1

Modovolate Aviation, LLC

1131 Carol Lane

Glencoe, IL 60022

hperritt@gmail.com

(312) 504-5001

22 April 2015

Hon. Michael Huerta

Administrator

Federal Aviation Administration

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Summary Exemption Request under Section 333 of the FAA Reform Act and Part 11 

of the Federal Aviation Regulations from certain parts of the FARs.

Dear Administrator Huerta:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, Modovolate Aviation, LLC, an Illinois limited liability 

company (“Movo Aviation,” the “LLC, or the “Petitioner”), hereby applies for a

summary exemption from the listed Federal Aviation Regulations (“FARs”) to allow it

to operate small Unmanned Aircraft Systems (“sUAS”) for aerial data collection, under 

the conditions and limitations set forth in this Petition.

The requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited,

(2) predetermined, and (3) would provide safety enhancements to the already safe news 

gathering operations presently using manned helicopters and airplanes. Approval of 

this exemption would thereby enhance safety and fulfill the FAA Administrator’s 

responsibilities to “...establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” Section 333(c) of the Reform Act.

The name and address of the applicant is:
2

Modovolate Aviation, LLC

Attn: Henry H. Perritt, Jr.

Telephone: (312) 504-5001

Email: hperritt@gmail.com

Address: 1131 Carol Lane, Glencoe, IL 60022

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. § 45.23(b)

14 CFR § 61.3

14 C.F.R. § 91.7 (a)

14 CFR § 91.9 (b) (2)

14 C.F.R. § 91.103

14 C.F.R. § 91.109

14 C.F. R. § 91.119

14 C.F.R. § 91.121

14 CFR § 91.151 (a)

14 CFR § 91.203 (a) & (b)

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a)

14 CFR § 407 (a) (1)

14 CFR § 409 (a) (2)

14 CFR § 417 (a) & (b)
3

The Appendix describes the FARs from which an exemption is requested and 

summarizes the justification for each requested exemption. 

The Petition is submitted to fulfill Congress’ goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) 

before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Administrator must determine which types of UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national security 

in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). 

If the Adminstrator determines that such vehicles “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. § 333(c) (emphasis added).

The Secretary has delegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions 

from its regulatory requirements for civil aircraft, a term defined under §40101 of the 

Act, which includes sUASs. The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) or (b) of this section or any 

sections 44702-44716 of the Federal Aviation Act if Administrator finds the exemption 

in the public interest. 49 U.S.C. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 

CFR §91.203 (a) (1).

Modovolate Aviation, LLC, is an Illinois limited liability company organized for the 

purpose of conducting microdrone research, experimentation, demonstration, 

education and aerial photography.

Movo Aviation was formed and is jointly owned by Henry H. Perritt, Jr. and Eliot O. 

Sprague. 
4

Henry H. Perritt, Jr., the Chief Executive Officer of the LLC and its General Counsel, is a 

law professor and former dean at Chicago-Kent College of Law, the law school of 

Illinois Institute of Technology. Holding a bachelor of science degree in aeronautics and 

astronautics from MIT, a master of science degree in management from MIT’s Sloan 

School, and a juris doctor degree from Georgetown University Law Center, Mr. Perritt 

has written dozens of law review articles and several books on how the law should 

adapt to technological innovation. He is a private helicopter and airplane pilot, with an 

instrument airplane rating. 

Eliot O. Sprague is Chief Operating Officer of the LLC. A graduate of Hillsboro Aero 

Academy, he is a full-time news helicopter pilot, helicopter flight instructor, director for 

a Chicago-area on-demand commercial helicopter operator, and a member of the board 

of directors of Midwest Helicopter Association. He is intimately familiar with 

commercial aviation and familiar with the threats that unregulated microdrone flight 

present to the safety of himself, his coworkers, his passengers, and to persons and 

property on the ground. He holds commercial helicopter and airplane, instrument 

helicopter, commercial flight instructor-rotary wing, and commercial flight instructor –

instrument-rotary wing ratings.

Messrs Perritt and Sprague have authored a number of articles published in aviation 

and journalism magazines and in law reviews explaining how sUAS can enhance the 

public interest, boost economic productivity and be operated so as to assure the safety 

of the national airspace system.

The Petitioner and its officers have flown a variety of sUAS for recreational and 

hobbyist purposes, including the Parrot AR, the DJI Phantom, and the Cinestar 8 HL. 

They have assembled a Cinestar 8 HL, and a Birdseye View FireFLY6 tiltrotor.

Now, a number of people, some professional colleagues and some strangers, have heard 

about Petitioner’s activities and are pressing Petitioner to undertake aerial data 

collection for compensation.

The Petitioner has been advised by counsel that this is not now permissible unless he 

obtains special permission from the FAA. Many competitors of Petitioner are actively 

flying sUAS to conduct aerial photography for commercial purposes, notwithstanding 

the FAA’s stated prohibition. Petitioner also notes and has read the congressional 

mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that 
5

the FAA move quickly to accommodate the economic and societal benefits that can 

result from widespread deployment of sUAS technology. Accordingly, Petitioner 

applies for authorization under the Federal Aviation Act, and the FARs rules to 

undertake the following activities for commercial purposes. Unless the Petition is 

granted, Petitioner will be at a significant competitive advantage if it, as it prefers, 

complies with FAA policy.

Vehicle

The Petitioner will fly the following sUAS:

 DJI Phantom 3

 DJI Inspire

 Cinestar 8 HL

 3DRobotics IRIS+

 FreeFly ALTA

All these vehicles have built in capability to limit the height they fly above the ground, 

to limit the radius of the distance the fly from the operator, and to exclude them from 

class B, C, and D airspace. The vehicles also have the built-in capability to return to the 

launching point if the wireless control link is interrupted or if the operator attempts to 

exceed any of the height, radius, or airspace limitations programmed into it.

The largest vehicle—the Cinestar 8 HL-- weighs about five pounds empty and has a 

maximum gross weight of approximately twenty pounds. The others weigh less and 

have correspondingly smaller payloads. All of them have top speeds of about 30 knots. 

All of them are multicopters with fixed-pitch rotors, thrust from which is varied by 

changing RPM. All of them are powered by lithium polymer batteries.

Flight profiles

The Petitioner will program its aircraft so that they will not fly above 400 feet above 

ground level, or more than 1500 feet away from the operator. The operator will 

carefully preflight the vehicle before each mission to assure that its compass and GPS 

system are properly calibrated and that the return-to-home feature, altitude, and radius 

limitations work.
6

The operator will operate its vehicles on aerial data collection, aerial photography, news 

gathering, training, and demonstration missions only under the following 

circumstances:

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

In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer.

2. The UA will be operated at an altitude of no more than 400 feet above ground 

level (AGL). Altitude will be reported in feet AGL.

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

The PIC will 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.

4. All operations will utilize a visual observer (VO). The UA will 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 will be able to communicate orally 

at all times; electronic messaging or texting will not occur during flight 

operations. The PIC will be designated before the flight and will not transfer his 

or her designation for the duration of the flight. The PIC will ensure that the VO 

can perform the duties required of the VO.

5. The requested exemption and all documents needed to operate the UAS and 

conduct its operations in accordance with the conditions and limitations of the 

requested grant of exemption, are hereinafter referred to as the operating 

documents. The operating documents will be accessible during UAS operations 

and will be 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 

will take precedence and be followed. Otherwise, the operator will follow the 

procedures as outlined in its operating documents. The operator may update or 

revise its operating documents, and track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official 

upon request. 
7

6. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the requested exemption, the operator will petition 

for an amendment to its grant of exemption. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS 

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

will undergo a functional test flight prior to conducting further operations under 

the requested exemption. Functional test flights will only be conducted by a PIC 

with a VO and will remain at least 500 feet from other people. The functional test 

flight will be conducted in such a manner so as not to pose an undue hazard to 

persons and property.

8. The operator is will maintain and inspect the UAS to ensure that it is in a 

condition for safe operation.

9. 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 will account for 

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

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

aircraft will not be operated until the necessary maintenance has been performed 

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

10. The operator will follow the UAS manufacturer’s maintenance, overhaul, 

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

components.

11. Each UAS operated under the requested exemption will comply with all 

manufacturer safety bulletins.

12. All PICs will hold either an airline transport, commercial, private, recreational, or 

sport pilot certificate. The PIC will 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 will 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.

13. The operator will 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 will be logged in a manner 
8

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 safely to operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption will occur under the 

terms of the requested exemption. Training operations will only be conducted 

during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119.

14. 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). 

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

15. The UA will 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 

will be made available to the Administrator or any law enforcement official upon 

request.

16. The UA 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.

17. If the UAS loses communications or loses its GPS signal, the operator will cause 

the UA to return to a predetermined location within the private or controlledaccess property.

18. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

19. The PIC will not begin a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

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

exemption holder will apply for a new or amended COA if it intends to conduct 
9

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

requested exemption.

21. All aircraft operated in accordance with this exemption will 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 will be as large as practicable.

22. 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 will be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating.

23. These documents will be made available to the Administrator or any law 

enforcement official upon request.

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

activities at all times.

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

26. All Flight operations will 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 will ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations will cease 

immediately in a manner ensuring the safety of nonparticipating persons’ 

and

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard.

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

nonparticipating persons under the requested exemption.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 
10

Accidents will be reported to the National Transportation Safety Board (NTSB) 

according to instructions contained on the NTSB Web site: www.ntsb.gov. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the 

Reform Act relating to size, weight, speed, operating capabilities, proximity to airports 

and populated areas and operation within visual line of sight and national security. The 

Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial 

photography with its sUAS.

Granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of 

sUAS into the National Airspace System advances the public interest. The 

Committee Report leading the House to adopted H.R. 658 said: 

"The successful integration of unmanned aircraft systems (UAS) into the 

National Airspace System (NAS) can support more than 23,000 high-paying jobs 

in the United States. . . . The absence of a plan to integrate UASs into the NAS is a 

barrier to such job creation . . . ."1

Granting the Petition represents a step toward such integration, in the absence of 

a comprehensive regulatory regime for sUAS, and thus would serve the 

Congressional goal and the public interest.

2. Granting the Petition would facilitate the creation, display, and public 

distribution of art, long recognized as advancing the public interest. They are at 

the core of the activities that the First Amendment to the United States 

Constitution seeks to promote and to protect from governmental restrictions.

Creative photography and video art fall well within the First Amendment’s 

protections. "Entertainment, as well as political and ideological speech, is 

protected; motion pictures, programs broadcast by radio and television, and live 

 

1

 H. R. Rep. 112-29 on H.R. 658, 112th Cong., 1st Sess. at 116. The House-Senate 

Conference Committee on the FAA Modernization and Reform Act of 2012 

recommended amendments to H.R. 658 in lieu of amendments adopted by the Senate. 

Conference Report to Accompany H.R. 658, H.R. Rep. 112-381, 112th Cong., 2d Sess., at 

p. 1 (Feb. 1, 2012).
11

entertainment, such as musical and dramatic works fall within the First 

Amendment guarantee. "2

3. Granting the Petition would enable new forms of news coverage, enabling the 

public to know about and to understand newsworthy events, an activity

similarly within the core of First Amendment protections. 3

4. Granting the petition would enable Petitioner to demonstrate the commercial 

viability of creating art and gathering news with new aeronautical technology 

Commercial creative art is protected as well as non-commercial art.4 The Patents 

and Copyrights Clause of the United States Constitution and the copyright 

statute’s protection of visual art and audiovisual works embody the proposition 

that more creative effort with respect to these kinds of work will be exerted when 

the creators are allowed to be paid for their works, thus increasing the 

production of artistic works. 

 

2

 Schad v. Borough of Mount Ephraim, 452 U.S. 61, 65 (1981); White v. City of Sparks, 

500 F.3d 953, 956 (9th Cir. 2007) (holding that self-expression through painting is 

protected by the First Amendment; rejecting city's argument that protection requires a 

political message); Hoffman v. Capital Cities/ABC, Inc., 255 F.3d 1180 (9th Cir. 2001) 

(reversing judgment for plaintiff; use of photograph of actor as part of fashion article 

was protected by First Amendment despite commercial purpose); Edme v. Internet 

Brands, Inc., 968 F. Supp.2d 519, 529-530 (E.D. N.Y. 2013) (denying summary judgment 

on statutory right of publicity claim; "newsworthy" broadly construed to allow public to 

benefit from visual images); Hill v. Public Advocate of the United States, ___ F. Supp.2d

___ , Civil Action No. 12–cv–02550–WYD–KMT, 2014 WL 1293524 (D. Colo. Mar. 31, 

2014) (holding that photograph of gay marriage was within First Amendment 

protection despite its use for political purposes; discussing how access to photograph 

advances the public interest).

3

 Glik v. Cunniffe, 655 F.3d 78, 83-84 (1st Cir. 2011) (citing cases holding that news 

photography is will with First Amendment protection and that protection extends to 

ordinary citizens as well as reporters; affirming denial of immunity to police officers in 

section 1983 suit by citizen who was arrested for using cellphone camera to photograph 

arrest).

4

 White, 500 F.3d at 956-957.
12

Granting the petition will allow the petitioner to respond to economic incentives 

to increase its creative production. The result will be an increase in the stock of 

artistic photography, including video for public enjoyment. 

A significant part of the Petitioner’s activities involve capturing and 

disseminating visual representations of newsworthy events. Receiving 

compensation for these newsgathering activities using traditional technologies 

incentivizes Petitioner, resulting in greater output of news. The new technologies 

embodied in sUAS enable different perspectives on the news not easily 

obtainable by traditional means. Allowing Petitioner to be compensated for 

using the new technologies will provide an incentive for it to intensify its

collection and dissemination efforts.

The rules from which Petitioner seeks exemption artificially and irrationally limit 

the effective use of new technologies to enhance news gathering, thereby 

subverting the public interest.

5. Granting the Petition will fulfill the FAA’s own declaration that encouraging 

new aviation technologies advances the public interest. The FAA itself has 

recognized the public interest in its role of "Encouraging and developing civil 

aeronautics, including new aviation technology."5 Granting the Petition will 

enhance FAA fulfillment of that commitment, thereby serving the public interest. 

Air commerce flourishes in the United States because of the rapid pace of 

innovation in aeronautical and associated technologies, followed by their 

commercialization and their introduction of the marketplace. The drone 

technology that the Petitioner uses exemplifies the latest innovative leap forward 

in aeronautical technology. Preventing it from using this in air commerce 

subverts achievement of the goal.

6. Granting the Petition will fulfill the Congressional determination that integrating 

sUAS technology into the NAS serves the public interest. Section 330 of the FAA 

Modernization and Reform Act of 2012, specifically recognizes the advantages to 

air commerce obtainable from the deployment of sUAS technologies. It 

mandated several steps by the FAA to accelerate the availability of these 

 

5

 FAA, Safety: The Foundation of Everything We Do, 

http://www.faa.gov/about/safety_efficiency/.
13

technologies in the National Airspace System, thereby representing a 

congressional determination that the public interest is served by making these 

technologies more widely available at the earliest practicable date. The Petition 

represents a way for the FAA to move incrementally, while still satisfying its 

congressional mandate and meeting its obligation to enhance the public interest 

by making new technologies available by allowing the use of sUAS technologies 

in a manner that protects the public and the rest of the aviation community from 

significant risk.

The commercial activities by Petitioner proposed in the Petition represent 

contributions to new forms of air commerce, thereby fulfilling the FAA’s 

statutory mandate under the 2012 Act.

7. Granting the Petition will enhance aviation safety, thereby advancing the public 

interest. The Petitioner has committed itself in the Petition to safety practices that 

reduce or eliminate hazards to aircraft in the National Airspace System and to 

persons and property on the ground. Many others are flying sUAS without 

regard to these hazards. Granting the Petition will offer the Petitioner up as an 

example of how the FAA is willing to accommodate the new technology when it 

is constrained by appropriate limitations to enhance safety. It will also allow the 

Petitioner to be a role model for safe commercial sUAS operations.

Users of the National Airspace System are confronted by mushrooming threats 

from sUAS flown in defiance of the FAA’s ban. Unless the FAA shows some 

flexibility to accommodate lawful and safe operation of sUAS for legitimate 

commercial purposes, the level of defiance will increase, intensifying the hazards 

to manned aircraft and to persons and property on the ground.

The Petition to use a UAS for aerial data collection and its proposed limitations are

similar in all material respects to those approved by the FAA 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), 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642) and 

11310 to Colin Hinkle (see Docket No. FAA-2014-0608). In those grants 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 
14

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.

The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, 11213, 

and 11310 also apply to the situation presented by this Petition.

Respectfully submitted,

Modovolate Aviation, LLC,

By its General Counsel:

Henry H. Perritt, Jr.
15

Appendix

FAR section Subject Justification

14 CFR § 45.23(b) Requirement to display 

registration number on 

vehicle

Insufficient space on 

vehicle

14 CFR Part 21 Aircraft certification 

requirements and 

procedures

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS; 

petition describes 

training for sUAS 

operator

14 CFR § 91.7 (a) Airworthiness 

requirement

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual 

to be available in the 

cockpit

No one aboard to read 

manual

14 CFR § 91.103(b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one aboard to 

operate controls

14 CFR § 91.119 Minimum altitudes for 

safe flight

Safety requires 

operation below these 

altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151(a) Fuel requirements Vehicle does not use 

fuel

14 CFR § 91.203 (a) & (b) Requirement for 

registration and 

airworthiness 

certificates to be 

onboard

No one aboard to read 

certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read 
16

requirement instruments

14 CFR § 91.215 Transponder 

requirement

Vehicle has insufficient 

useful load; will be 

operated below ATC 

radar coverage

14 CFR § 91.405 (a) Inspection requirements Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.407(a) (1) Inspection approval 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.409 (a) (2) Airworthiness 

inspection

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS

14 CFR § 91.417 (a) & (b) Maintenance records 

requirements

Designed for manned 

aircraft; not suitable for 

off-the-shelf sUAS