1 

## M odovolate Aviation, LLC

1131 Carol Lane Glencoe, IL 60022 hperritt@gmail.com (312) 504

- 5001

2 2 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 H uerta :
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 exemp tion from the listed Federal Aviation Regulations (“FARs”) to allow it to opera te small Unmanned Aircraft Sy stem s (“sUAS”) for aerial data collection
, under
the conditions and limitations set forth in this Petition.

T he requested exemption would permit th e 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 helicopter s 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 33 3(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.

Th e 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 th e rulemaking required unde r 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).

I f the Adminst rator 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 d elegated his aviation authority to the Administrator of the FAA.

The Federal Aviation Act expressly grants the FAA th e 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 th e 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 Elio t 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

as tronautics 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 t echnological 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 f light 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 unregula ted 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 f light 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 productiv ity 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

.

N ow, 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
obtain s 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 section s 332 and 333 of the FA A Revitalization and Reform Act of 2012 that5

the FA A move quickly to accommodate the economic and societal benefits that can
result from widespread deployment of sUAS technology. A ccordingly, Petitioner applies for authorization under the Federal Aviation Act , and the FAR s rules to undertake the following activities for commercial purposes. Unless the Petition is grant ed, 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 vehicle s 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. T he vehicle s also have the built

- in capability to return to the launching point if the wireless control link is interrupted or if t he 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 speed s of about 30 kn ots

. All of them are multicopters with fixed

- pitch rotors , thrust from which is vari ed by changing RPM

. All of them are powered by lithium polymer batter ies

.



### Flight profiles
The Petitioner will program its aircraft so that they will not fly abo ve 400 feet above ground level, or more than 1500 feet away from the operator

. The operator wil l carefully preflight the vehicle before each mission to assure that its c ompass 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 collec tion, 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 t han 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 s ight (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 d uties 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
doc uments. 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 opera ting 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 revisi ons 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 condu cted 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 n ot to pose an undue hazard to persons and property.

8. The operator is will maintain and inspect the UAS to ensur e 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. inopera ble 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 f light.
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 s afety 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 n ot 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 fr om persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner8 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 ded icated training sessions. During training, proficiency, and experience

building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accor dance 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. T he 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

- publis hed 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 pre determined location within the private or controlled

access 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 i f 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 conduct9 operations that cannot be conducted under the terms of the COA attached to the

requested ex emption

. 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 a s 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 th e 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

pe rsons 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 th e requested exemption.
28. Any inciden t, 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 aeri al 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 o f 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 c reation, 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 Fir st 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 (Fe b. 1, 2012).11 entertainment, such as musical and dramatic works fall within the First

Amendment g uarantee. " 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 Pe titioner 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 an d the copyright statute’s protection of visual art and audiovisual works embod y 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 prod uction 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 politi cal 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 pu blic 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 i n 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 i t 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 Pe tition 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 te chnology." 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, follow ed by their commercialization and their introduction of the marketplace. The drone technology that the Petitioner uses exemplifies the latest innovative leap forward in aeronautical technolog y . Preventing i t from using this in air commerce
subverts achie vement 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 advant ages 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 i tself 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 def iance 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) a nd 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, rather14

than a m anned 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 Exempt ion 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 n ot 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 instrument s No one aboard to read16 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