April 21, 2015

U. S. Department of Transportation Docket Operations West Building Ground Floor, Room W12
- 140 1200 New Jersey

Ave., SE Washington, DC 20590 **Regarding:** Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from 14 CFR Part 21; 61.113(a) and (b); 91.103; 91.109(c); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2 ); 91.417(a) and (b). Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Reform Act) and 14 CFR Part 11, ReelSkies which is an owner and operator of Small Unmanned Aircraft Sy stems (sUAS) equipped to conduct comme rcial aerial p hotography and videograph y for agricultural i nspection, real estate, and other commercial operations hereb y applies for an exemption from the listed Federal Aviation Regulations (FAR) to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA as required by Section 333. The Reform Act gives the Secretary of Transportation the authority to determine if certain sUAS may

operate safel y in the national airspace s ys tem (NAS) before completion of the FAA’s plan and rulemaking to integrate sUAS into the NAS. The Reform Act directs the Secretary to consider which ty

pes of sUAS as a result of their size, weight, speed, operational capability , proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace or a threat to national security. If the Secretary determines that such vehicles may operate safel y in the NAS, the Secretary “shall establish requirements for the safe operation of such aircraft.” The granting of this exemption request will provide immediate benefit to both the agricultural and real estate industries by authorizing highl y controlled sUAS operations at or below 2 00 feet above ground level (AGL), in line of sight of an FAA Certificated Airline Transport Pilot during daylight hours and above controlled privately owned and operated property. ReelSkies sUAS shall weigh less than 10 pounds including the payload. They will operate at no more than 30 knots and have the capability to hover, and move verticall y and horizontally

simultaneously
. Operations would be conducted above privatel y owned and operated properties, with the consent of the owner/operator. Re elSkies operations will be performed b y a professionalpilot ; this will insure that the sUAS will not create a hazard to users of the national

airspace sy stem or the public. The grant of this exemption request is in the public interest, does not create a hazard to users of the NAS or the public, or pose a threat to national security. In the following pages ReelSkies addresses all areas of concern to include:

 Equivalent levels of safety  Exemptions requested The name and address of the applicant is: **ReelSkies** ATTN : Nick Gruber Phone: ( 402 ) 318
- 8093 Email: nick.j.gruber@gmail.com Address: 5341 West Chanceler Court

Li ncoln, NE 68521 ReelSkies appreciates yo ur consideration in this matter. Best Regards, Nick Gruber President ReelSkies In cluded in this Exemption L ett er :

 Operations  Regulations for which exemptions are requested To follow this Exemption L etter and/or on request:

 ReelSkies Operating Manual  Inspection Program  Aircraf

t Operating Manual (AOM)

### Table of Contents

Operations and How They Serve the Public Interest About ReelSkies ReelSkies sUAS Description Safety Maintenance Permissions and Permitting Operations Flight Time and Flight Durations Exemptions from which Regulations

### Operations **and How They Serve the Public Interest**

**Real Estate Photography by sUAS** 

 SUAS allow aerial video and photograph y of real estate property without the use of full size aircraft.  Use of sUAS in real estate, as well as other sectors, is more efficient, less costly , and environmentall y friendly
.  Utilizing sUAS for real estate is safer than utilizing full
- sca le aircraft which pose a greater risk to people and property  Operations will be conducted below 200 feet AGL, at slow speeds, and within line of sight of a certificated pilot
. **Agricultural Inspection by sUAS**

 SUAS inspection is of higher quality , more relia ble, and can be reviewed in real time. SUAS inspections allow for the collection, dissemination and permanent storage of photos and videos of agricultural inspections.  SUAS inspection is more efficient and less costly
.  SUAS inspection is safer than traditional manned commercial aircraft. SUAS’s are less likel y to cause damage to property or life in the event of an accident. **Inspection of Construction Areas**

 SUAS use at construction sites will provide an aerial view of the area to interested parties such as financier of the project.  Due to the small size of sUAS they pose less risk of damage to people or property when properly

used then full size aircraft.


### About **ReelSk**

**ies President** 

 Nick J. Gruber, a graduate of Embry
- Riddle Aeronautical University, l eads ReelSkies as President. He graduated with a Bachelor ’s in Aeronautics minor in management .  Nick Gruber holds an Airline Transport Pilot (ATP) Certificate along with Certified Flight Instructor (CFI), Instrument (CFII), and Multi
- engine (MEI) certificates. He also holds a Commercial Rotorcraft Helicopter with Instrument certificate. He currently

flies for a Part 121 airline.  Nick has extensive experience in both commercial aviation and radio control airc raft operations including helicopters and multi
- copters.  ReelSkies sUAS are outfitted for aerial photogra phy and videograph y for use in agricultural i nspecti on and real estate industries.**Experience**

As a professional pilot , Nick Gruber understands that safety is paramount and will always hold **s afety**  ah ead of any commercial endeavor.

 Individuals within ReelSkies have onl y operated sUAS as hobbyists. To date, ReelSkies members have not engaged in any commercial activity to ensure it is in compliance with any applicable FARs or local, state, and federal laws.  ReelSkies has a detailed sUAS operating m anual and a ircra ft i nspecti on manual that it shall follow, sho uld this exemption be approved. 

### ReelSk **ies sUAS Description**  ReelSkies intendeds to operate DJ I sUAS multi
- rotor aircraft for the purpose of obtaining photographs and v ideo for agricultural inspection, real estate, and other commercial endeavors
. These aircraft have fail
- safe features to include geo
- fencing and lost link return home capability . DJI

is the manufacturer of multi
- rotors weighing less than 25 pounds and has developed technology

that will enhance safe sUAS operations within the NAS. **T6 00/** **DJI Inspire 1** 

**Model** T600/Inspire 1 **Weight (Battery Included)** 2935g 6.5 pounds **Battery** 22.2V, 4500mAh **Hovering Accuracy Vertical:** 0.5m 1.7 f eet **Horizontal:** 2.5m 8.2 feet **Ma x Angular Velocity Yaw** **/Pitch :**  150 °/s /300°/s **Ma x Tilt Angle**  35° **Ma x Ascent Speed**  5 m/s 11.2 mph **Ma x Descent Speed**  4 m/s 9 mph **Ma x**  **Speed** 22 m/s 49.2 mph **Ma x**  **Flight Time** 18 min **Operating Temperature Range**

- 10° to 40°C **Dimensions** 438x451 x301 mm 17x18 x12 inches Specifications and Design:A. All sUAS flown under this exemption shall be less than 10 pounds including aircraft and payload. This exemption requests permission only with respect to the specific use of the DJ I In spire 1 Model T600 , which weighs less than 10 pounds including payload. B. The radio freq

uency spectrum used for operation and control of the sUAS shall comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. The DJ I Inspire uses spread spectrum technology operating in the 2.4 Ghz range and is compliant with all FCC regulations as demonstrated in the aircraft manual. C. Max imum speed shall be less than 30 knots. D. The sUAS shall be equipped with Inertial Navigation Sensor(s) and Gy roscopes (IRS/IRU/Accelerometer/MEMS Gy roscopes). E. The sUAS shall be equipped with a Compass (Magnetometer/Heading Source). F. The sUAS shall be equipped with a Global Positioning Sy stem (GPS) guidance sy stem. The sUAS shall be designed, should it lose communications or lose its GPS signal, t o return to a pre - determined location within the area of operations and land or be recovered in accordance with Reel Skies sUAS operating m anual. 

### Safety ReelSkies proposes that the exemption requested applies to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or higher level of safety to operations under the current regulatory structure because the proposed operations represent a safet y enhancement to the already safe operations conducted with conventional aircraft. **This Exemption Request is for Use of sUAS subject to Extensive Operational and Safety Requirements**  These limitations and conditions to which ReelSkies agrees to be bound when conducting commercial operations under an FAA issued exemption at a minimum include: A. The sUAS Pilot in Command (PI C) shall possess at a minimum, a private pilot certificate and current third
- class medical certificate.

 The PI C shall also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PI C is rated on their pilot certificate. The PI C shall be trained in the operation of the specific make and model of the sUAS being piloted and success fully completed all training required.  The PI C shall 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 sUAS pilot and at least five hours logged as a sUAS pilot with a similar sUAS ty

pe (multi
- rotor/helicopter /airplane ). Prior documented flight experience that was obtained in compliance with applicable regulations may

satisfy this requirement.  For currency

the PIC shall have accumulated and logged, in a manner consi stent with 14 CFR §61.51 (b), a minimum of five hours as sUAS pilot operating the make and model of sUAS to be utilized for operations und er the exemption and three take offs and three lan dings in the preceding 90 day s. Flight time and number of takeoffs an d landings will be recorded in a logbook for purposes of demonstrating currency
.  Training, proficiency , and experience
- building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. B. During training, proficiency , and experience
- building flights, all persons not essential for flight operations are considered non
- participants, and the PIC must operate the sUAS with appropriate distance from non
- participants in accordance with 14 CFR §91.11 9. C. The PI C shall alway s be within visual line of sight (VLOS) of the sUAS while conducting operations. D. A risk mitigation survey will be conducted prior to each flight to ensure VLOS can be maintained at all times, hazards are properly identified, and that all regulatory

perimeters can be met. 

### Maintenance A. SUAS shall be maintained in accordance with the manufacturer’s recommendations and ReelSkies sUAS o perati ng m anual
. B. ReelSkies will document and maintain a record of the sUAS maintenance, preventative maintenance, alterations, and status of replacement, overhaul component parts, and the total time in service of the sUAS. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. See ReelSkies sUAS o perati ng m anual
. C. ReelSkies shall comply with all manufacturer Safety / Service Bulletins or equivalent pertaining to the sUAS aircraft.D. The PI C s hall perform a preflight inspection of the sUAS, controller, and ground control station prior to each flight to ensure it is ope rational with no discrepancies. The preflight inspection checklist can be found on page 48 of the AOM. If the preflight inspection reveals discrepancies, repairs or maintenance shall be performed prior to flight and logged in the maintenance log . The sUAS will only be operated if all s ys tems are operating per manufacture’s specifications an d in a discrepancy free condition. E. Maintenance or repairs that may affect the sUAS operation or flight characteristics shall undergo a functional test flight when required in accordance with manufactures recommendations and ReelSkies sUAS operating m anual. This functional test fl ight shall be recorded in the sUAS’s records. If the functional test flight is completed successfully , the sUAS can be returned to service b y the PI C.
F. ReelSkies shall follow the manufacturer’s sUAS maintenance, overhaul, replacement, inspection, and life limit requirements. When not provided by the manufacturer aircraft maintenance, component, overhaul, replacement, and inspection maintenance requirements shall be established and included in ReelSkies sUAS o perati ng m anual
.

 At a minimum the foll owing will be meet: 1. Actuators / Servos 2. Powerplant(s) (motors) 3. Propellers 4. Electronic speed controller(s) 5. Batteries 6. Remote controllers and Ground control station 

### Permissions and Permitting A. All required permissions and permits shall be obtained from territorial, state, county or city jurisdictions, including local law enforcement, or other appropriate governmental agencies. B. At least three days before a scheduled operational flight, ReelSkies shall submit a written plan of activities to the local flight standards district office (FSDO) with jurisdiction over the area of the proposed flight. The 3
- day notification may

be waived with the concurrence of the FSDO. The plan of activities shall in clude at least the following:

1. Dates and times for all requested flights 2. Name and phone number of ReelSkies sUAS Flight Operations 3. Name, certificate, phone number of the PIC responsible 4. Make, model, and serial number of sUAS to be used 5. Statement from ReelSkies that it will be operating on approved privatel y owned and operated property; the list of those who gave permission shall be made available to the inspector upon request. 6. Description of the flight activity , including maps or diagr ams of any area over which flights will be conducted, the relationship of that area to any nearb y city , town, etc., and the altitudes essential to accomplish the operation 7. Signature of exemption
- holder or representative C. Documents required per 14 CFR §91.9 and §91.203 shall be readil y available to the PI C an y time the aircraft is in operation. These documents shall be made available to the Administrator or an y l aw enforcement official upon request. D. ReelSkies shall obtain an Air Traffic Organizatio n (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this grant of exemption. E. ReelSkies shall obtain the consent of all persons involved in the operation and ensure that onl y consenting persons be allowed within 500 feet of the Operations Area. 

### Operations A. The sUAS shall not operate within 5 nautical miles of the geographic center of any airport as denoted on the current FAA
- published aeronautical chart unless a letter of agreement with that airp ort’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. This letter of agreement with the airport management shall be made available to the Administrator upon request. B. The sUAS will only operate within the lateral boundaries of approved privately owned and operated property . An Operations Area within those boundaries will be established for each flight. These areas will be free of unnecessary hazards or risks and non
- participating personne l. The sUAS shall only operate within a pre
- defined area of operations that shall be thoroughl y inspected b y the PI C for buildings, overhangs, obstacles, wires, pole s, people, vehicles, shadows, glare, reflective surfaces, clouds, smoke, and terrain among other potential hazards. C. Flights shall be conducted under day visual meteorological conditions (VMC) only
.
 In addition, the sUAS shall not be operated less than 500 feet below or l ess than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PI C.  SUAS operations shall **not** be conducted at night, as defined in 14 CFR §1.1.  Flights shall **not** be conducted under special visual fli ght rules (SVFR). D. Flights shall be operate d at an altitude at or below 200 feet AGL, as indicated by the procedures specified in ReelSkies sUAS operating m anual. E. Ground speeds will not exceed 30 knots as indicated b y the aircraft GPS. F. The PI C shall be prohibited from operating the sUAS from any moving device or vehicle. G. The sUAS shall be operated within VL OS of the PI C.

 The PI C shall maintain VLOS without the aid of telesco pes, cameras or other devices.

 T he PI C will maintain VLOS with their own vision, which includes the use of eyeglasses or corrective lenses as specified on the PI C’s medical certificate. H. The sUAS shall remain clear and yi eld the right of way to manned operations and activities at all times including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc. I. ReelSkies will require the PIC to have successfully completed a qualification process which will include ground and flight training, as outlined in the ReelSkies sUAS Operating Manual. J. The PI C’s primary responsibility

while in flight is the safe operation of the sUAS. 

### Flight Time and Flight DurationsThe PI C will commence the landing sequence when 25% battery life remains. The aircraft will automatically return to base when it triggers a low battery warning. 

### Exemptions from which Regulations Unless otherwise requesting an exe mption, ReelSkies , the PI C, and the sUAS shall comply with all applicable parts of 14 CFR including, but not limite d to, Parts 45, 47, 61, and 91. ReelSkies is requesting exemptions from the following Federal Aviation Regulations to the extent necessary

to enable the requested sUAS operations for the reasons detailed below. **Relief sought from 14 CFR ReelSkies**  **Statement** 21 Stated Below 61.113(a) and (b) Stated Below 91.103 Stated Below 91.119(c) Stated Below 91.121 Stated Below 91.151(a)(1) Stated Below 91.405(a) Stated Below 91.407(a)(1) Stated Below 91.409(a)(1) and (2) Stated Below 91.417(a) and (b) Stated Below

**14 CFR 21**

**– Requirements to Secure Airworthiness Certificates**  1. Certificate exemptions should be given because size, weight, and operation areas of the sUAS meet the level of safety necessary for exemption under Section 333 of the Reform Act. 2. FAA has the authority to exempt aircraft from airworthiness certificate requirements under the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act.**14 CFR 61.113 (a) and (b)**

**– Private Pilot Privileges and Limitations; P**  **ilot in**

**Command** 1. Due to the fact that there are no standards for private or commercial sUAS operations, ReelSkies requests to utilize at least private pilots with a third class medical in support of its own operations. 2. Knowledge of flight characteristics and the Federal Aviation Regulations (FARs), along with the ability

to phy sicall y manipulate the controls of the sUAS are the critical aspects of the requested operation. ReelSkies feels this can be accomplished b y a private pilot that has specific traini ng on the sUAS aircraft and operates in accordance with the ReelSkies sUAS Operating Manual, Federal Aviation Regulations, local, state and federal laws. 3. The risks associated with the operation of a sUAS are so diminished from the level of risk associate d with commercial aviation operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PI C exceeds the present level of safet y achieved b y 14 C.F.R. §61.113 (a) & (b). 4. Equivalent or better safety levels will be achieved as there will be no human bei ngs on board the sUAS aircraft. In addition, people will not be allowed in the area of operation. 5. FAA has authority

to waive pilot requirements for commercial operations under 49 U.S.C §44701(f).

**14 CFR 91.103**

**– Preflight Action**  1. The PI C shall perform a preflight inspection in accordance with the manufacturer’s recommendations and the ReelSkies sUAS Operating Manual of the controller, ground control station and associat ed equipment prior to each flight to ensure it is free of all discrepancies. 2. Equivalent safety levels will be met through preparation and compliance according to ReelSkies ’s sUAS Operating Manual; including but not limited to, weather reports, forecasts, wind, temperature, battery requirements and other information, relating to aircraft performance, gross weight, shall be considered. **14 CFR 91.119(c)**

**– Requirements for Minimum Safe Altitudes for Civil Aircraft**  **Operation** 1. The sUA S will be operated at or below 2 00 feet AGL
.2. ReelSkies shall obtain the consent of all persons involved in the operation and ensure that only consenting persons be allowed within 500 feet of the Operations Area. 3. The sUAS will only

operate within the lateral boundaries of appro ved privately owned and operated property . An Operations Area within those boundaries will be established for each flight. These areas will be free of unnecessary hazards or risks and non
- participating personnel. 4. Given the size, weight, speed, material, and operation of the sUAS aircraft, equivalent levels of safety

will be achieved. **14 CFR 91.121**

**– Altimeter Settings**  1. SUAS will not have a barometric altimeter, and may use a GPS altitude read out indication instead, so an exemption may be needed. 2. Th e operator will achieve an equivalent level of safety as the sUAS uses AGLheight from its initialization/takeoff point. **14 CFR 91.151 (a) (1)**

**– Fuel Requirements for Flights in VFR Conditions**  1. The FAA has previously issued exemptions for fuel requirements in VFR conditions including Exemptions 2689F, 5745, 10673, and 10808. 2. ReelSkies feels an equivalent level of safety can be obtained b y terminating the flight prior to the following. **Aircraft Fuel (Battery) Requirements** DJIInspire
- 18 m inutes which allows for 5 minutes reserve. 1. The DJ I Inspire has a second level of safety that is achieved through the use of an aircraft battery

monitoring s ys tem. The aircraft s ystem will alert the operator of low battery

voltage and return the aircraft to its take off location before battery capacity is depleted. 2. ReelSkies will not operate sUAS at night in accordance with 14 CFR 1.1 3. An equivalent level of safety will be achieved because these sUAS are limited in size, operational purposes of the sUAS, and shall only fly above approved privately owned and operate d property at or below 2 00 feet AGL, it does not bear the same risks associated with this section’s requirements. **14 CFR 91.405 (a)**

**– Maintenance Required**  This section and Part 43 apply onl y to aircraft with an airworthiness certificate; therefore these sections will not apply
.In the absence of regulatory provisions dealing with sUAS operation for maintenance required. See ReelSkies sUAS Operating Manual, Inspection Program and Manufactures Ma intenance Recommendations for maintenance required. 1. Maintenance shall be accomplished by ReelSkies , pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program. 2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y train ed personnel onl y . 3. The ReelSkies sUAS Operating Manual and Inspection Program details how to enter worked preformed in the maintenance log for scheduled, unscheduled maintenance or func tional test flights that are performed. 4. ReelSkies shall only

operate its sUAS with all sy stems functioning per manufactures specification in a discrepancy free condition. 5. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. This maintenance process allows for an equivalent level of safety to be achieved due to the limited size, scope and area of operations. **14 CFR 91.407 (a) (1)**

**– Operation after Maintenance, Preventive Maintenance,**  **Rebuilding or Alteration** This section and Part 43 apply onl y to aircraft with an airworthiness certificate; therefore these sections will not apply
. In the absence of regulatory provisions dealing with sUAS operation after maintenance, preventive maintenance, rebuilding, alteration or functional test flights, ReelSkies has develo ped requirements to address these topics. See ReelSkies sUAS Operating Manual, Inspection Program and Manufactures User Guides. 1. Maintenance will be accomplished by ReelSkies pursuant to the manu facturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program. 2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y trained personnel onl y. 3. Functional test flights will be performed b y the PIC when required, the sUAS sha ll only be returned to service when this functional test flight is successfull y completed. If a mechanical issue arises the sUAS can land safel y or be recoveredwithin the Operations Area.

4. The ReelSkies sUAS Operating Manual details how to enter in the m aintenance log scheduled and unscheduled maintenance or functional test flights that are performed. 5. ReelSkies shall only

operate its sUAS with all sy stems functioning per manufactures specification in a discrepancy free condition. 6. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition. These maintenance procedures allow for an equivalent level of safety to be achieved due to the limited size, scope and area of operations. **14 CFR 91.409 (a) (1) and (2)**

**– Inspections**  This section and Part 43 apply onl y to aircr aft with an airworthiness certificate; therefore these sections will not apply
. In the absence of regulatory provisions dealing with sUAS inspections, ReelSkies has developed requirements to address this topic. See ReelSkies sUAS Operating Manual, Inspect ion Program and the Manufactures User Guides. 1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual and Inspection Program. 2. Maintenance, preventive maintenance, rebuilding, and alteration will be successfully accomplished b y trained personnel onl y. 3. The ReelSkies sUAS Operating Manual details how to enter into the maintenance log all inspections that are performed. 4. Functional test flight will be performed b y the PIC when requi red after inspections, the sUAS shall be returned to service when the flight is successfull y completed. If a mechanical issue arises the sUAS can land safel y or be recovered within the Operations Area. 5. ReelSkies shall only

operate its sUAS with all sy ste ms functioning per manufactures specification in a discrepancy free condition. 6. These records will be maintained at the principle base for operation for the life of the aircraft or as required b y Federal Aviation Regulations. ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft andbest suited to maintain the aircraft in an airworth y condition. These maintenance

inspections allow for an equivalent level of safety to be achieved due to the limited size, scope and area of o perations. **14 CFR 91.417(a) and (b)**

**– Maintenance Records**  This section and Part 43 apply only to aircraft with an airworthiness certificate; therefore these sections will not apply
. In the absence of regulatory provisions dealing with sUAS maintenance re cords, ReelSkies has developed requirements to address this topic. See ReelSkies sUAS Operating Manual and Inspection Program. 1. Maintenance will be accomplished by ReelSkies pursuant to the manufacturer’s recommendations and ReelSkies sUAS Operating Manual. 2. Maintenance, preventive maintenance, rebuilding, and alteration maintenance recording keeping will be performed b y trained personnel and entered in the respective aircraft maintenance log at completion of each event. The ReelSkies sUAS Operating Manual details how entries are to be made in the aircraft maintenance log for scheduled and unscheduled maintenance or functional test flights that are performed. 3. These records will be maintained at the principle base for operation for the life of the ai rcraft or as required b y Federal Aviation Regulations. ReelSkies and the Aircraft Manufacturer (DJ I) are the most familiar with the aircraft and best suited to maintain the aircraft in an airworth y condition. These maintenance records allow for an equiva lent level of safety to be achieved due to the limited size, scope and area of operations.