- 3 -

Table of Contents

I. Publishable Summary ........................................................................... 5

II. Petitioner’s Contact Information ............................................................... 8

III. Hill Country Aerial LLC's - Operations

 A. The sUAS ................................................................................. 9

 B. Flight Conditions ......................................................................... 9

C. Flight Operations ........................................................................... 10

IV. Privacy ............................................................................................ 10

V. Aircraft and Equivalent Level of Safety ...................................................... 11

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 ......13

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

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

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

 G. 14 C.F.R. 45.25: Location marks on fixed-wing aircraft ...........................15

 H. 14 C.F.R. 45.27: Location 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 ..........................................16

 K. 14 C.F.R. 47.31(c): Application ........................................................16

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

.............................................................................................................................16

 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 .............................................................................. 20

 Q. 14 C.F.R. 91.103: Flight preparation ................................................... 20

 R. 14 C.F.R. 91.103(a)(b)(1)and(2): Preflight procedures and actions ............... 21

 S. 14 C.F.R. 91.105: Flight crewmembers at stations ..................................21
- 4 -

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

tests .........................................................................................22

 U. 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations ...............22

 V. 14 C.F.R. 91.115: Right-of-way rules: Water operations ...........................23

 W. 14 C.F.R. 91.119: Takeoff and Landing ...............................................23

 X. 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General ....................24

 Y. 14 C.F.R. 91.121: Altimeter Settings ..................................................25

 Z. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions ................25

 AA. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications 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 ..................................................................30

 GG. 14 C.F.R. 91.409: Inspections .........................................................30

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

.............................................................................................................................. 31

 II. 14 C.F.R. 91.417: Maintenance records ...............................................32

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

 for aircraft .................................................................................32
- 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 Aerial 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 aerial site reconnaissance for hazardous site and 

environmental conditions is critical to the safety of Power Lineman. Without the use of 

the 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 three 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 life 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 visualization 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 contrast, 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 55lbs., conducted in the strict conditions outlined below, 

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 speeds, 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, buildings, people, and other elevated standing 

structures. 

The intended utilization of the sUAS operations contemplated by this petition is in the 

public interest. It clearly satisfies the exemplary uses of UAS - to replace work by 

humans that is both dangerous and difficult, while 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 multi-rotor 

aircraft based on the DJI Phantom II, weighing less than fifty-five (55) 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 Aerial site inspections.

o Power line surveys and inspections.

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 within a 

range of approximately 25 feet from the utility-power generation line being inspected. Due 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 minimum a two man flight crew with an assistant/spotter. 

The Pilot in Command (PIC) will have substantial training and experience with operating the 

sUASs. 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 protection 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 Aerial 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 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.

These limitations and conditions to which Hill Country Aerial LLC agrees to be bound 

when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 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 

limitation, the majority of flights are anticipated to operate at lower elevations. These 

flights would not exceed 25 feet over the height of the power line towers or poles being 

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

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 uncontrollably 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 applicant’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 Which 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 requests 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 sUASs. The capabilities 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 sUASs, 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 maintenance 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 present 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 fireproof 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 part

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 addressed 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 aircraft 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 provisionally 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 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.

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

will have no entrance to the cabin, cockpit or pilot station on which the word “limited,” 

“restricted,” “light-sport,” “experimental,” 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 LLC 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 subpart (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) Has 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 Aerial 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 applicant 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 Aerial 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 model aircraft, weighs less than 55 lbs. including 

payload, and 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 -

The proposed operations 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 private 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 

Research 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 radio-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 counterproductive)

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 unmanned 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 Command

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 employment 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 sUAS will 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 set 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 exceeds 

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

In addition, there 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 does 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 acquisition 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, dexterity 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 requests 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 flight, 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 approved 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, there 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 where 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 

identified 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 preparation.

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 

familiar 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 

completed, 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, 

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. 
- 21 -

This regulation requires each pilot in command to take certain 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 operations, 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 takeoff 

distances and aircraft performance data before initiation of flight. 

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

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

part provides:

"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 takeoff

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 the 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.

Hill 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 

controls. 

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 size 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 600 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 conducted 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

give 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 of 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 bodies of water.

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

Hill Country Aerial LLC requests an exemption from 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 

undue 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 in 

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 at less 

than the minimums prescribed in paragraph (c) of this section. 

Hill Country Aerial LLC will not operate the sUASs any higher than 400 feet

AGL. Furthermore, while Hill Country Aerial LLC will not be operating over any

congested areas, the sUASs 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 associated with these 
- 24 -

operations is far less than those presently presented with conventional aircraft operating at or 

below 500 AGL. In addition, the low-altitude operations of the sUASs will ensure separation 

between these small-UASs 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 when 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 associated with these 

operations is far less than those presently presented with conventional aircraft operating at or 

below 500 AGL. In addition, the low-altitude operations of the sUASs will ensure separation 

between these small-UASs operations and the operations 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 observe 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 flight 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) there is enough fuel to fly to

the first point of intended landing and, assuming normal cruising speed— (1)

During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after

that for at least 45 minutes

(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 sUASs Hill 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 sUASs will be 

operated in, far less than one mile, will allow the sUASs 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 

sight 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 sUASs 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 powering the 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 

predetermined 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 Corporation 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 will 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 91.151(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 planned 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 exemption 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 effective 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 will 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 Phantom II or similar, which has 

an equivalent level of safety as manned aircraft with an airworthiness certificate. Both the DJI 

A2 and the DJI 2.4 GHz ISM; Intelligent Orientation Control (IOC) flight controller provides a 

number of safety features in addition 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 return to the home position as recorded 

by the GPS instrumentation. 

In the restricted environment and under the conditions proposed, operation of the sUASs

will be at least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness 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 control. 

The sUAS to be operated hereunder is less than 55 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. These 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 is 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 Transponder 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 radar 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 into 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 distances, 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

requirement. 

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, Hill 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 environments 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 that aircraft be inspected as prescribed 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

concerned 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 and 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 subpart.

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

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 maintain and repair the sUAS meets the requirements for an 

equivalent level of safety pursuant to Section 333 for both types of sUASs, its intended use, and 

the operating environment. Additionally, due to the small size 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 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.
- 30 -

FF. 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, 

rebuilding or alteration.

Hill Country Aerial LLC requests an exemption from 14 C.F.R. Part 91.407(a)(1). This

Part provides that:

Any 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 maintain and repair the sUAS

meets the requirements for an equivalent level of safety pursuant to Section 333 for both types of 

sUASs, its intended use, and the operating environment. Additionally, due to the small size of 

the sUASs, 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. 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 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 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 flight, 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 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 part:

That 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 Phantom 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 transport:

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

for 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 flight, 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 exceed 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 certificate. 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) and (b).

Section 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 maintenance, 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 

include—

(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 return 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, and 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 required 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 

directive 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 currently 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 repeated 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 furnished 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 Aerial LLC will

keep detailed maintenance on every part as it is replaced, including but not limited to propellers,

batteries, and electrical components.