety of those nonparticipating persons. In addition, the FAA fi nds that operations may be conducted closer8 than 500 feet to vessels, vehicl es and structures when the prop erty owner/controller grants such permission and the PIC makes a safety assess ment of the risk of operating closer to those objects.

Thus, the FAA finds that relief from § 91.119(c) is necessary because all operations will be conducted below 400 feet above ground level ( AGL) and may be operated closer than 500 feet from persons, vessels, vehicles, and struct ures as described above. Provided adherence to the procedures in the operating documents and the additional conditions and limitations outlined below, the FAA finds that relief from § 91.119(c) is warranted. Because of the conditions and limitations below, relief from § 91.119(d) is not applicable.

Regarding the petitioner’s request ed relief from 14 CFR § 91.121 Altimeter Settings , the UAS uses a global positioning system (GPS) altitude indicat or rather than a barometric altimeter. As stated in the conditions and limitations be low, the FAA requires any altitude reported to ATC to be in feet AGL. The petitioner may c hoose to set the GPS altit ude indicator to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations, re lief from 14 CFR § 91.121 is granted to the extent necessary to comply with the applic able conditions and limitations stated below.

Regarding the petitioner’s requested relief from 14 CFR § 91.151(a) Fuel requirements for flight in VFR conditions , relief has been granted for manned ai rcraft to operate at less than the minimums prescribed in 14 CFR § 91.151( a), including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The pe titioner states that its UAS operations will be conducted “in secure areas that are strictly controlled,” with UA under 55 pounds, and within VLOS. These factors, combined with th e petitioner’s stated in tention to terminate flights with 25% remaining battery power, pr ovides the FAA with sufficient reason to grant the requested relief from 14 CF R 91.151(a). In accordance with th e conditions and limitations below, the PIC is prohibited from beginning a flight unless (conside ring wind and forecast weather conditions) there is e nough power to fly at normal crui sing speed to the intended landing point and land the UA with 25% battery power remaining.

These features, combined with the lack of pa ssengers and crew, will ensure safety in NAS operations and not present a hazard to persons or property on the ground.

Additionally, in evaluating the petitioner’s pr oposed operating paramete rs with regard to VLOS and a safe operating perimeter, the FAA considered operations from a moving device or vehicle. Since the petitioner did not disc uss provisions for these circumstances, the conditions and limitations below preclude ope rations from moving de vices or vehicles.

As stated in the petition, the scope of the petitioner’s propose d operation is “to provide high definition aerial photography with small, unmanned aircraft and lightwei ght UAS’s.” Further, the petitioner describes a broader scope of opera tions including “the in spection of towers and structures that would otherwis e require climbing at great risk to the perso nnel involved, though given the stability and maneuverabilit y, they may be used by law enforcement9 personnel, search and rescue and by other fi rst responders for other photography including video.” The petitioner’s operating documents a nd petition provided limited information to support inspection and imagery of towers a nd structures. No suppor ting information or descriptions were found to suppor t search and rescue operations in support of first responders. Therefore the FAAs analysis was limited to use of UAS for the inspection and imagery of towers and structures. The conditions and limita tions below restrict the UAS operation to this purpose only.

Regarding an Air Traffic Organization (ATO) issu ed Certificate of Waiver or Authorization (COA), the majority of current UAS operations occurring in the NAS are being coordinated through Air Traffic Control (ATC) by the issuance of a COA. This is an existing process that not only makes local ATC facilities aware of UAS operations, but also provides ATC the ability to consider airspace issues that are unique to UAS operations. The COA will require the operator to request a NOTAM, which is th e mechanism for alerting other users of the NAS to the UAS activities being conducted. The conditions and limitations below prescribe the requirement for the petitioner to obtain an ATO-issued COA.

Public Interest

The FAA finds that a grant of exemption is in the public interest. Th e enhanced safety and reduced environmental impact achieved using a UA with the specifications described by the petitioner and carrying no passenge rs or crew, rather than a ma nned 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.

The following table summarizes the FAA’s dete rminations regarding the relief sought by the petitioner:10 Relief considered (14 CFR) FAA determination (14 CFR) 21 Subpart H Relief not necessary 45.23(b) Relief not necessary

61.113(a) and (b) Relief granted with conditions and limitations

91.7(a) Relief granted with conditions and limitations 91.9(b)(2) Relief not necessary 91.103(b) Relief not necessary 91.109 Relief not necessary

91.119 Relief not granted for paragraphs (a) and (b); paragraph (c) granted with conditions and limitations; paragraph (d) not applicable

91.121 Relief granted with conditions and limitations

91.151(a) Relief granted from 91.151(a)(1), day, with conditions and limitations 91.203(a)(b) Relief not necessary

91.405(a) Relief granted with conditions and limitations

91.407(a)(1) Relief granted with conditions and limitations

91.409(a)(1)(2) Relief granted with conditions and limitations

91.417(a) and (b) Relief granted with conditions and limitations

The FAA’s Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, LowCount ryRC, Corporation is granted an exemption from §§ 61.113(a) and (b), 91.7(a), 91.119(c) , 91.121, 91.151(a)(1), 91.4 05(a), 91.407(a)(1), 91.409(a)(1)(2), and 91.417(a) and (b) to the exte nt necessary to allow the petitioner to operate a UAS to conduct high definition aerial photography for the inspection of towers and structures. This exemption is subject to th e conditions and limita tions listed below.

Conditions and Limitations

Relative to this grant of exemption, LowCountryRC, Corporation is hereafter referred to as the operator.11 The petition and the following supporting documen tation are hereinafter referred to as the operating documents:

1. A2 Flight Control System User Manual V1.20 2. A2 Product Release Notes 3. Low Country RC Flight Manual 12-14-2014 4. Low Country RC Maintenance Manual 12-14-2014 5. Low Country RC Futaba Specification sheet
6. DJI S1000 User Manual
7. DJI S1000 Product Release Notes 8. WooKong-M Quick Start Guide 9. WooKong-M Product Release Notes 10. Zenmuse Z15 User Manual 11. Zenmuse Z15 Product Release Notes

Failure to comply with any of the conditions an d 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 ex emption are limited to the following aircraft described in the operator’s petition which is an octocopter weighing less than 55 pounds including cameras: DJI Industries S1000 Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2) UAS operations under this exemption are limited to conducting operations for the purpose of high definition aerial photogra phy for the inspection of towers and

structures.

3) The UA may not be flown at an indicated airspeed exceeding 50 knots.

4) The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). All altitudes reported to ATC must be 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.

6) All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PI C and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS12 capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight a nd cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents.

7) The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

8) The operating documents and this grant of exemption must be accessible during UAS operations and made availabl e to the Administrator upon re quest. If a discrepancy exists between the conditions and limitati ons in this exemption and the procedures outlined in the operating documents, the c onditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revise d 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 contacte d if questions arise regarding updates or revisions to the operating documents.

9) Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection rev eals a condition that affects th e 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. The Ground

Control Station must be included in the preflight inspection. All maintenance and alterations must be properly docum ented in the aircraft records.

10) Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight in accordance w ith the operator’s manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operating documents.

11) The preflight inspection section in the operating documents must be amended to include the following requirement: The preflight inspection must account for all13 discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sec tions of the operating documents.

12) The operator must follow the manufacturer ’s UAS aircraft/component, maintenance, overhaul, replacement, inspecti on, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s manuals.

13) The operator must carry out their mainte nance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection,

and alterations must be noted in the airc raft logbook, including total flight hours, description of work accomplished, and the sign ature of the authorized person returning

the UAS to service.

14) The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

15) Each UAS operated under this exemption mu st comply with all manufacturer System and Safety Bulletins.

16) The PIC must possess at least a private pilo t certificate and a valid third-class airman

medical certificate. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

17) The operator may not permit any PIC to ope rate unless the PIC meets the operator’s qualification criteria, completes the operator’s training program, maintains currency according to the operating documents, and 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 qua lification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). The VO is also required to complete the operator’s training requirements. A record of training must be documented and made available upon request by the Admini strator. Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building), are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.14 18) UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

19) The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautic al chart unless a letter of agreement with that airport's management is obt ained, 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 available to the Administrator upon request.

20) 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.

21) If the UAS loses communications or loses it s GPS signal, the UA must return to a predetermined location within the private or controlled-access property (safe zone) and

land or be recovered in accordan ce with the operator’s manual.

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual.

23) The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions and assuming normal cruising speed) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining.

24) The operator must obtain an Air Traffic Or ganization (ATO) issued Certificate of Waiver or Authorization (COA) prior to c onducting 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 not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

25) All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CF R part 45, Subpart C. Markings must be as large as practicable.15 26) Before conducting operations, the radio fr equency spectrum used for operation and control of the UA must comply with th e Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

27) The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the

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

documents must be made available to th e Administrator or any law enforcement official upon request.

28) The UA must remain clear and yield the ri ght of way to all other manned aviation operations and activit ies at all times.

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

30) The UA may not be operated over conge sted or densely populated areas.

31) Flight operations must be conducted at leas t 500 feet from all nonpa rticipating persons (persons other than the PIC or VO), ve ssels, vehicles, and structures unless:

a. Barriers or structures ar e present that sufficiently protect nonparticipating persons from 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 a nd are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or stru ctures where the property owner/controller has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and;

c. Operations near the PIC or VO do not pr esent an undue hazard to the PIC or VO, per § 91.119(a).

32) All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

33) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.16 Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

This exemption terminates on February 28, 2017, unless sooner supers eded or rescinded.

Issued in Washington, DC, on February 23, 2015.

/s/ John Barbagallo Acting Deputy Director, F light Standards Service17 Project No.: AFS–15-047-E Project Officer: _______________
Doc No. ARM–1/100/: Program Office AFS–80

Mr. Anthony J. Marino, President Low Country RC, Corporation 3104 River Drive Thunderbolt, GA 31404