D&C Inspection Services, Inc. proposes the following changes to our existing 333 Exemption No. 

11731, Regulatory Docket No. FAA–2015–0061. The criteria proposed in this modification request 

provides for compliance to the current FAA regulations contained in Small Unmanned Aircraft 

Regulations (Part 107).

1. sUAS must weigh less than 55 pounds including payload. 

2. The sUAS may not be operated at a speed exceeding 87 knots (100 miles per hour) and 

in no case will the sUAS be operated at airspeeds greater than the maximum sUAS 

operating airspeed recommended by the sUAS manufacturer.

3. The sUAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL) or, if higher than 400 feet AGL, remain within 400 feet of a structure.

4. Visual line of sight (VLOS) operations only; the sUAS must remain within VLOS of the 

remote operator or the VO (visual observer) at all times during operations.

5. The VO may be used to satisfy the VLOS requirement as long as constant verbal 

communications between the remote operator and the VO exists.

6. At all times the sUAS must remain close enough so that the remote operator or VO are 

capable of seeing the sUAS with vision unaided by any device other than corrective 

lenses.

7. First - person view camera cannot satisfy “see - and - avoid” requirement but can be used 

as long as requirement is satisfied in other ways.

8. Electronic messaging or texting is not permitted during sUAS flight operations.

9. No person may act as a remote operator or VO for more than one sUAS operation at one 

time.

10. The remote operator must be designated before the flight and cannot transfer his or her

designation for the duration of the flight.

11. The remote operator must ensure that the VO can perform the duties required of the VO.
12. The remote operator is responsible for maintaining and inspecting the sUAS to ensure

that it is in a condition for safe operation.

13. Prior to each flight, the remote operator must conduct a pre-flight inspection and 

determine the sUAS is in a condition for safe flight. The pre-flight inspection must 

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

If the inspection reveals a condition that affects the safe operation of the sUAS, then the

sUAS is prohibited from operating until the necessary maintenance has been performed 

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

14. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation 

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

functional test flight prior to conducting further operations under this exemption.

15. Functional test flights can be conducted by a remote operator with or without VO and 

must maintain VLOS for the duration of the functional test flight, the test flight must be

conducted in such a manner so as to not pose an undue hazard to persons and property.

16. A person may not operate a sUAS if he or she knows or has a reason to know of any 

physical or mental condition that would interfere with the safe operation of the sUAS.

17. The remote operator must follow the manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the sUAS and sUAS components.

18. Make available to the FAA, upon request, the small UAS for inspection or testing, and any 

associated documents/records required to be kept under the proposed rule.

19. sUAS operations may not be conducted during night (daylight only operations 30 minutes 

before official sunrise to 30 minutes after official sunset, local time) with appropriate anti -

collision lighting)

20. The sUAS must remain clear and give way to all manned aviation operations and 

activities at all times.

21. The remote operator must abort the flight in the event of unpredicted obstacles or

emergencies.

22. If the sUAS loses communications or loses its GPS signal, the sUAS must return to 
a pre-determined location within the private or controlled-access property.

23. The remote operator must leave a reserve of at least 10-15% battery capacity or what is

recommended by the manufacturer if greater.

24. The remote operator is prohibited from beginning a flight unless (considering wind and

forecast weather conditions)

25. Minimum weather visibility of 3 miles from control station.

26. Documents used by the remote operator to ensure the safe operation and flight of the sUAS

must be available to the remote operator at the Ground Control Station of the sUAS

anytime the sUAS is operating.

27. All operating documents must be made available to the Administrator or any law 

enforcement official upon request.

28. The sUAS may not be operated from any moving device or vehicle, unless the operation is 

being conducted over a sparsely populated area.

29. The sUAS may not be operated from any manned aircraft.

30. Operations in Class B, C, D and E airspace are allowed with the required ATC permission.

31. Operations in Class G airspace are allowed without ATC permission.

32. External load operations are allowed if the object being carried by the sUAS is securely 

attached and does not adversely affect the flight characteristics or controllability of the 

aircraft. Transportation of property for compensation or hire allowed.

33. A person operating a sUAS must either hold an FAA-issued Remote Pilot Certificate with a 

small UAS rating or be under the direct supervision of a person who does hold an FAAissued Remote Pilot Certificate with a small UAS rating.

34. Report to the FAA within 10 days of any operation that results in at least serious injury, loss 

of consciousness, or property damage of at least $500.
35. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property

owner/controller or authorized representative will be obtained for each flight to be

conducted. These documents must be made available to the Administrator or any law 

enforcement official upon request.

36. All sUAS may not be operated over any persons not directly involved in the operation.

37. All aircraft must be registered in compliance with part 107.13 part 91

38. The remote operator may deviate from the limitations of this exemption in the response to 

an inflight emergency.

39. Remote operators must have a TSA issued Transportation Worker Identification Card 

(TWIC) and be at least 17 years old.

40.Any remote operator may not operate a sUAS unless the remote operator has demonstrated 

the ability to safely operate the sUAS in a manner consistent with how the sUAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures.

41. Flights for the purposes of training the holder of this exemption remote operators and VOs 

(training, proficiency, and experience-building) and determining the remote operators 

ability to safely operate the sUAS in a manner consistent with how the sUAS will be

operated under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the remote operator must operate the sUAS 

with appropriate distance from nonparticipants.

42. The sUAS may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or 

any law enforcement official upon request.

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

for operating closer to those objects and the remote operator has made a safety

assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard.

44. The remote operator and VO, or essential persons are not considered 

nonparticipating persons under this exemption.