Peter Bretherton

Director of Operations

Advanced Aerial Inspections, Inc.

2024 White Feather Trail

Crosby, TX 77532

Cell: 281-543-1144

Email: 4peter@gmail.com

March 10, 2016

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Advanced Aerial Inspections, Inc. for an Exemption Pursuant to Section 333 of the FAA

Modernization and Reform Act of 2012

To Whom It May Concern:

I would like to file using the FAA Summary Grant Speed UAS Exemption that will be based on the

practically identical 12/09/2014 filing by M&G Enterprises Exemption No. 11302 Regulatory Docket No.

FAA-2014-1032 which was granted on 4/8/2015.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14

C.P.R. Part 11, Advanced Aerial Inspections, Inc. hereby applies for an exemption from the Federal

Aviation Regulations ("FARs") identified below, to allow commercial operations of small unmanned

aerial vehicles.

This exemption is made based on information outlined in this petition, as well as the accompanying DJI

S1000 User Manual and the Advanced Aerial Inspections, Inc. Operational Limitations (Appendix B).

The DJI S1000 UAS was selected because it has a proven capability for controlled flight as well as a gyro

stabilized flight mode, GPS aided navigation, a compass, blinking LED’s on the bottom and a failsafe

mode for returning home. These devices are offered for general sale around the world and have often been

used as Model Aircraft in the USA.

Specifically, the UAS is:

- A lightweight (< 40.0 lb gross weight with all on-board equipment), battery operated 8-motor

rotorcraft in the form of a octocopter that takes off and lands vertically, manufactured by DJI,

Model S1000, with the following equipment:

- An on-board flight computer with GPS navigation and location ability that receives signals for

flight controls from a ground-based transmitter/controller;

- Dual on-board cameras capable of capturing imagery in the form of full color, high definition still

photos and video;

- An on-board telemetry system that delivers flight data from the on-board flight computer to the

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass

direction of flight and direction back to its launch site;

- A 600mW, 5.8GHz on-board radio transmitter that transmits live video from the on-board camera

plus all the flight data from the telemetry system described above;
The Ground Station Includes:

- A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and

who controls the UAS while in the air;

- A 100mW, 2.4GHz radio transmitter/controller operated by the PIC to control the UAS while in

flight;

- A radio receiver receiving live video and flight data from the on-board camera and computer

projects it all together onto a screen for the PIC to view during flight;

- A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UAS

while in flight.

Proposed Operations:

Advanced Aerial Inspections, Inc. intends to use UAS in three general areas.

First, Advanced Aerial Inspections, Inc. seeks an exemption to perform video filming and photographing

by air for public and private use. Second, it will employ UAS’s to inspect land, residential commercial

and industrial structures and property. Third, Advanced Aerial Inspections, Inc. seeks permission to use

UAS to offer training to persons, from both private and public entities, which are interested in the safe

operation of UASs.

Specifically, Advanced Aerial Inspections, Inc. will use UASs which are equipped with cameras and

sensors, in order to engage in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, including: television,

cinematography, advertising, promotions, public or news mass events.

(b) Video filming by air and photographing to support professional operations in engineering, land

surveying, construction, architecture, real estate and other related professional activities.

(c) Inspections by air of agricultural areas.

(d) Inspections by air of infrastructure such as bridges, highways, electrical installations, dams, aqueducts,

photovoltaic power stations, wind farms and pipes. These inspections will only be done under contract

with the owners or with any local government authority.

(e) Inspection by air of land and residential, commercial and industrial structures, only under contract

with the owners or with any local government authority.

(f) Inspections by air to detect sources of pollution and gas emissions, under contract with the owners in

the area or with any local government authority.

(g) Support provided to search and rescue operations and reconnaissance in cases of need, emergency or

natural disasters and only when government authorities have requested it by contract or donation.

(h) Advanced Aerial Inspections, Inc. is passionate about offering training to persons, private and public

entities, which are interested in the safe use of UASs, for purposes of enhancing the skills and safety

controls which make the NAS safer and for the protection of persons and property.
Relevant Statutory Authority

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant

to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to

operate in the National Air Space ("NAS") where it is safe to do so based on the following considerations:

• 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 the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's safety

regulations and minimum standards when the Administrator decides a requested exemption is in the

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from§§ 44701(a), (b) and§§ 44702-44716,et seq.). A party requesting an

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

Advanced Aerial Inspections, Inc. Proposed UAS Operations Meet the Requirements of Section 333

of the Reform Act

Advanced Aerial Inspections, Inc. proposed operations in this Petition for Exemption qualify for

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and

relevant factors are satisfied.

Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational Capability

Advanced Aerial Inspections, Inc. will employ the DJI S1000 octocopters for the operations specified in

this Petition for exemption. The S1000 UASs have a maximum take-off weight of less than 40 pounds,

the flight speed will not exceed 35 miles per hour, and it will not be flown in controlled airspace or at an

altitude that exceeds 400 feet AGL. All flights will be flown in such a way that they can be safely

terminated with a reserve battery power of 25% of the battery's maximum charge. The DJI S1000 UASs

do not carry any flammable propellant or fuel. The S1000 UAS also has an integrated GPS system that

calculates the UAS’s position and height and relays that information via a secure connection to the

operator. Additionally, the S1000 UAS contain a failsafe mode if its connection to the remote control is

lost, and this system permits the UAS to return to a predetermined location and land without injury or

damage.

Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations Manual.

The Advanced Aerial Inspections, Inc. Operations Limitations and the DJI's operators manual contain all

of the procedures and limitations necessary to successfully perform the operations specified in this

Petition for Exemption. (Submitted User’s Manual and Appendices B).

Public Interest

The public interest will be served by granting Advanced Aerial Inspections, Inc. Petition for Exemption.

Congress has established a national policy that favors early integration of UASs into the NAS in

controlled, safe working environments such as those proposed in this Petition. In addition, the public also

has an interest in reducing the hazards associated with alternate methods of conducting similar operations.

Currently operations are conducted using teams that physically climb onto structures using ladders, using

low flying helicopters or aircraft, or simply not available by traditional means. By using UAS, exposure

to physical hazards will be reduced of conducting the operation while remaining safely on the ground.

Additionally, Advanced Aerial Inspections, Inc. intended uses for the UAS’s have identifiable safety

benefits that include reducing the danger and emissions associated with full size helicopters, UAS have no
fuel to ignite or explode, no crew, adds a greater degree of flexibility, which supplements the current

capabilities offered by manned aircraft, and public interest for a ground impact for of a small lightweight

UAS is further minimized from an ecological and safety standpoint.

Federal Register Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed:

Advanced Aerial Inspections, Inc. seeks an exemption from the following rules:

Parts 21; §§ 45.23(b); 27; 61.113(a) and (b); 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121;

91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14,

Code of Federal Regulations (14 CFR).

The exemption will enhance safety by reducing risk to the general public and property owners from the

substantial hazards associated with performing equivalent work with conventional aircraft, rotorcraft, or

other methods.

Conclusion

Advanced Aerial Inspections, Inc. Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to airports and

populated areas, operation within visual line of sight and national security. Additionally, the Petition

provides more than adequate justification for the grant of the requested exemptions to permit

Advanced Aerial Inspections, Inc. to operate the selected UAS for the operations specified herein.

Granting the exemption will benefit the public interest as a whole in several ways, including (1)

significantly improving safety and reducing risk by alleviating human exposure to danger, and (2)

improving the quality of services and decreasing operating costs compared with conventional flight

operations.

Very Respectfully,

Peter Bretherton

Director Of Operations, Advanced Aerial Inspections, Inc.

2024 White Feather Trail

Crosby, TX 77532

4peter@gmail.com
Appendix A

The regulations from which the exemption is requested are listed below. Beside each regulation number is

the page of the attached Appendix A upon which each may be found together with our proposed

equivalent level of safety for each regulation:

Parts 21,§§ 45.23(b); 27, 61.113(a) and (b) 61.3; 91.7(a); 91.9(b)(2); 91.103; 91.109; 91.119; 91.121;

91.151(a); 91.203(a) and (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14,

Code of Federal Regulations (14 CFR).

Exemptions Requested

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under§ 40101 of the Act,

including UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

Advanced Aerial Inspections, Inc. seeks an exemption from several interrelated provisions of 14 C.F.R.

Parts 21, 27, 45, 61 and 91 for purposes of conducting the requested operations using a UAS. Listed

below are the specific sections of 14 C.F.R. for which exemption is sought:

14 C.F.R. Part 21, Subpart H - Airworthiness Certificates

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform

Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used

for the same application. (Regulatory Docket No. FAA-2014-0352). These criteria are met, and therefore

no exemption is needed.

Equivalent Level of Safety

The UAS selected by Advanced Aerial Inspections, Inc. is safe when taking into account their size,

weight, speed, and operational capability. The UAS weigh less than 40 pounds and will be flown at less

than 35 miles per hour and completely outside controlled airspace. Additionally, the UAS carry neither

pilots nor passengers, carry no explosive materials and or flammable liquid fuels, and operate exclusively

within the parameters stated in the Operator’s Manual and Operations Limitations.

Operations under this exemption will be closely controlled and monitored by the operator and will be

conducted in compliance with local public safety requirements, to provide security for the area of

operation. Advanced Aerial Inspections, Inc. will also provide the FAA with advance notice of all

operations via NOTAMS and coordination with the local FSDO. In all cases, the UAS operated under the

proposed conditions, will be at least as safe as, or safer than conventional rotorcraft operating with an

airworthiness certificate without the restrictions and conditions of the proposed UAS operations.

14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.P.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category

rotorcraft. To the extent the Advanced Aerial Inspections, Inc. UAS would otherwise require certification

under Part 27, we seek an exemption from Part 27's airworthiness standards for the same reasons

identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

14 C.F.R. §§45.23(b), Display of marks; general

These regulations provide that each aircraft must display "N" and the aircraft's registration number in

letters at least 2 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS does not

have an entrance in which the word "EXPERIMENTAL" can be placed; however, Advanced Aerial

Inspections, Inc. will obtain and display “N” and the aircrafts’ registration name which will be assigned

by the FAA.
Advanced Aerial Inspections, Inc. proposes to achieve an equivalent level of safety by including the word

"EXPERIMENTAL" as large as practicable on the top of the aircraft, where the PIC, VO and others in the

vicinity of the aircraft while it is preparing for launch will be able to see the designation. Finally, the

ground station will display a high contrast flag or banner that contains the words "Unmanned Aircraft

Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the

ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate

its point of origin.

In a previous Grant of Exemption, Regulatory Docket No. FAA-2014-0352, the FAA determined that

exemption from these requirements was warranted provided that the aircraft "have identification (NNumber) markings in accordance with 14 C.F.R part 45, Subpart C if the markings are as large as

practicable."

14 CFR § 61.113 (a) and (b); 61.3 (c,2-v): Private Pilot Privileges and Limitations, Medical

Certificate

In addition, Advanced Aerial Inspections, Inc. seeks exemption from 14 C.F.R § 61.113, which restricts

private pilot certificate holders from flying aircraft for compensation or hire, and which would also

require a second class medical certificate. The purpose of this section is to ensure the skill and

competency of any PIC where the aircraft is carrying passengers or cargo for hire. In this case, while the

UAS will be operated as part of a commercial operation, it carries neither passengers nor cargo. In the

Grant of Exemption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique

characteristics of UAS operation outside of controlled airspace did not warrant the additional cost and

restrictions attendant with requiring the PIC to have a commercial pilot certificate and class II medical

certificate. Additionally, instead of having a second or third class medical, we suggest that the PIC

exercise the privileges similar to that of a sport pilot, requiring only a valid US driver’s license.

Safety Mitigation

Advanced Aerial Inspections, Inc. seeks to ensure safe operation by ensuring that any PIC is thoroughly

versed in airspace and communication issues pertaining to all aircraft operators but also in the unique

aspects of UAS flight. The director of operations has private pilot’s license, and Advanced Aerial

Inspections, Inc. will require a PIC to have a minimum of a private pilot’s license and adhere to the flight

limitations listed in Appendix C.

We find that the combination of aeronautical knowledge, UAS airmanship skills, and verification through

remaining current is a sufficient method to evaluate a pilot’s qualifications, given that operations will be

conducted within the limitations outlined in this petition.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Advanced Aerial Inspections, Inc. seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a

civil aircraft be in airworthy condition to be operated. The FAA has stated (Regulatory Docket No. FAA2014-0352) that no exemption is required to the extent that the requirements of Part 21 are waived or

found inapplicable.

14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

Given its size, configuration, and load capacity, the DJI S1000 has no ability to carry such a manual on

the aircraft, not only because there is no pilot on board, but because there is simply no room or capacity to

carry such an item on the aircraft.

Safety Mitigation

The safety related purpose of this manual requirement can be equally satisfied by maintaining the S1000

Manual at the ground control point where the pilot flying the S1000 will have immediate access to it.
Accordingly, we request an exemption from § 91.9(b) (2)'s flight manual requirements, on the condition

that the S1000 flight manual be available at the control point during each operation.

14 C.F.R. § 91.103: Preflight Action

Advance Aerial Inspections, Inc. seeks an exemption from 14 C.P.R.§ 91.103, which requires a PIC to

become familiar with specific information before each flight, including information contained in the

FAA-approved Flight Manual on board the aircraft. While the PIC will be familiar with all information

necessary to safely conduct the flight, an exemption is requested to the extent that an FAA-approved

Flight manual is required.

Safety Mitigation

An equivalent level of safety will be provided by following the Aircraft Operations Manual and flight

manual provided by the manufacturer. The PIC will take all required preflight actions- including

performing all required checklists and reviewing weather, flight requirements, battery charge, landing and

takeoff distance, aircraft performance data, and contingency landing areas- before initiation of flight. The

Operators Manual and Operational Limitations will be kept at the ground station with the operator at all

times.

14 C.F.R. § 91.109(a): Flight Instruction

Advanced Aerial Inspections, Inc. seeks an exemption from 14 C.F.R. § 91.109(a), which provides that

"no person may operate a civil aircraft (except a manned free balloon) that is being used for flight

instruction unless that aircraft has fully functioning dual controls." UAS and remotely piloted aircraft, by

their design, do not have functional dual controls. Instead, flight control is accomplished through the use

of a device that communicates with the aircraft via radio communications.

Safety Mitigation

Given the size and speed of the UAS employed by Advanced Aerial Inspections, Inc., an equivalent level

of safe training can still be performed without dual controls because no pilot or passengers are aboard the

UAS, and all persons will be a safe distance away in the event that the UAS encounters any difficulties

during flight instruction. In addition, we will conduct flight training at our Research and Development test

sites, which are located on its own property. These training flights will be conducted in a sterile area and

will otherwise comply with the provisions in the Operator’s Manual for flights at the R&D facility. The

FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. § 91.119: Minimum Safe Altitudes

Advanced Aerial Inspections, Inc. requests an exemption from the minimum safe altitude requirements of

14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or structure in

non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at

less than those minimum altitudes when it can be operated "without hazard to persons or property on the

surface," provided that "each person operating the helicopter complies with any routes or altitudes

specifically prescribed for helicopters by the FAA."

Safety Mitigation

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed

herein, and given the lack of flammable fuel, any risk associated with these operations is far less than

those that presently exist with conventional aircraft. An equivalent level of safety will be achieved given

the size, weight, and speed of the UAS, as well as the location where it is operated. In order to avoid any

risk to aircraft, flight operations will be restricted to 400' AGL or below
14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an aircraft

to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the

departure airport or barometric pressure. An exemption is required to the extent that the UAS do not have

a barometric altimeter, but rather a GPS altitude read out.

Safety Mitigation

The FAA has stated that an equivalent level of safety can be achieved if the UAS will be operated at 400'

AGL or below and within visual line-of-sight in addition to GPS based altitude information relayed in real

time to the operator. See Grant of Exemption to Astraeus Aerial, Docket No. FAA-2014-0352. As the

attached Operations Manual indicates, the chosen UAS meets these requirements, and a zero altitude

initiation point will be obtained prior to flight

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Advanced Aerial Inspections, Inc. requests an exemption from 14 C.F.R. § 91.15l(a)'s fuel requirements

for flight in VFR conditions. Section 91.151 states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming

normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

Here, the technological limitations on UAS battery power means that no meaningful flight operations can

be conducted while still maintaining a 30 minute reserve. Advanced Aerial Inspections, Inc. proposes that

all flights comply with this requirement by mandating that the aircraft be safely landed with no less than

25% of battery life remaining.

Safety Mitigation

The FAA has stated that an equivalent level of safety is provided if the UAS flight is terminated with at

least 25% reserve battery power still available. See Grant of Exemption to Astraeus Aerial, Docket No.

PAA-2014-0352. The Operations Manual conforms to this limit, providing an equivalent level of safety.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew."

At a maximum gross weight of less than 40 pounds, the UAS is too small to carry documentation, does

not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of

safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by

the FAA will be co-located with the crew at the ground control station and available for inspection upon

request. The FAA has stated (Regulatory Docket No. FAA-2014-0352) that no exemption is required.

14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) Maintenance Required

Advanced Aerial Inspections, Inc. seeks an exemption from the maintenance inspection requirements

contained in 14 C.P.R.§ 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations

specify maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.P.R. §

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as

prescribed in subpart E of this part and shall between required inspections ...have discrepancies repaired

as prescribed in part 43 of this chapter"). An exemption from these regulations is needed because Part 43

and these sections only apply to aircraft with an airworthiness certificate, which the UASs will not have.
Safety Mitigation

An equivalent level of safety will be achieved because maintenance and inspections will be performed in

accordance with the Operators Manual. As provided in the Operators Manual, flights will not be

conducted unless a flight operations checklist is performed that includes all of the aircraft's components.

Appendix B

Operational Limitations

1. The unmanned aircraft system (UAS) will weigh less than 40 pounds, including energy source(s) and

equipment.

2. The UAS will not be flown at a ground speed exceeding 35 MPH.

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated

by the procedures specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL.

4. The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the

PIC to be able to use human vision unaided by any device other than corrective lenses.

5. All operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to

communicate verbally at all times.

6. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. If the

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

operating until the necessary maintenance has been performed and the UAS is found to be in a condition

for safe flight. The Ground Control Station, if utilized, will be included in the preflight inspection. All

maintenance and alterations will be properly documented in the aircraft records.

7. If the UAS 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 in

accordance with the operator’s manual. The PIC who conducts the functional test flight will make an

entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight

and aircraft record entry will be added to the operator’s manual.

8. The operator will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements. When unavailable, aircraft

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will be

established and identified in the operator’s manual. At a minimum, requirements for the following will be

included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);
c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;

9. The Pilot In Command (PIC) will possess at least a private pilot certificate and at least a valid driver’s

license. 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.

10. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least

ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). Prior documented

flight experience that was obtained in compliance with applicable regulations may satisfy this

requirement. Training, proficiency, and experience-building flights can also be conducted to accomplish

the required flight cycles and flight time.

11. Prior to operations the PIC will have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for

operations and three take-offs and three landings in the preceding 90 days. Training, proficiency,

experience-building, and take-off and landing currency flights can be conducted to accomplish the

required flight cycles and flight time.

12. The UAS may not be operated directly over any person, except authorized and consenting personnel,

below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or

emergency.

13 The operator will ensure that no persons are allowed within 500 feet of the area except those

consenting. This provision may be reduced to no less than 200 feet if it would not adversely affect safety.

14. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in accordance with

the operator’s manual.

15. Each UAS operation will be completed within 30 minutes flight time or with 25% battery power

remaining, whichever occurs first.

16. The operator will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations. This COA will also require the operator to

request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior

to the operation.

17. All aircraft operated in accordance 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 must be as large as practicable.

18. Each UAS operated will comply with all manufacturer Safety Bulletins.

19. The radio frequency spectrum used for operation and control of the UA will comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency requirements.

20. At least three days before scheduled flight, the operator will submit a written Plan of Activities to the

local FSDO with jurisdiction over the area of proposed flight area. The 3-day notification may be waived

with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator

c. Make, model, and serial or N-number of UAS to be used;

d. Name and certificate number of UAS PIC involved
e. A statement that the operator has obtained permission from property owners and/or local officials to

conduct the flight operations; the list of those who gave permission must be made available to the

inspector upon request;

f. Signature of exemption-holder or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or

state over which flights will be conducted and the altitudes essential to accomplish the operation.

22. The 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. The UA will remain clear and yield the right of way to all other manned operations and activities at all

times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang

gliders, etc.).

24. 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.

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

26. The UAS 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.

27. The UAS will not operate in Class B, C, or D airspace without written approval from the FAA. The

UAS may not operate within 5 nautical miles of the geographic center of a non- towered airport as

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as required by the

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

Administrator upon request.

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.