- 3

- 

### Table of **Contents**

I. Publishable Summary ........................................................................... 5
II. Petitioner’s Contact I nforma tion ............................................................... 8

III. Hill Country Aerial LLC's

- Operations
A. The sUAS ................................................................................. 9 B. Flight Con ditions ..................................................................... .... 9

C. Flight Operations .........

............ ...................................................... 10

IV . Privacy .......................................................................................... .. 10 V. Aircraft and Equivalent Level of Safety ...................................................

... 1 1 VI. Public Interest and Safety ..................................................................... . 12 VII. Regulations from which Exemption is Requested .......................................... 13 A. 14 C.F.R. 21(h): Airworthiness Certificates ....................................... . 13

B. 14 C.F .R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration ................................. 13

C. 14 C. F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts 91

, 125

, 135.411(a)(1) and 135.419 of this chapter

... ...1 3 D. 14 C.F.R. 45.11: Marking of products ................................................. 1 4

E. 14 C.F. R. 45.21: General ............................................................... ..1 4 F. 14 C.F.R. 45.23: Display of marks; general ....................................... ...1 4

G. 14 C.F.R. 45.25: Location marks on fixed

- wing aircraft ........................ ...1 5

H. 14 C.F.R. 45.27: L ocation of marks; non

- fixed

- wing aircraft ..................

... 15
I. 14 C.F.R. 45.29: Size of marks ......................................................... 15

J

. 14 C.F.R. 47.3(b)(2): Registration required ....................................... ...1 6

K . 14 C.F.R. 47.31(c) : Application ................................................... .....1 6

L . 14 C.F.R. 61.113: Private Pilot Privileges and Limitations: Pilot in Command

.

..................................................................................................................... ........ 1 6

M . 14 C.F.R. 61.113(a) and (b): Private Pilot Certificate and Act as Pilot in
Command ...........................................................................

...... 18

N . 14 C.F.R. 91.7(a): Civil aircraft airworthiness ....................................

... 19

O . 14 C. F.R. 91.9(b)(2): Civil aircraft flight manual, markings, and placard requirements ........................................................................

...... 19 P. 14 C.F.R. 91.9(c): Civil aircraft flight manual, markings, and placard requirements ..................................................................

............ 2 0 Q . 14 C.F.R. 91.103: Fl ight preparation .............................................

... ... 2 0

R . 14 C.F.R. 91.103(a)(b)(1)and(2): Prefl ight procedures and actions .........

... ... 2 1

S . 14 C.F.R. 91. 105: Flight crewmembers at stations .............................. ....2 1- 4

- T . 14 C.F.R. 91.109: Flight instruction: Simulated instrument flight and certain flight

tests ........................................................................................ .2 2

U . 14 C.F.R. 91.113(b): Right

- of

- way rules: Except water operations ............

... 2 2

V . 14 C.F.R. 91.115: Right

- of

- way rules: Water operations ........................... 2 3

W . 14 C.F.R. 91. 119: Takeoff and Landing ............................................. ..2 3

X . 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General ............... .....2 4

Y . 14 C.F.R. 91.121: Altimeter Settings ................................................ ..2 5

Z . 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions ............... .2 5

AA . 14 C.F.R. 91. 203(a) and (b): Civil aircraft: Certification s required ............

... 26

BB . 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment
and Use ................................................................................. ...28

CC . 14 C.F.R. 91.403: General .............................................................

. 28

DD . 14 C.F.R. 91.405(a) and (b): Maintenance Required ..............................

.. 29

EE . 14 C.F.R. 91. 407: Operation after maintenance, preventive maintenance, rebuilding or alteration ...............................................................

... 29

FF . 14 C.F.R. 91.407(a)( 1): Operation after maintenance, preventive maintenance, rebuilding or alteration .................................................................. 3 0

GG . 14 C.F.R. 91.409: Inspections ...................................................... ...3 0

HH . 14 C.F.R. 91.409(a)(2): aircraft issuance of airworthin ess certificate inspection

............................................................................................................................. . 3 1

II . 14 C.F.R. 91.417: Maintenance records .............................................. .3 2

J J . 14 C.F.R. 91.417(a) and (b): Owner/Operator records of maintenance
for aircraft .............................................................................. ...3 2- 5

- **I. Publishable Summary**

Pursuant to 14 C.F.R. Part 11 and Part 21, the following summary is provided for

publication in the Federal Register, should it be determined that publication is needed:
Applicant seeks an Exemption from the following Rules:

14 C.F.R. 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.21; 14 C.F.R. 45.23; 14 C. F.R. 45.23(b); 14 C.F.R. 45.25; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 47.3(b)(2); 14 C.F.R. 47.31(c); 14 C.F.R. 61.113; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.115; 14 C.F.R. 91.119; 14 C.F.R. 91.119(b)(c); 14 C.F.R. 19.121; 14 C.F.R. 91.151; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 19.405( a) and (b); 14 C.F.R. 91.407; 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409; 14 C.F.R. 91.409(a)(2) and 14 C.F.R 91.417; 14 C.F.R. 91.417(a) and (b) to operate commercially a small unmanned aircraft system (sUAS) (15lbs or less).

Approval of exemption for Hill Country Aerial, LLC will allow commercial operations of
sUASs in the

o A erial site inspections.

o Power line surveys and inspections.

Power line work is extremely dangerous providing emergency services for the public safety and well

- being. Having aer ial site reconnaissance for hazardous site and environmental conditions is critical to the safety of Power Lineman. Without the use of
th e sUAS, current procedures require waiting until flood waters recede, causing extensive delays to power restoration and the general public safety and well

- being

.- 6

- Texas Floods

- May 2015

- Site Reconnaissance Blanco River Crossing, Wimberley Texas- 7

- Current operations for utility company inspections involve having a crew of 4 or 5
technicians with two or thr ee persons spending hours prepping, mounting

, and then
either climbing electrical towers or utilizing aerial lifts to inspect for damage and worn
out material at each tower location . These inspectors are not only working under dangerous conditions , but they may indeed be involve in l ife threatening scenarios.

Moreover, another current practice of utility company inspection operations involve the use of a helicopter with 3 or 4 persons flying at very low altitude trying to achieve an
aerial visuali zation of damaged and worn out tower structure and electrical wiring. This is extremely dangerous for all involved including surrounding structures and high power
electrical lines

, with the risk of property damage , human injury or worst death.

In contra st, a sUAS weighing less than 55lb, which is powered by batteries

, eliminates virtually all of the risk for property damage, human injury, or death. The operation of small UASs, weighing less than 5 5lbs., conducted in the strict conditions outlined be low

, will provide an equivalent level of safety supporting the grant of the Exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations.- 8

- These lightweight aircraft operate at slow spe eds, close to ground, and in a low risk, low to moderate population environment and, as a result, are far safer than conventional operations conducted with helicopters

, moving vehicles , or fixed

- wing aircraft operating in close proximity to the ground, bui ldings, people, and other elevated standing

structures.

The intended utilization of the sUAS operations contemplated by this pet ition is in the public interest. It clearly satisfies the exemplary uses of UAS

- to replace work by
humans that is both d a ngerous and d ifficult, w hile simultaneously providing a greater level of safety.

Finally, the petitioner requests Exemption from the requirement of the PIC possessing a private or commercial pilot’s license. Research studies cited by petitioner, sponsored by the FAA and Army Research Laboratory, demonstrate that UAS, even those much larger than the sUASs proposed by Hill County Aerial , can be safely flown by pilots with a small amount of training

.

**II. Petitioner’s Contact Information**

Hill Country Aerial
Michael C. Bitzko 3966 Deep River San Antonio, TX 78253

210 437

- 2556; mbitzko@twc.com- 9

- **III. Hill Country Aerial**  **LLC’s Operations**

**A. The sUASs**

The requested Exemption will permit the operation of small, unmanned mult i

- rotor
aircraft based on the DJI Phanto m II, weigh ing less than f ifty

- five (5 5) pounds (inclusive of batteries and technical payload). These rotorcrafts operate at speeds of no more than thirty (30) knots, and have the capability to hover and move in the vertical and horizontal planes simultaneously. The sUASs will have the following specifications or equivalent:

Airframe: DJI Phantom II Control System (s) : 2.4 GHz ISM; Intelligent Orientation Control (IOC) ; A2

Tx: 5.8G SWR<1.5 ; Futaba 14 SG

Rx: 5.8G SWR<1.5 ; Internal in A2

Motors: Tiger (MN2214

- KV920 Anti

- Gravity Series) ; DJI 4114 Propellers: Tiger RC 9” (9443) Carbon Fiber ; Tiger RC 15” Carbon Fiber
Batteries: 11.1 V, 5200 mAh 3 S lithium

- polymer (LiPo) ; Glacier from RC Buddy 6000mA 6

- cell with EC5 main power connection

.

**B. Flight Conditions**

The sUASs will be used for :

o A erial site inspections.

o Power line surveys and i nspections.

Hill Country Aerial LLC proposes Exemption under Section 333 to operate commercially
and to provide the intended inspections, the sUAS will normally need to be operated w ithin a range of approximately 25 feet from the utility

- power generation line being inspected. D ue to the nature of the proposed operations, the PIC and the designated spotter may at times be less than 500 feet away from structures during the operation, and an exemption is therefore required. Flights will be operated at an altitude of no more than 400 feet AGL.- 10

- **C. Flight Operations**

Every sUAS flight will use at minimu m a two man flight crew with a n assistant/ spotter

. The Pilot in Command ( PIC) will have substantial training and expe rience with operating the

sU ASs

. The standard pre

- flight and operational procedure will be as follows:

1. At the utility company and community municipality sites, the flight crew will wait
for approval from the utility company personnel and security

. 2. The crew will put on personal prot ection equipment

. 3. The crew then performs a pre flight check per the PFC and reviews any additional safety concerns within the pre

- determined air space.

**IV. Privacy** 

There is little concern that the proposed flights will cause invasions of privacy because all flights will occur over controlled power company right of ways and easements . Hill County Aerial will be notified by the Power Utility Company of any restricted areas not to be inspected. The Power Utility Companies for whom Hill County Aeri al will contract, will have obtained any required property owner’s prior consent and knowledge.- 11

- **V. Aircraft and Equivalent Level of Safety** 

Hill Country Aerial LLC proposes that the exemption requested herein apply to
civil aircraft that h ave 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.

These limitations and conditions to which Hil l Country Aerial LLC agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 5 5 lbs.

2. Flights will be operated within line of sight of a pilot and observer.

3. Maximum total flight time for each operational flight will be 3 hours . Flights will be

terminated at 20% battery power reserve should that occur prior to the 3 hour limit.

4. Flights will be operated not to exceed at an altitude 400 feet AGL. Despite this

li mitation, the majority of flights are anticipat ed to operate at lower elevations . These
flights would not exceed 2 5 feet over the height of the power line towers or poles being

inspected , and would under no circumstance exceed the 400 feet AGL restrictio n.

5. Minimum crew for each operation will consist of the sUAS pilot and the visual observer.

6. A briefing will be conducted in regard (s) to the planned sUAS operations prior to each
day’s activities. It will be mandatory that all personnel who will be performing duties in

connection with the operations be present for this briefing.

7 . Pilot and observer will at all times be able to communicate by voice.

8 . The sUAS will have the capability to abort a flight in case of unexpected obstacles or
emergencies.

9

. If the multi

- rotor and its controller disconnects during flight, the system’s failsafe

protection will come to the rescue and the multi

- rotor will return to home and land

automatically, rather than flying off uncontroll ably or landing at an unknown location.

The proceeding conditions to which Hill Country Aerial LLC agrees to be bound will satisfy the criteria providing adequate justification for the grant of the requested exemptions allowing commercial operation of ap plicant’s sUAS in the utility company power line inspection
industries.- 12

- **VI. Public Interest and Safety** 

By flying the sUASs over utility company’s high towers and electric wires, rather than putting pilots in helicopters flying at low altitude and people in a vehicle with a mounted camera extension, or having utility company climbers scale electrical towers to inspection equipment and material, the hazards stemming from these extreme conditions will be removed.- 13

- **VII. Regulations from Whi ch Exemption is Requested** 

**A. 14 C.F.R. 21(h): Airworthiness Certificates**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 21(h). This exemption meets the requirements for an equivalent level of safety pursuant to Section 333 based

on the small size, light weight, relatively slow speed, and use in controlled environments on private land, as described previously in this petition.

**B. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines,**  **propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.** 

Hill Country Aerial LLC r equests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, that the holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return

to service.

The nature of the sUAS is that of a model aircraft and the operator (s) of Hill Country
Aerial LLC who will maintain and when necessary will seek certified and licensed repair personnel. The operator ( s ) will conduct inspections and maintenance based on maintenance guidelines provided by the manufacturer of the sUAS s

. The capab ilities of these operator ( s ) to maintain and repair the sUAS will meet the requirements for an equivalent level of safety
pursuant to Section 333 for the type of sUAS s , its intended use, and the operating environment.

**C. 14 C.F.R. 43.11: Content,**  **form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 43.11. This part provides, inter alia, that mainten ance record entries be maintained and for the listing of discrepancies and placards by inspectors.

The sUAS, due to its small size, does not have room for placards to be placed in or on it and no inspections for sUAS have been certified by FAA at the pre sent time. However, as a condition to the approval of exemption, Hill Country Aerial LLC is willing to keep log books of all maintenance and repairs.- 14

- **D. 14 C.F.R. 45.11: Marking of products.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an approved fireproof identification plate.

The sUAS, due to its small size, does not have room for fi reproof placards to be placed in it. Any required placards could become hazardous, due to the additional weight and strain placed
on the sUAS.

**E. 14 C.F.R. 45.21: General.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 45.21. This p art provides, inter alia, that except as provided in §45.22, no person may operate a U.S.

- registered aircraft unless that aircraft displays nationality and registration marks in accordance with the requirements of this section and §§45.23 through 45.33.

There are no current procedures for obtaining a registration mark for sUASs by the FAA. However, as a condition to the approval of exemption, Hill Country Aerial LLC is willing to be assigned a registration number and to display it where practicable as ad dressed in this petition relative to Parts 23, 27, and 29, below.

**F. 14 C.F.R. 45.23: Display of marks; general.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that each operator of an aircraf t must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Moreover, limited, restricted or light

- sport category aircraft or experimental or pr ovisionally certificated aircraft, the operator must also display on that aircraft
near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more
than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.

The sUAS, due to its small size, does not have room to display aircraft marks in a conventional size. However, as a condition to the approval of exemption, Hill Country Aerial- 15

- LLC is willing to affix an ai rcraft mark to one or more of the "arms" of the sUAS. The size of the marking will be determined by the size of the "arm" being used and may be less than 1 inch in
size.

A partial exemption from this display regulation §45.29(f) may be needed as the UAS

w ill have no entrance to the cabin, cockpit or pilot station on which the word “limited,” “restricted,” “light

- sport,” “exp erimental,” or “provisional,” is applicable. Given the size of the sUAS, two

- inch lettering will be impossible.

**G. 14 C.F.**  **R. 45.25: Location of marks on fixed**

**- wing aircraft** 

The sUAS is a multi

- rotor model aircraft and is not fixed

- wing. Therefore, 14 C.F.R.

45.25 is inapplicable.

**H. 14 C.F.R. 45.27: Location of marks; non**  **fixed**

**- wing aircraft** 

Hill Country Aerial LL C requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. The sUAS,
due to its small size, does not have a cabin, fuselage, boom or tail to display the marks required by §45.23.

**I. 14 C.F.R. 45.29: Size of marks** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, at s ubpart (3) that the registration marks for rotorcraft must be at least 12
inches high.

The sUAS, due to its small size, does not have any surface area large enough to display
marks anywhere near 12 inches high. However, as a condition to the approval of exemption, Hill Country Aerial LLC is willing to affix an aircraft mark to one or more of the "arms" of the sUAS. The size of the marking will be determined by the size of the "arm" being used and may
be less than 1 inch in size.- 16

- **J. 14 C.F.R. 47**  **.3(b)(2): Registration required**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 47.3(b)(2). This part provides "(b) No person may operate an aircraft that is eligible for registration under 49

U.S.C. 44101

- 44104, unless the aircraft

— (1) H as been registered by its owner; [or] (2) Is carrying aboard the temporary authorization required by §47.31(c)."

There are no current procedures for obtaining a registration mark for sUASs by the FAA. However, as a condition to the approval of exemption, Hill Country Aerial LLC is willing to be assigned a registration number provided by FAA and to display it where practicable as addressed in this petition relative to Parts 23, 27, and 29, above.

**K. 14 C.F.R. 47.31(c): Application** 

Hill Country Ae rial LLC requests an exemption from 14 C.F.R.47.31 (c). This part provides "(c) After compliance with paragraph (a) of this section, the applicant for registration of an aircraft last previously registered in the United States must carry the second copy of the Aircraft Registration Application in the aircraft as temporary authority to operate
without registration."

Because FAA currently has no process for registering sUAS, it is impossible to comply with Part 47.31(a), which states, inter alia: "(a) Each a pplicant for a Certificate of Aircraft Registration, AC Form 8050

- 3 must submit the following to the Registry: (1) An Aircraft Registration Application, AC Form 8050

- 1, signed by the applicant in the manner prescribed by §47.13; (2) The original Aircraft Bill of Sale, AC Form 8050

- 2, or other evidence of ownership authorized by §47.33, §47.35, or §47.37 (unless already recorded at the Registry).”

**L. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: Pilot in Command.** 

Hill Country Aeri al LLC requests an exemption from 14 C.F.R. 61.113. The PIC (pilot in command) of the sUAS does not possess either a private or commercial license. However, because (i) the sUAS is essentially a mo del aircraft, weighs less than 5 5 lbs. including payload, a nd will not carry any pilot or passengers, (ii) the area of operation is controlled and restricted, (iii) all flights will be planned and coordinated in advance, and (iv) the maximum
altitude of the sUAS will not exceed 400 feet AGL.- 17

- T he proposed opera tions will achieve the equivalent level of safety of current operations by manned aircraft with a private or commercial pilot ’ s license. The level of safety provided by Hill Country Aerial LLC meets or exceeds that provided by an individual possessing a pr ivate or commercial pilot's license operating a manned aircraft.

Stated another way, the skill set needed to successfully and safely operate the UAS is

very different from the set of skills needed by a pilot of manned aircraft. Both FAA and Army

Researc h Laboratory research demonstrate that UAS, even those much larger than the sUAS proposed by Hill Country Aerial LLC , can be safely flown by non

- certificated pilots with a small amount of training.

**"[T]he specific motor skills needed to control the radi o** 
**- controlled UAV would**  **have to be learned by aviators independently of the motor skills learned in flying an aircraft. In particular, the somatic and visual cues that pilots use**  **during aircraft landings would not be useful (and perhaps even counterproducti ve)**  **for the different skill sets and perceptual viewpoint necessary for**

**radio**

**- controlled landings."** 

**-----------------------------------** Michael J. Barnes, Beverly G. Knapp, Barry W.Tillman, Brett A. Walters & Darlene Veliki, Crew systems analysis of unm anned aerial vehicle (UAV) future job and tasking

environments , Technical Report ARLTR

- 2081, Aberdeen Proving Ground, MD: Army Research Laboratory, page 12 (2000).- 18

- **M. 14 C.F.R. 61.113(a) and (b): Private Pilot Certificate and Act as Pilot in Co**  **mmand**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 61.113 (a) and (b)

. Section 61.113(a) and (b) prescribes that (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employme nt if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or
hire.

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations

**.**

Because the s UAS w ill not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance as se t forth in the Manual. The level of safety provided by Hill Country Aerial LLC meets or exceeds the requirements included in the Manual exceeds that provided by a single individual holding a commercial pilot’s certificate operating a
conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exce eds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

In addition, t here are no standards for either Private or Commercial sUAS pilot certificates. The safe operation and control of the UAS as described in the Exemption Applications doe s not depend on the type of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, the key factors needed by the PIC are knowledge of the airspace within which the power line inspections will take place and how that airspace fits into the National Airspace System (NAS). That knowledge can be and is gained primarily through training and experience, and not through flight training in fixed wing or rotor aircraft, nor is it dependent on the acquisitio n of a commercial or private pilot’s certificate. Those certificates demonstrate knowledge of the factors and skills needed for the safe operation of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or ability to safely operate a small unmanned aerial vehicle, operating at 400 AGL or lower, within strictly controlled pre

-- 19

- approved airspace. Besides knowledge of airspace regulations, dexter ity in the control and operation of the sUAS acquired from actual operation of the aircraft is the most important factor in establishing an equivalent level of safety.

**N. 14 C.F.R. 91.7(a): Civil aircraft airworthiness.** 

Hill Country Aerial LLC r equests an exemption from 14 C.F.R. 91.7(a). The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft should this exemption be granted, no standard will exist for determining airworthiness. Given the size and weight of the aircraft and the requirements contained in Hill Country Aerial LLC ‘s rules of operations, described above, for maintenance and use of safety check lists prior to each fli ght, an equivalent level of safety will be provided.

**O. 14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking, and placard**  **requirements.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.9(b)(2). This part provides: "(b) No person may operate a U.S.

- registered civil aircraft...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current appro ved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof."

First, there does not currently exist a method of approving manuals for sUAS. Second, given the size and configuration of the sUAS, t here is no space to carry such a flight manual on the aircraft. In addition, carrying the manual on the aircraft would be void

.

The equivalent and greater level of safety will be maintained by keeping the flight manual at the ground control point wher e the pilot flying the sUAS will have immediate access to it. The FAA has issued the following similar exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.- 20

- **P. 14 C.F.R.**  **91.9(c): Civil aircraft flight manual, marking, and placard requirements.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person may operate a U.S.

- registered civil aircraft unless that aircraft is
identif ied in accordance with part 45 of this chapter."

As stated above, there is no current registration process for sUAS; and the sUAS, due to its small size, does not have room to contain fireproof placard or to display aircraft marks in a
conventional size. However, as a condition to the approval of exemption, Hill Country Aerial

LLC is willing to affix an aircraft mark to one or more of the "arms" of the sUAS. The size of the marking will be determined by the size of the "arm" being used and may be less than 1 inch in
size.

**Q 14 C.F.R. 91.103: Flight p**  **reparation.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91. 103

. Section 91.103 prescribes, in pertinent part, that each pilot in command shall, before beginning a flight, become
fami liar with all available information concerning that flight, to include :

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be

com pleted, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section,
oth er reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.- 21

- This regulation requires each pilot in command to take ce rtain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided by Hill Country Aerial LLC ‘s rules of o perations, described above, for maintenance and use of safety check lists prior to each flight, which will allow for an equivalent level of public safety . The PIC will take all actions including reviewing weather, flight battery requirements, landing and t akeoff distances and aircraft performance data before initiation of flight.

**R**

**. 14 C.F.R. 91.103**  **(a) (b)**  **(1) and (2): Preflight**  **procedures and a ction.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.103 (a) (b) (1) (2). This part provi des:

"Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— ... (b) For any flight, runway lengths at airports of intended use, and the following takeof f and landing distance information: ... (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature."

The Hill Country Aerial LLC pilot in command in fact will, before beginning a flight, become familiar with all available information concerning that flight. However, as the flights of th e sUAS will not be at airports the information required of Part 91.103(b)(2) does not apply. However, as a condition to the approval of exemption, Hill Country Aerial LLC shall perform preflight operations as outlined previously in this Petition.

**S. 14 C.F.R. 91.105: Flight crewmembers at stations.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.105 since this part is not applicable due to the sUAS carrying no flight crewmembers. However, to achieve an equivalent level of safety, Hill Country Aerial LLC will not operate the aircraft unless
someone is at the controls at all times with an assigned PIC and designated observer

.- 22

- **T. 14 C.F.R. 91.109: Flight instruction; Simulated instrument flight and certain flight** 

**tests.**

Hi ll Country Aerial LLC requests an exemption from 14 C.F.R. 91.109.

This part 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

con trols.

Remotely piloted aircraft, including the sUAS here, are designed and constructed without dual controls. Flight control will be accomplished through the use of a control box that
communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety is provided by the very limited siz e and speed of the aircraft and by the fact that neither a pilot nor passengers will be carried in the aircraft.

**U. 14 C.F.R. 91.113(b): Right** 

**- of** 

**- way rules: Except water operations.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 113 (b) to the extent that it applies to overhead aircraft operating at or above 6 00 feet AGL as the sUAS will be operating no higher than 400 feet AGL. This part provides:

“(b): General. When weather conditions permit, regardless of whether an operation
is c onducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right

- of

- way, the pilot shall gi ve way to that aircraft and may not pass over, under, or ahead of it unless well
clear."

For example, if another aircraft is operating overhead at 10,000 feet AGL there is no danger posed to that other aircraft if the sUAS is operating under it or ahead o f it at or beneath
400 feet AGL. However, as a condition to the approval of exemption, Hill Country Aerial LLC will operate its sUAS to see and avoid and give way to other aircraft that should enter airspace at
or below 400 feet AGL.- 23

- **V**

**. 14 C.F.R.**  **91.115: Right**

**- of** 

**- way rules: water operations.** 

This Part does not apply as Hill Country Aerial LLC does not plan on operations on or over bo dies of water

.

**W. 14 C.F.R. 91.119: Takeoff and Landing.** 

Hill Country Aerial LLC requests an exemption fr om 14 C.F.R. 91.119. Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without

un due hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel , vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

—

(1) A helicopter may be operated at less than the minimums prescribed i n paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated a t less than the minimums prescribed in paragraph (c) of this section.

Hill Country Aerial LLC will not operate the sUAS s any higher than 400 feet AGL. Furthermore, while Hill Country Aerial LLC will not be operating over any congested areas, the sUAS s wi ll necessarily be flown closer to 500 feet to the structures it will be examining

.

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated wi th these- 24

- operations is far less than those presently presented with conventional aircraft operating at or
bel ow 500 AGL . In addition, the low

- altitude operations of the sUAS s will ensure separation
between these small

- UAS s operations and the operations of conventional aircraft that must comply with Section 91.119.

**X . 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General.** 

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.119 subparts (b) and (c). This regulation provides:

"Except w hen necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:...

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.”

Hill Country Aerial LLC will not operate the sUAS any higher than 400 feet AGL. Furthermore, while Hill Country Aerial LLC will not be operating over any congested areas, the sUAS will necessarily be flown closer to 500 feet to the structures it will be examining

.

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associ ated with these operations is far less than those presently presented with conventional aircraft operating at or
bel ow 500 AGL . In addition, the low

- altitude operations of the sUAS s will ensure separation
between these small

- UAS s operations and the operati ons of conventional aircraft that must comply with Section 91.119.- 25

- **Y**

**. 14 C.F.R. 91.121: Altimeter Settings** 

**.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for altimeter use below 18,000 feet mean sea level (“MSL”) in maintaining the cruising altitude or flight level of the aircraft.

Hill Country Aerial LLC's operation of the sUAS will not exceed 400 feet AGL and will be operated in a fashion that is not a sustained cruising flight such as a manned aircraft will typically fly. The control device used in the ground station has live feedback information about the sUAS, including but not limited to the height of the sUAS, its forward velocity, and compass heading. The operator will be able to ob serve and control the maximum height of the sUAS. Additionally, the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety provided by Section 91.121 will be met.

**Z**

**. 14 C.F.R. 91.151: Fuel requirements for fligh**  **t in VFR conditions.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. Part 91.151. This Part provides that:

“(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) ther e 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

(b) No person may begin a flight in a rotorcraft 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, to fly after
that for at least 20 minutes.”

The sUAS s H ill Country Aerial LLC will fly is electric, using lithium polymer batteries that currently have a flight limit of approximately no more than 26 minutes. Therefore, due to the limitations of the batteries it is currently impossible to comply with Part 91. 151. However, the sUAS will be operated in a manner with at least the same equivalent of safety as that of a manned aircraft complying with Part 91.151 because the short distances the sUAS s will be operated in, far less than one mile, will allow the sUAS s to be flown to a safe landing point within the area of operation within a short period of time and well within the minimum level of reserve capacity of the batteries.- 26

- During the entire preprogrammed flight, the operator will always have a visual line of

s ight and be prepared to take over. Pilot’s radio transmitter ("Tx") has a flight count down timer
which is set to a minimum of 20% battery reserve defined as allowing an additional 3 minutes of flight time

- more than enough to safely fly the sUAS s back to “home” area. This operation procedure adequately complies with ASTM standard F3005 − 14 4.3.1 (Standard Specification
for Batteries for Use in Small Unmanned Aircraft Systems (sUAS)). The timer begins from the point the throttle is moved out of its start position.

The battery poweri ng th e sUAS provides approximately 26 minutes of powered flight. As a result, the sUAS would never meet the 30 minute reserve requirement. Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a predete rmined area, a longer time frame for flight in daylight VFR conditions is reasonable.

Hill Country Aerial LLC believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corp oration to
operate without compliance with Section 91.151 (a)). Given the limited size and speed of the sUAS, its ability to land safely almost anywhere, that it will be under the operator and the
observer’s visual observation at all times, and that it wil l be operating in a tightly controlled area, where all people, other than the operator and the observer, will be removed before flight, permitting its operation with less than 30 minutes of reserve fuel does not engender the type of
risks that Section 91.1 51(a) was intended to alleviate.

Hill Country Aerial LLC believes that an equivalent level of safety can be achieved by limiting flights to when 20% of battery power remains. This restriction would be more than adequate to allow the sUAS to reach its p lanned landing zone. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

**AA**

**. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required.** 

Hill Country Aerial LLC requests an exempti on from 14 C.F.R. 91.203(a) and (b). This section provides in part:

“(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate...

(2) An effe ctive U.S. registration certificate issued to its owner...- 27

- (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 at the cabin or cockpit entrance so that it is legible to passengers or crew.”

First, there are currently no procedures by the FAA for providing airworthiness
certificates for sUAS. However, as a condition to the approval of exemption, Hill Country Aerial

LLC wi ll display on the sUAS a registration certificate or equivalent that is issued by FAA pursuant to this petition at the ground point control, where the operator will have immediate

access to them.

Second, the sUAS Hill Country Aerial LLC will use the Phant om II or similar, which has an equivalent level of safety as manned aircraft with an airworthiness certificate. Both t he DJI

A2 and the DJI 2.4 GHz ISM; Intelligent Orientation Control (IOC) flight controller provides a number of safety features in additi on to acting as the command and control Rx bound to the Futaba brand Tx, including automatic return to home if the radio control link is broken, referred
to as a failsafe.

Because of the use of GPS with the sUAS, the operator will set the initial location of flight takeoff ("home position") and if the radio control link is broken, both the DJI A2 and the DJI 2.4 GHz ISM; Intelligent Orientation Control (IOC) flight controller will recognize this broken control link and cause the sUAS to automatically retur n to the home position as recorded by the GPS instrumentation.

In the restricted environment and under the conditions proposed, operation of the sUAS s will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an
airwor thiness certificate without the restrictions and conditions proposed. Hill Country Aerial

LLC will not accept assignments from clients who are within 5 miles of controlled airspace without first gaining written and/or oral permission from air traffic contr ol.

The sUAS to be o perated hereunder is less than 5 5 pounds inclusive of batteries and technical payload, carries neither a pilot nor passengers, and carries no explosive materials or flammable liquid fuels. The sUASs operating under this exemption will be tightly controlled and monitored by the operator and the observer, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation. The FAA will have advance notice of all operations. Th ese safety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under Subpart H. Lastly, application of these same criteria demonstrates that- 28

- there i s no credible threat to national security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial payload.

**BB. 14 C.F.R. 91.215: ATC Tr**  **ansponder and Altitude Reporting Equipment and Use**

**.**

This section requires that installed Air Traffic Control (ATC) transponder equipment

must meet specific performance and environmental requirements, and aircraft must be equipped
with an operable coded ra dar beacon transponder.

There are presently no known commercially available ATC transponders that meet the payload requirements of a sUAS and are available at reasonable cost. However, because the

sUASs used by Hill Country Aerial LLC will not be flying i nto or near airports, and will fly no higher than 400 feet AGL, there is very low risk of collision with any manned aircraft. In addition, because there will be no need to have contemporaneous communication with Air Traffic Control, due to the short distan ces, short flight times, and restricted altitude the sUASs will operate within, Hill Country Aerial LLC requests an exemption from this section. Additionally, the sUAS is too small to contain ATC transponder equipment in any form factor
that is known to be available commercially.

**CC**

**. 14 C.F.R. 91.403: General** 

**.**

This section requires that the owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition. Hill Country Aerial LLC will adhere to this

req uirement.

However, this Section also limits maintenance to that “prescribed in this subpart and other applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of the exemptions under Part 43 requested above, Hil l Country Aerial LLC requests an exemption from this Section.

This exemption meets the requirements for an equivalent level of safety pursuant to
Section 333 based on the small size, light weight, relatively slow speed, and use in controlled
rural environ ments on private, secured land, as described previously in this petition.- 29

- **DD**

**. 14 C.F.R. 91.405 (a) and (d): Maintenance Required** 

**.**

This section requires t hat aircraft be inspected as pre scribed by Section E, 14 C.F.R. §§91.401

- 91.421. As shown below, Hill Country Aerial LLC is applying for an exemption for
these sections, due to the fact that its operators will inspect the sUAS prior to each flight and keep maintenance records of all parts that are replaced. Because the Sections discussed below are

con cerned with manned aircraft, and as such have inspection requirements designed for the safety of passengers, they are inapplicable to Hill Country Aerial LLC

.

Hill Country Aerial LLC is also applying for an exemption to subpart (d) of this section, which requires a placard to be installed and references §43.11. As noted previously, Hill Country Aerial LLC requests an exemption to the placard requirement, because, due to the small size of the sUAS, there is no room to place the placard. As an alternative a nd to achieve an equivalent level of safety, Hill Country Aerial LLC will keep logbooks detailing all repairs.

Despite the requested exemption from subparts (a) and (d) of this section, Hill Country
Aerial LLC will follow subparts (b) and (c) of this subp art.

**EE. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding,** 

**or alteration**

**.**

This section requires that any aircraft which “has undergone maintenance, preventative
maintenanc e, rebuilding, or alteration unless . . . [i]t has been approved for return to service by a person authorized under § 43.7 of this chapter . . ..”

However, Hill Country Aerial LLC has requested an exemption from §§ 43.7 and 43.11 as described previously

.

The capability of the operators to maintain and repair the sUAS meets the requirements for an equivalent level of safety pursuant to Section 333 for both type s of sUAS s , its intended use, and the operating environment. Additionally, due to the small si ze of the sUAS, there is no room to place inspection placards.

Therefore, because Hill Country Aerial LLC has requested an exemption from 43.7 and 43.11, Hill Country Aerial LLC respectfully requests an exemption from 91.407. To achieve an equivalent leve l of safety, Hill Country Aerial LLC will regularly inspect and maintain its sUASs in accordance with the DJI operator manual, and keep detailed inspection records as described
above.- 30

- **FF. 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive m aintenance,**  **rebuilding or alteration**

**.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. Part 91. 407(a)(1) . This Part provides that:

A ny aircraft which “has undergone maintenance, preventative maintenance, rebuilding,
or alteration unless . . . [i]t has been approved for return to service by a person authorized under § 43.7 of this chapter . . ..”

However, Hill Country Aerial LLC has requested an exemption from §§ 43.7 and 43.11 as described previously. The capability of the operators to mai ntain and repair the sUAS meets the requirements for an equivalent level of safety pursuant to Section 333 for both type s of

sUAS s , its intended use, and the operating environment. Additionally, due to the small size of
the sUAS s , there is no room to place inspection placards.

Therefore, because Hill Country Aerial LLC has requested an exemption from 43.7 and 43.11, Hill Country Aerial LLC respectfully requests an exemption from 91.407. To achieve an equivalent level of safety, Hill Country Aerial LLC will regularly inspect and maintain its sUASs in accordance with the DJI operator manual, and keep detailed inspection records as described
above.

**GG**

**. 14 C.F.R. 91.409: Inspections** 

**.**

This section lays out the requirements for inspections of aircraft. Hil l Country Aerial

LLC respectfully requests an exemption from these requirements because they are intended to maintain the safety of manned aircraft significantly larger and capable of significantly longer flights than the Phantom II and the DJI S800.

Hill Country Aerial LLC does have an inspection procedure. Prior to each flight, the operator will conduct an inspection of the sUAS. The steps of this pre

- flight inspection
include: a). Check the following proponents for damage during transport: Airframe; Connections; and Propellers. b) Calibrate the camera. c) Verify voltage and settings for main flight Tx and the gimbal Tx. d) Measure voltage battery.- 31

- e) Cycle through different control modes of the Flight Tx observing LED lights for good conn ection and response. f) Cycle through all controls of the Gimbal Tx making sure the gimbal and camera respond to commands. g) Activate engine power without moving throttle up to check that the automatic
throttle kill works.

After each flight, Hill Co untry Aerial LLC will conduct the following post

- flight inspection:

a) Blow sUAS with compressed air to remove dirt and dust. b) Wipe down sUAS with a cloth to remove dirt and dust.

The pre

- flight and post

- flight inspections meet or exceed the level of safety achieved by
adherence to 14 C.F.R. 91.409

.

**HH. 14 C.F.R. 91.409(a)(2): aircraft issuance of airworthiness certificate inspection** 

**.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.203(a) and (b). This section provides in par t:

T hat no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

This section lays out the requirements for inspections of aircraft.

Hill Country Aerial LLC respectfully requests an exemption from these requirements because they are intended to maintain the safety of manned aircraft significantly larger and capable of significantly longer flights than the Phan tom II

.

Hill Country Aerial LLC does have an inspection procedure. Prior to each flight, the operator will conduct an inspection of the sUAS. The steps of this pre

- flight inspection
include: a). Check the following proponents for damage during transpor t: Airframe; Connections; and Propellers. b) Calibrate the camera.- 32

- c) Verify voltage and settings for main flight Tx and the gimbal Tx. d) Measure voltage battery. e) Cycle through different control modes of the Flight Tx observing LED lights

f or good connection and response. f) Cycle through all controls of the Gimbal Tx making sure the gimbal and camera respond to commands. g) Activate engine power without moving throttle up to check that the automatic
throttle kill works.

After each fli ght, Hill Country Aerial LLC will conduct the following post

- flight inspection:

a) Blow sUAS with compressed air to remove dirt and dust. b) Wipe down sUAS with a cloth to remove dirt and dust.

The pre

- flight and post

- flight inspections meet or excee d the level of safety achieved by
adherence to 14 C.F.R. 91.409

.

**II . 14 C.F.R. 91.417: Maintenance records** 

**.**

Hill Country Aerial LLC respectfully requests an exemption from this Section, as it is only applicable for aircraft with an airworthiness certi ficate. Because Hill Country Aerial

LLC will not have an airworthiness certificate, this Section is inapplicable. As an alternative and to achieve an equivalent level of safety, Hill Country Aerial LLC will keep detailed maintenance on every part as it is replaced, including but not limited to propellers, batteries, and electrical components.

**JJ. 14 C.F.R. 91.417(a) and (b): Owner/Operator records of maintenance for aircraft**

**.**

Hill Country Aerial LLC requests an exemption from 14 C.F.R. 91.417(a) an d (b)

. S ection 91.417(a) and (b) prescribes, in pertinent part, that :

(a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintena nce, and alteration and
records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each- 33

- engine, propeller, rotor, and appliance of an aircraft. The records must

i nclude

—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft
for re turn to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and
each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller,
rotor, a nd appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection re quired by the inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety
directi ve number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major
alteration to the airframe and curre ntly installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repea ted or superseded by other work or for 1 year after the work is performed.- 34

- (2) The records specified in paragraph (a)(2) of this section shall be retained and
transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnish ed to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for
return to service.

Hill Country Aerial LLC respectfully requests an exemption from this Section,
as it is only applicable for aircraft with an airworthiness certificate. Because Hill Country Aerial

LLC will not have an airworthiness certificate, this Section is not applicable. As an alternative and to achieve an equivalent level of safety, Hill Country Aeria l LLC will keep detailed maintenance on every part as it is replaced, including but not limited to propellers, batteries, and electrical components.