• 

"HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

December 1 7, 2 0 15 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Submission of Request for Authorization to Conduct Unmanned Aircraft 

System Operations Allowed by Section 333 of the FAA Modernizations and 

Reform Act of 2012 Through the Exemption Process Identified Under 14 

C.F.R. Section 11.81. 

Dear Secretary: 

Pursuant to Section 333 of PL 112-95 commonly known as the "FAA Modernization and 

Reform Act of 2012" or "the Reform Act", Heath Consultants Incorporated (Heath) petitions for 

authorization to conduct commercial unmanned aerial system (UAS) operations using a 2015 

InstantEye Mk-2 for the oil and gas production, transportation, and distribution industry within the 

United States National Airspace System (NAS). These operations include, but not limited to, 

Natural Gas Leak Detection, Research and Development, Aerial Surveys, Mapping, and 

Inspections that consist of still photographs, video, and other data obtained by on board sensors. 

The name and address of the applicant is: 

Heath Consultants Incorporated 

Attn: Jim Rutherford, Vice President 

Products Business Unit (PBU) 

9030 Momoe Rd 

Houston, TX 77061 

Phone: 713-844-1300 

j .rutherford@heathus.com 

Heath petitions to be exempt from the following C.F.R.s in accordance with precedent set 

by the following approvals: Exemptions 11062 through 11067, 11080, 11109, 11110 and 11213. 

Heath also requests the secretary determine that good cause exists for not publishing a 

summary of the petition in the Federal Register because the requested exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to the petitioner. 

1 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

" "' HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

The regulations from which the exemption is requested are as follows: 

14 C.F.R. § 61.23(a) and (c), 

14 C.F.R. § 61.101(e)(4) and (5), 61.113 (a) and (b), 61.315(a); 

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.103; 

14 C.F.R. § 91.109(a) 

14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121 

14 C.F.R. § 91.151(a); 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) 

Appendix A discusses each rule listed above and explains why exemptions pursuant to the 

proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the 

public interest. 

Since 1933, Heath has been the leading service provider, manufacturer and distributor for 

a wide range of gas detection, pipe and cable locating and odorant analysis equipment. Heath's 

products and services are designed to meet the midstrean1, upstream and downstream markets. Our 

services include walking and mobile leak surveys, gas leak pinpointing, odor complaint response, 

greenhouse gas emissions programs, underground utility mark-outs/locating, meter reading, meter 

change-out/AMR/AMI and a number of support services. Heath's use ofunrnanned aerial systems 

will result in improved gas leak surveying, which will improve pipeline safety and greenhouse gas 

errusswn. 

Equivalent Level of Safety 

The applicant 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 even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement of operations that would 

be conducted with conventional aircraft. These conditions are drawn from Exemptions 11062 

through 11067, 11080, 11109, and 11110. 

Below are the limitations and conditions to which Heath (or "operator") agrees to be bound 

when conducting commercial operations under an FAA issued exemption: 

l. Operations will be limited to the Unmanned Aerial Systems (UAS) listed below with type, 

weight and airspeeds indicated. All UAS listed have a weight of less than 55 pounds 

including payload, and a maximum airspeed of less than 87 knots (1 00 miles per hour). 

2 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: {713) 844-1300 • Fax: (713) 844-1309 
• 

""HEATH 

ICONSULTANTS 

Heath Consultants Incorporated 

Proposed operations of any other aircraft will require a new petition or a petition to amend 

this exemption. 

a. Overview 2015 InstalltEye Mk-2. 

The InstantEye is a small aerial system that is hand-launched, flown, and handrecovered by one person. The vehicle weighs less than 1.5 lbs. and can cany an 

additional 1 lb. payload. It transitions from a stowed configuration to airborne in 

less than 30 seconds and flies for up to 30 minutes while providing rapid situational 

awareness and sensor operation. 

b. JnstantEye offers exceptional stability, pos1t10n hold, and responsiveness: 

"Manual" mode gives the user total control at speeds up to and limited to 60 mph. 

"Ait" and "GPS" provide capabilities for vertical and horizontal position hold, 

travel to waypoints at speeds up to 30 mph and vertical climb rates of2000 ft./min. 

2. The UAS will not be operated at a speed exceeding 87 knots ( 100 miles per hour). In no 

case will the UAS be operated at airspeeds greater than the maximum UAS operating 

airspeed recommended by the aircraft manufacturer. 

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

(AGL). Altitude will be reported in feet AGL. 

4. The UAS must be operated within visual line of sight (VLOS) of the pilot-in-command 

(PIC) at all times. This requires the PIC to be able to use human vision unaided by any 

device other than conective lenses, as specified on the PIC's FAA-issued airman medical 

certificate or U.S. driver's license. 

5. All operations must utilize a visual observer (VO). The UAS must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 

PIC must be able to communicate verbally at all times; electronic messaging or texting is 

not permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the VO can perform the duties required ofthe VO. 

6. A copy of the FAA approved exemption and all documents needed to operate the UAS and 

conduct its operations in accordance with the conditions and limitations stated in the grant 

of exemption, will be hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations 

3 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

"'"'HEATH (CONSULTANTS 

Heath Consultants Incorporated 

in the FAA approved exemption and the procedures outlined in the operating documents, 

the conditions and limitations in the FAA approved exemption take precedence and must 

be followed . Otherwise, the operator must follow the procedures as outlined in its operating 

documents. 

The operator may update or revise its operating documents. It is the operator's 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension of or an1endment to its FAA 

approved exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted its exemption, then the operator must petition for 

an amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

7. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

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

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

Functional test flights may only be conducted by a PIC with a VO and must remain at least 

500 feet from other people. The functional test flight must be conducted in such a manner 

so as to not pose an undue hazard to persons and property. 

8. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals 

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

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

in a condition for safe flight. 

10. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, 

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

ll. Each UAS operated under this petition will comply with all manufacturer safety bulletins. 

12. The PIC must hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid 

4 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• HEATH (CONSULTANTS 

Heath Consultants Incorporated 

U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal Government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or 

her pilot certificate. 

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under 

this petition for exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51 (b). 

Flights for the purposes of training the operator's PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC's ability to safely operate the UAS in a 

manner consistent with how the UAS will be operated will adhere to the conditions and 

limitations specified within this petition for exemption. Training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UAS with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

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

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

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

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

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

with the airport management must be made available to the Administrator or any law 

enforcement official upon request. 

16. The UAS may not be operated Jess than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

17. If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the private or controlled-access property. 

5 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

• ""HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

18. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

19. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UAS to conduct the intended 

operation and to operate after that for a least 5 minutes or with the reserve power 

recommended by the manufacturer, if greater. 

20. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an A TO-issued COA. 

21 . All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 4 7, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as 

practicable. 

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR § 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents 

must be made available to the Administrator or any law enforcement official upon request. 

23. The UAS must remain clear and give way to all manned aviation operations and activities 

at all times. 

24. The UAS may not be operated by the PIC from any moving device or vehicle. 

25. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UAS and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of the 

UAS, flight operations must cease immediately in a manner ensuring the safety of 

nonparticipating persons; and 

6 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: {713) 844-1300 • Fax: {713) 844-1309 
• 

""

,HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

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

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not present 

an undue hazard. The PIC, VO, operator trainees or essential persons are not 

considered nonparticipating persons under this exemption. 

26. All operations shall be conducted over private or controlled-access property with 

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

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

to be conducted. 

27. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the FAA's UAS Integration Office (AFS-80) with 24 hours. Accidents must be reported to 

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov. 

Unless otherwise specified in this petition for exemption, the UAS, the UAS PIC, and the 

UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91. 

The operation of small UAS, weighing less than fifty pounds, conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein. These lightweight aircraft operate at relatively slow speeds, near the 

ground, and in areas that are under the control of the operator. As a result, they are far safer than 

conventional operations conducted with manned aircraft operation in close proximity to the ground 

and people. 

Sincerely, 

Vice President PBU 

Heath Consultants Incorporated 

7 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

"""HEATH fCONSULTANTS 

Heath Consultants Incorporated 

APPENDIX A 

Regulations- Exemption Requested 

• 14 C.F.R. § 61.23(a) and (c), 

• 14 C.F.R. § 61.101(e)(4) and (5), 61.113 (a) and (b), 61.315(a); 

• 14 C.F.R. § 91.7(a); 

• 14 C.F.R. § 91.1 03; 

• 14C.F.R.§91.109(a) 

• 14C.F.R.§91.119(c); 

• 14 C.F.R. § 91.121 

• 14 C.F.R. § 91.151(a); 

• 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b) 

Pursuant to 14 C.F.R. § 11.81 (e), Heath Consultants Incorporated seeks exemption from 

the below mentioned regulations and provides reason as to why the exemption should be approved 

based on the level of safety at least equal to that of which the rules require. 

• 14 C.F.R. § 61.23(a) and (c); 

~ States: (a) Operations requiring a medical certificate. Except as provided in 

paragraphs (b) and (c) of this section, a person: ... 

and 

(c) Operations requiring either a medical certificate or U.S. driver 's license. 

As set forth within FAA granted Exemptions 11062 through 11067, 11080, 11109, 11110 

and 11213 and others, the minimum requirement to operate a UAS for commercial 

purposes is to hold at least a sport license and a valid driver's license. The granted 

exemptions exempt the UAS PIC from this limitation to his or her license. Heath petitions 

for the same exemption as approved within the previously listed exemptions. 

• 14 C.F.R. § 61.101 (e)(4) and (5), 61.113 (a) & (b), 61.315(a); 

~ 61.101 (e)(4) and (5); 

States: (4) Except as provided in paragraphs (d) and (i) of this section, a 

recreational pilot may not act as pilot in command of an aircrafi-

(4) For compensation or hire; 

(5) In furtherance of a business: 

8 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

)'"" HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

)> 61.113 (a) and (b); 

States: (a) Except as provided in paragraphs (b) through (g) of this section, no 

person who holds a private pilot certificate may act as 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: 

)> 61.315 (a); 

States: (a) If you hold a sport pilot certificate you may act as pilot in command of 

a light-sport aircraft, except as specified in paragraph (c) of this section. 

(c)(2) For compensation or hire; 

(c)(J) In furtherance of a business; 

Under the current limitations of a private, recreational, or sport pilot license, a pilot holding 

a valid private, recreational or sport license cannot operate for compensation or hire or in the 

furtherance of a business. As set forth within FAA granted Exemptions 11062 through 11067, 

11080, 11109,11110 and 11213 and others, the minimum requirement to operate a UAS for 

commercial purposes is to hold at least a sport license and a valid driver's license. The granted 

exemptions exempt the UAS PIC from this limitation to his or her license. Heath petitions for the 

same exemption as approved within the previously listed exemptions. 

• 14 C.F.R. § 91.7(a) 

)> States: No person may operate a civil aircraft unless it is in an airworthy condition. 

Currently, there are no airworthiness certificates for the proposed UAS. Pre- and postflight inspections will be accomplished in accordance with manufacture's maintenance manual(s) 

and guidance. During flight, the PIC will adhere to C.F.R. § 91.7(b) and abort air operations 

immediately upon identification of an in-flight emergency. By applying the prescribed operations, 

inspection and maintenance procedures within the limitations and conditions of Heath's petition 

for exemption, an equivalent level of safety will be achieved. 

• 14 C.F.R. § 91.103 

)> States: Each pilot in command shall, before beginning a .flight, become .familiar 

with all available information concerning that .flight. This information must 

include- (paragraphs a, b, I and 2). 

A pre-flight mission brief will be attended by all crew members. This "PMB" will contain 

weather and all flight information including emergency and abort procedures. A signature will be 

required by all crew members indicating they have received the PMB and have read any NOT AMs 

or other procedural updates which may have impact to standard operating procedures. In addition, 

the PIC will verify the UAS is ready for flight by conducting a pre-flight inspection. 

The exemption requested for the section is specifically addressed toward the requirements 

which do not apply to UAS operations such as runways and air traffic control integration. 

9 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

)',"' HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

• 14 C.F.R. § 91.109(a) 

);> States: 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. 

The majority ofUAS by design are developed with single operational control through the 

use of pre-determined GPS enabled waypoints programmed before or during flight and/or the use 

of a single hand held transmitter or control station controlled by the PIC. This design does not 

allow for dual controls during flight training and therefore the exemption is requested. To assist in 

mitigating this limitation, all training will be conducted through the use of a "buddy box" where 

the PIC/Trainer can regain control of the UAS at any time at their discretion. 

• 14 C.F.R. § 91.119(c) 

);> States: Except ·when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: (c) Over other than congested areas. An 

altitude of500 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. 

Heath operations will normally be conducted at or below 200 feet AGL in accordance with 

automatically issued "blanket" COA (as per the recently announced Section 333 exemption 

streamlining- https://www.faa.gov/news/updates/?newsld=82245) and in primarily Class G and 

E airspace. When operations require a higher ceiling and/or are within Class C and D airspace, 

Heath will submit a request and operate under an approved COA. 

As UAS are inherently safer than traditional aircraft due to their small size, light weight, 

battery operation versus fuel and have no humans on-board; Heath will not operate within 500 feet 

of any vehicles, persons or structures other than those part of the flight operation being conducted. 

In addition, objects and hazards identified and geo-located prior to flight operations will be utilized 

within the flight planning stages to ensure this objective is met. 

• 14 C.F.R. § 91.121 

);> States: Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating ... 

UAS are equipped with Global Positioning System (GPS) which provide altitude and geelocation data to the operator versus utilizing an altimeter. Due to this fact, an exemption is required 

for this system to be utilized in flight. GPS are precise within a few feet vertically and therefore 

meet a safety level equal to if not higher than regulatory guidance. 

As described in the limitations and conditions section ofHeath's petition for exemption; in 

the event the UAS loses GPS signal, automated landing will immediately commence. The flight 

plan is built in such a way that hazards are identified prior to launch and an immediate landing 

within the flight plan will ensure all hazards are avoided. 

10 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

)'",HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

• 14 C.F.R. § 91.151(a) 

>- States: 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: 

This regulation is based on the capabilities of a traditional aircraft which have flight times 

of several hours or greater; therefore, with the majority ofUAS, which have flight times of an hour 

or less, this regulation would effectively deny the ability of the UAS to operate. 

Drawing from previously approved Exemptions the PIC is will not begin a flight unless 

(considering wind and forecast weather conditions) there is enough available power for the UAS 

to conduct the intended operation and to operate after that for at least 5 minutes thereafter or with 

the reserve power recommended by the manufacturer if greater. The ability to quickly and safely 

land UAS in non-traditional environments ensures at least an equal level of safety. 

• 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2) and 91.417(a) & (b) 

~ 91.405(a) States: Each owner or operator of an aircraft-(a) Shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter. 

Ji> 91.407(a)(1) States: (a) No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless-(1) It has 

been approved for return to service by a person authorized under § -13. 7 of this 

chapter. 

);> 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no 

person may operate an aircraft unless, within the preceding 12 calendar months, it 

has had-(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this paragraph 

unless it is performed by a person authorized to perform annual inspections and is 

entered as an "annual" inspection in the required maintenance records. 

);> 91.417(a) & (b) States: (a) Except for work pe1jormed in accordance with §§ 

91.411 and 91.413, each registered owner or operator shall keep the following 

records for the periods specified in paragraph (b) of this section: (paragraphs I (i 

- iii), 2 (i-vi)); (b) The owner or opera/or shall retain the following records for the 

periods prescribed: (paragraphs 1-3). 

11 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
• 

~HEATH ICONSULTANTS 

Heath Consultants Incorporated 

Due to the fact the proposed UAS presently do not have airworthiness certificates, these 

regulations do not apply and therefore an exemption is required. Pre/Post flight and routine 

inspections and maintenance will be conducted in accordance with the manufacturer's guidance as 

stated in the user/maintenance manuals. Heath will maintain logs of pre- and post-flight 

inspections. In the event maintenance is required, the PIC will verify the UAS is in an airworthy 

status prior to operational use. 

All inspection and maintenance will be documented and maintained in-house. These 

actions will meet the intent of the regulation exemption being requested and lead to the equivalent 

level of safety. 

12 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309