# RF Guys
1802 Jan a Ln Morris Illinois 60450 Page 1 of 13 March 13, 2016
Docket Management Facility U.S. Department ofTransportation 1200 NewJerseyAve

.,SE Washington, DC 20590 

### RE: Exemption Request Section 333 of the FAA Reform 

### Act and Part 11 of the Federal Aviation Regulations DearSiror Madam : Pursuantto Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R

. Part 11, RF Guys an operatorofSmall Unmanned Aircraft Systems ("sUAS") equipped to offeron-demand commercial sUAS operations for a number ofvaried industries and applications. These include: • Aerial search and rescue operational support • Infrastructure inspection • Agricultural monitoring and support • Industrial refinery and manufacturer plant inspection • Promotional Activities • Accident/Incident survey and investigative support • Utility-powertransmission system inspections and patrolling • Private security monitoring • Filmmaking, cinematography, andvideography • Pipeline inspection and patrolling • Aerial surveying and mapping • Wildlife and forestry monitoring • Construction site inspection and monitoring • Public Entity Support Operations • Maritime aerial operations • sUAS Consulting • Real Estate videography and imagery Cell tower inspection TABLE 1 Operations underthe exemption will be subjectto strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333. Approval ofthis exemption would therebyenhance safety and fulfill the Secretary ofTransportation 's (the FAA Administrator's) responsibilities underSection 333(c) ofthe Reform Act to "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." The name and address ofthe applicant are:

# RF Guys
1802Jan a Ln Morris Illinois 60450 Page 2 of 13 RF Guys Attn: Brandon Kindelspire 1802 Jana Ln Morris Illinois 60450 Phone: 435.210.8249 Email: bkspire@gmail.com The regulations from which the exemption is requested are as follows: 14 C.F.R. § 61.113(a) 

### & (b); 14 C.F.R. § 61.133(a) ; 14 C.F.R

. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.405(a); 14 C.F.R. 

### § 91.407{a)(1); 14 C.F

. R. § 91

.409{a)(2}; 14 C.F.R. § 91.417{a} 

### & (b) Appendix A describes each rule listed above and explains the factors exemptions pursuantto the proposal setforth in this letterare appropriate, provide an equ ivalent level ofsafety, and are in the public interest

. 

### THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 RF Guys submits that grant of this exemption application for use of sUAS to accomplish services described in Table 1 that will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction of UASs intothe national airspace system ("NAS") if itcan be accomplished safely. This law directsthe Secretary ofTransportationto considerwhether certain UASs may operate safely in the NAS before completion ofthe rule making required underSection 332 ofthe Reform Act. In makingthis determination, the Secretary is requ ired to determine which types of UASs do not create a hazard to users of the NAS or the publicor pose a threatto national security in l ight ofthe following:
• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in close proximityto airports and populated areas; and • Operation ofthe UAS within visual line of sight ofthe operator. Reform Act§ 333(a)(1). lfthe Secretary determinesthatsuch vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." Id.§333( c} (emphasis added). The Federal Aviation Act expressly grantsthe FAA the authorityto issue exemptions

.This statutory authority, by itsterms, i ncludes exemptingcivil aircraft, as the term is defined under §40101 of the Act, from the requirementthat all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pi lots to operate aircraft in commercial service:

# RF Guys 1802 Jana Ln Morris lllinois60450 The Administrator may grantan exemption from a requ i rement of a regulation pre scribed under subsection (a) or (b) ofthis section or any ofsections 4470244716 ofthis title ifthe Administratorfi nds the exemption is in the public interest. 49 U.S.C. §44701(f). See also49 U.S.C. § 44711(a); 49 U

.S

.C. § 44704; 14 C.F

. R. § 91.203(a)(1). The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333 of the Reform Act; the add itional authority in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations ; and the significant public benefit, including enhanced safety and cost savings associated with transitioningto UASs fo r aerial su rveying and photography

.Acco rdingly, the applicant respectfully requests thatthe FAA grantthe requested exemption without delay. 

### AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY RF Guys will operate the following aircraft: 1. DJI Phantom 3 Professional The applicant proposes thatthe exemption requested herein apply to civil aircraftthat have the characteristics and that operate with t he limitations listed he rein

.These limitati ons providefor at least an equivalent oreven higher level of safetyto operations underthe current regulatory structure because the proposed operations represent asafetyenhancement to operat ions thatwould be conducted w ith conventional aircraft. These conditions are drawn from Exemptions 11062 through 11067, 11080, 11109, and 11110

. These limitations and conditions to which Tailwind (or "operator" ) agrees to be bound when conducting commercial operations underan FAA issued exemption include : 1

. Ope rations ofthe sUAS will weighs less than fifty-five (55) pounds (the "UA'' or "UAS"). Proposed operations of any otheraircraft will require a new petition ora petition to amend this gran t .G 2

. The UA may not be flown at an indicated ai rspeed exceeding 50 knots

. 3. The UA may be operated at an altitude of no more than 400 feet above ground level ("AGL"), as indicated by the procedures specified in the attached manuals. All altitudes reported to AirTraffic Control ("ATC") must be in feetAGL. 4. The UA must be operated within visual line of sight ("VLOS" ) ofthe pilot-i n-command ("PIC") at all times. This requiresthe PIC to be able to use human vision unaided by any device othe r than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate

. 5. All operations must utilize avisual observer("VO"). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintain sVLOS capab i lity

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

.The PIC must be designated beforethe flight and cannottransfer his or her des ignation forthe duration ofthe flight. The PIC must ensure thatthe VO can perform the functions prescribed in the operator's manual.

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1802 Jan a Ln Morris Illinois 60450 Page4 of 13 6. The manuals must be amended to include all conditions and limitations required by the FAA. The manuals must be maintained and made available to the Administrator upon request. Ifa discrepancy exists between the conditions and limitations in the exemption and the procedures outlined in the manuals, the conditions and Iimitations inthe exemption take precedence and must be followed. Otherwise, the operator mustfollowthe procedures as outlined in the manuals. The operator may update or revise the manuals. It is the operator's responsibility to track such revisions and present updated and revised documentstothe Administrator upon request. The operator must also present updated and revised documents if it petitions for an extension oramendment ofthis exemption. If the operatordeterminesthat any update or revision would affectthe basis upon which the FAA granted this exemption, then the operator must petition for amendmentto its exemption. 7. Prior to each flight, the PIC must inspectthe UAS to ensure it is in a condition for safe flight. Ifthe inspection reveals acondition that affectsthe safe operation ofthe UAS, the aircraft is prohibited from operating unti Ithe necessary maintenance has been performed, and the UAS is found to be in a condition forsafe flight. The ground control station must be included inthe preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 8

. Any UAS that has undergone maintenance oralterations that affectthe UAS operation orflight characteristics, e.g., replacement of aflight critical component, must undergo afunctional testflight in accordance with the operator's manual. The PIC who conducts the functional testflight must make an entry in the UAS aircraft records of the flight. The manuals include this requirement. 9. The preflight inspection section in the manuals includes the following requirement: the preflight inspection must account for all discrepancies, i.e., inoperable components, items, orequipment, not cove red in the relevant preflight inspection sections ofthe operator's manual. 10. The ope rator must foilow RF Guys UA aircraft/component, maintenance, overhau I, rep Iacement, inspection, and Iife Iimit requirements, with particularattention to flight critical components that may not be addressed in the manufacturer's manuals. 11. Operator must carry out its maintenance, inspections, and record keeping requirements in accordance with the manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, incl udingtotal flight hours, description ofwork accomplished, and the signature ofthe authorized technician returni ngthe UAS to service. 12. The authorized technicians must receive and documenttraining referenced in the manuals. 13

. Each UAS operated underthe exemption must comply with all manufacturers system and safety bulletins. 14. Operator's maintenance personnel must make a record entry in the UAS logbook or equivalent document ofthe corrective action taken against discrepancies discovered between inspections. 15. The PIC must possess at least a private pilot certificate and athird-class airman medical certificate. The PIC must also meetthe flight review requirements specified in 14C.F.R. 61.56 as to the UAS.

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1802Ja na Ln Morris Illinois 60450 Page 5 of 13 16. The operator may not permit any PIC to operate unless that PIC has demonstrated through RF Guys trainingand currency requirementsthatthe PIC is able to safely operate the UA in a manner consistentwith howthe UASwill be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures. 17. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private orcontrolled-access property and land or be recovered in accordance with the manuals

. 18. The PIC must abort the flight in the event of unpredicted obstacles oremergencies in accordance with the manuals. 19. The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast weather conditions) there is enough powertoflyto the first point of intended landing and, assuming normal cruising speed, toflyafterthatforat least10 minutes. 20. The operatorwill file a requestfora Notice to Airmen (NOTAM) not more than 72 hours in advance , but not less than 48 hours priorto the operation

. 21. All aircraft operated in accordance with the exemption must be identified by serial number, reg istered in accordance with 14 C.F.R. part 47, and have identification (N-Number) markings in accordance with 14 C.F

. R

. part 45, Subpart C. Markings must be as large as practicable

. 22. Before conducting operations, the radio frequency spectrum used foroperation and control ofthe UA must comply with the Federal Communications Commission ("FCC") orotherappropriate government oversight agency requirements

. 23

. The documents required under 14C.F

. R

. 91.9 and 91

.203 must be available tothe PIC at the ground control station ofthe UAS any time the aircraft is operating. These documents must be made available to the Administratoror any law enforcement official upon request. 24

. The UA must remain clear and yield the right ofwayto all other manned operations and activities at all times (including , but not limited to, ultralightvehicles, parachute activities, parasailing activities , hang gliders, etc.)

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

. 26. UAS operations may not be conducted during night, as defined in 14 C.F.R. 1.1. 27. All operations shall be conducted in Class Gairspace. 28. All operations must be conducted undervisual meteorological conditions ("VMC"). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from acloud or when visibility is less than 3statute milesfrom the PIC. 29. During operations in Class G ai rspace, the UAS may not operate within 5 nautical miles ofthe geographic centerof an airport as denoted on a current FAA-publ ished aeronautical chart unless a letterof agreement with that airport's management is obtained, and the operation is conducted in

# RF Guys
1802 Ja na Ln Morris Illinois 60450 Page 6 of 13 accordance with a NOTAM as required by the operator's COA. The letterofagreement with the airport management must be made available to the Administrator upon request. 30. The UAS may not be operated overcongeste d ordensely populated areas unless the conditions set forth in #31 are satisfied. These populated areas include, but are not limited 

### to, the yellow areas depicted on World Aeronautical Charts ("WAC") , Sectional Aeronautical Charts ("Sectionals"), or Terminal Area Charts ("TAC"). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the PIC's responsibility to maintain the minimum safe altitudes required by§ 91.119

. 31. Operations must be conducted at least 500 feetfrom all nonparticipati ng persons (persons other than the PIC or VO), vessels, vehicles, and structures unless : a

. barriers or structures are presentthatsufficiently protect nonparticipating persons from debris inthe event ofan accident. The operator must ensure that nonparticipating persons remain undersuch protection.lfa situation arises in which nonpa r ticipating persons leave such protection and are within 500 feet ofthe UAS , flight operations must cease immediately; and/or b

. the aircraft is operated nearvessels, vehicles, orstructures where the land owner/controller has granted permission and the PIC has made a safety assessment ofthe risk of operating closerto those objects ; and c. operations nearthe PIC or VO do not present an undue hazard to the PIC or VO, per§ 91.119(a)

. 32

. All ope rations shall be conducted over private orcontrolled-access property with permission from the land owner/controller orauthorized representative. Permission from land owner/controlleror authorized representative will be obtained for each flight to be conducted. 33

. In the event COAs are required, any incident, accident, orflight operation thattransgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office ("AFS-80") within 24 hours. Accidents must be reported to the National Transportation Safety Board (" NTSB") per instructions contained on the NTSB Web site: www
. ntsb

.gov

. 

### Privacy. All flights will occur over private orcontrolled access property with the property owner's prior consent and knowledge.lnspection will be in areas where the owners will have consented to the inspections orotherwise have agreed to allowthe UAS and the operatorto be in the area where inspection will take place. 

### Summary In summary, RF Guys seeks an exemption from the FARs setforth in AppendixA to operate commercially asmall unmanned vehicle (551bs. or less) in aerial survey and photographic operations

.

# RF Guys
1802 Ja na Ln Morris Illinois 60450 Page 7 of 13 Approval of this exemption for commercia I aeri aI survey and photographic operation s wi II enha ncesafety by reducing risk. Conventional operations, us i ngjet or piston powered aircraft, operate at extremely low altitudes just feet from the subject being inspected and in extreme proximityto people and structures. Such manned operations present the risks associated with vehicles that weigh in excess of 6000 Ibs

., carrying Iarge amounts of combustible fuel. Such ai rcraft mustfly to and from the project location

. In contrast, as UAS weighing fewer than fifty five (55) Ibs. , and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried on boa rd

.The sUAS is carried to the area offlight and not flown. The sUAS wi II carry no passengers of crew and, therefore, wi II not expose them to the risks associated with manned a i rcraftfl ights

. The operation of small UASs, weighing less than fifty five (55) lbs

., conducted in the strict conditions outlined above, wi II provide an equivalent IeveI of safety supporti ngthe grant of exemptions requested herein

. These Iightweight aircraft operate at slowspeeds, close to the ground , and in areas that are under the control of the customer. As a result, they arefar safer than conventiona I operations conducted with manned aircraft operating in close proximityto the ground and people

. Satisfaction ofthe criteria provided in Section 333 of the Reform Act of 20 12

-- .size, weight, speed, operating capabi Iities, proxi mityto airports and populated areas, and operation within visual! ine ofsight and national security-provide more than adequate justification for the grant of the requested exemptions aII owing commercial operation of applicants UAS for the purposes out! i ned here in and are consistentwith exemptions already granted, including Exemptions 11062 through 11067,11080,11109,through 11112, and 11114. Sincerely,

# :B~~ Brandon Kindelspire RF Guys Sole Proprietorship 1802 Jana Ln Morris Illinois 60450

# RF Guys
1802Jan a Ln Morris Illinois 60450 Page 8 of 13 

## APPENDIX A EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION RF Guys requests an exemption from the following regulations as well as any additional regulations that may technically applyto the operation ofthe sUAS: 

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and lim ited operating area associated with the aircraftto be utilized by the App l icant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety unde r Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementforan airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS

. In all cases, an analysis ofthese criteria demonstrates thatthe UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The sUAS to be operated hereunder is less than f ifty-five (55) lbs. fully loaded, carries neithera pilot no r passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a secured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightly controlled and monitored by both the operatorand underthe requirements and in compliance with local publicsafety requirements

.The FAA wi II have advance notice of all operations. These safety enhancements provide agreaterdegree of safetyto the pubIic and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F

. R

. Part 21 , Subpart H. Lastly, application ofthese same criteria demonstrates thatthere is no credible threatto national security posed by the sUAS, due to its size, speed ofoperation, location of operation, lack of explosive materials or flammable liquid fuels, and inabilityto carry a substantial external load

. 

### 14 C.F.R. §45.23 (b): Display of Marks, General When marks include onlythe Roman capital letter 11 N" and the registration number is displayed on limited, restricted or Iight-sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 i nches high, the words 11limited," 11 restricted," 11lightsport," uexperimental," or**~~provisional,"** as applicable

. An exemption is being sought given the size and design ofthe sUAS. The sUAS has no entrance near the cabin, cockpit or pilot station where the word 11 Experi mental"letters of not less than 2 inches nor more than 6 inches high can be displayed.

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1802Ja na Ln Morris Illinois 60450 Page 9 of 13 The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f)

. The equivalent level ofsafety will be provided by havingthe sUAS marked on its fuselage as required by §45.29 (f) where the sUAS air vehicle (AV) vehicleoperator(VO), AV visual observer, and others working with the sUAS will see the identification ofthe sUAS as marked appropriately with registered aircraft markings

. Each RF Guys sUAS air vehicle shall be registered with the FAA and the FAA aircraft registration numbe r shall be placed on the airvehicle in the largest practicable manner. The FAA has issued the following exemptions tothis regulation to Exemptions Nos.10700, 8738, 10167 and 10167A

. 

### 14 C.F.R. §61.113 (a) & 

### (b): Private Pilot Privileges and Limitations: Pilot in Command (a) Except as provided in paragraphs (b) through (h) ofthis section , no person who holds a private pilot certificate may act as pilot in command of an aircraft that iscarrying passengers or propertyfor compensation or hire; nor may that person, for compensation or hire, act as pilot i n command of an aircraft

. (b) A private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connection with any business or employment if : (1) The flight is only incidentalto that business oremployment; and (2) The aircraft does not carry passengers o r propertyfor compensation or hire. Unlike aconventional aircraftthat carries a pilot, passengers, and cargo, no persons or property are being carried bythe sUAS. The risks associated with the operation ofthe sUAS (given its size, speed, operational capabilities, and lack ofcombustible fuel) are greatly diminished from the level of risk associated with commercial operations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft). Given these safety features,RF Guys proposes that operators ofthe sUas should not be required to hold a commercial pilotcertification

. Instead , operators should be required to hold only a private pilot certification

. 

### 14 C.F.R. §91.7(a): Civil aircraft airworthiness (a) No person may operate a civil aircraft unless it is in an airworthy condition

. (b) The pi lot in command of a civil aircraft is responsible for determining whetherthat aircraft is in condition forsafe flight

.The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, orstructural conditions occur

. No airworth i ness certificates are issued forthe sUAS, should this exemption be granted, no FAA regulatory standard will exist for dete rmining airworthiness.

# RF Guys
1802Ja na Ln Morris Illinois 60450 Page 10 of 13 Given the size ofthe aircraft and the requirements setforth in the sUAS manuals , an equivalent level of safety will be achieved by ensuring com pi iance priorto each flight

.The FAA has granted exemptions to conduct similaroperations in Exemptions 11062 through 11067, 11080, 11109, and 11110. 

### 14 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual, Marking, and Placard requirements (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, orany combination thereof. Given its size and configuration, the sUAS has no ability or place to carry such a flight manual on the aircraft, there is no pilot on board, and no room or capacity to carry such an item on the sUAS. The equivalent level ofsafety will be maintained by keeping the flight manual atthe GCS within the reach of the sUAS vehicle operatorforimmediate access

.The FAA has issued the following exemptionstothis regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. 

### 14 C.F.R. §91.1 03: Preflight action This regulation requires each pilot in command totake certain actions before flightto insure the safety of flight. As FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafety will be provided as setforth hereinabove. The PIC willtake all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft I performance data before initiation offlight using appropriate checklists. 

### 14 C.F.R. §91.109: Flight instruction; Simulated instrument flight and certain flight tests Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft has fully functioning dual controls. sUAV's and remotely piloted aircraft, bytheirdesign do not have fullyfunctional dual controls. Flight control is accomplished through the use of a radiotransmitterthat communicates with the aircraftvia a receiver in the sUAVS. The FAA has approved exemptions forflighttrainingwithoutfullyfunctional dual controls fora numberofaircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K 

### & 9862A. The equivalent level ofsafety provided by the fact that neithera pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.

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1802Ja na Ln Morris Illinois 60450 Page 11 of 13 

### 14 C.F.R. §91.119: Minimum safe altitudes: General Section 

### 91

. 119 establishes safe altitudes foroperation of civil aircraft. Section 

### 91.119(d) allows helicoptersto be operated at less than the minimums prescribed, provi ded the pe rson operatingthe helicoptercomplies with any route oraltitudes prescribed for helicopters by the FAA

.This exemption is for a SUAVS and the exemption requests authorityto operate at altitudes up to 400 AGL underneath navigable airspace and in class Eand G airspace maintaining safe separation from actual aircraft, an exemption may be needed to allow such operations

. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well as the location where it is operated

. No flight' will be taken withoutthe permission ofthe property owneror local officials. Because ofthe advance notice to the property owner and participants in the filming activity, attemptswill be made to contact all affected individuals regarding the planned flight operations. Compared toflight operations with aircraft or rotorcraft weightingfar more than the maximum fiftyfive (55) lbs. proposed herein, and the lack offlammable fuel , any risk associated with these operations is far less than those presently presented with conventional aircraft. In addition ,the low-altitude operations ofthe SUAVS wi 

### II ensure sepa ration between these sUAVS operations and the operations of conventional aircraftthat must comply w ith Section 

### 91.119. 

### 14 C

.F.R. §91

.121 Altimeter Settings This regulation requ i res each person operating an aircraftto maintain cruising altitude by referenceto an altimeterthat is set"

... to the elevation ofthe departure ai rport oran appropriate altimetersetting available before departure

. " As the SUAVS rnay not have a barometricaltimeter, but instead aGPS altitude read out, an exemption may be needed. An equivalent level of safety w ill be achieved by the operator, pu rsuantto the Manual and Safety Check list, confi rm ing the altitude ofthe launch site shown on the GPS altitude indicator before flight

.

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1802 Ja na Ln Morris Illinois 60450 Page 12 of 13 

### 14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions (a} No person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weatherconditions) t here is enough fuel to flytothe first point of intended landing and, assuming normal cruisingspeed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes

. (b) No person may begin aflight in a rotorcraft underVFR conditions unless (considering wind and forecast weatherconditions) there isenough fuel to fly to the first point of intended Iandin g and, assuming normal cruising speed, to fly afterthatfor at least 20 minutes

. Section 91.151 (a} prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (consideringwind and forecast weathe r conditions) there is enough fuel to fly to the first point of i ntended landing, and, assuming normal cruising speed-(1} Duringthe day, to fly afterthat for at least 30 minutes; or(2) At night, to fly afterthat for at least45 minutes." The battery poweringthe sUAS has a 20-20 minute duration for powered flight. As a result, an exemption from 30 minute fuel reserve

. RF Guys believe thatan equiva lent level ofsafety can be achieved by limitingfl ights to landing with no less than 25% of battery power remaining

.This restriction would be more than adequate to return the sUAV to its planned Iandi ng zone from anywherewithin its Iimited operati ng area. Similar exemptions have been granted to numerous otherope rations

. 

### 14 C.F.R. §91.203 (a} and (b): Civil Aircraft: Certifications required (a) Except as provided in §91. 715, no person may operate acivil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness ce rtificate .

. .. .. (2) An effective U.S. registration certificate issued to its owneror, for ope ration within the United States, the second copy ofthe Aircraft registration Application as provided for i n §47

.31(c), or a registration certification issued underthe laws ofa foreign country. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew

. The sUAS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. And is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS

.

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1802Ja na Ln Morris Illinois 60450 Page 13 of 13 An equivalent level of safetywill be achieved by keepingthese documents atthe ground control point where the pilotflying the sUA$ will have immediate access to them, tothe extenttheyare applicableto the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos

. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

### 14 C.F.R. 

### § 91.405 (a); 407 

### (a) (1); 409 

### (a) (2); 417(a) & 

### (b): Maintenance Inspections These regulations require that an aircraft operatoror owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired asp rescribed in part43 ofthis chapter

. . . ," and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese section and Part 43 apply onlyto aircraft with an airworthiness certificate, and the requirements of pre -flight inspection required herein, these sections will not applyto the applicant. Routine and pre-flight maintenance will be accomplished by the operator. An equivalent level of safety will be achieved because these sUAVS are very limited in size and will carry avery small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the sUAV can land immediately and given its small size poses very little risk to persona or property

. The operatorwill ensure thatthe sUAVis in workingorderpriorto initiatingflight, perform required maintenance, and keep a log of any maintenance performed

. Moreover, the operator is the person most familiarwith the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level ofsafety.