June 23, 2015

Exemption No. 11778A

Regulatory Docket No. FAA–2015–0591

Mr. Jacob Rachniowski

Managing Partner

Cloud9Drones LLC

2606 Wilson Street 802

Austin, TX 78704

Dear Mr. Rachniowski:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated March 5, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Cloud9Drones LLC (hereinafter petitioner or operator) for an exemption. The 

exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct aerial inspections of towers/tall structures for multiple industries, and videography

for film and marketing.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined 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.

Airworthiness Certification

The UAS proposed by the petitioner are the C9D-BD (Butterfly Dragon), DJI‐S1000+, DJI

Inspire 1, DJI Phantom 3, 3DR Solo, and 3DR Iris+.
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In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Cloud9Drones LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Cloud9Drones LLC is hereafter referred to as the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the C9D-BD (Butterfly 

Dragon), DJI‐S1000+, DJI Inspire 1, DJI Phantom 3, 3DR Solo, and a 3DR Iris+ when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

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

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA 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 of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are 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 in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 
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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 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this 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.

8. 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.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a 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 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.

14. 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 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 
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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 

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

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

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA 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.

17. The UA may not be operated less 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

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

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

power recommended by the manufacturer if greater.

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

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. 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 UA 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 UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

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.

27. 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.

28. 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) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

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

parts 45, 47, 61, and 91.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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May	13,	2015

U.S.	Department	of	Transportation

Docket	Management	Facility

West	Building	Ground	Floor

Room	W12-140

1200	New	Jersey	Avenue,	S.E.

Washington,	D.C.	20590

Re:	Cloud9Drones	Section	333	Exemption	Amendment (Docket	#	FAA-2015-0591-0001)

Dear	Sir/Madam,

Cloud9Drones	LLC	is	writing	to	amend	our	Section	333	exemption	request,	posted	March	10th,	

2015,	with	the	intention	of	clarifying	certain	requests	and	to	add	additional	aircraft. This	

document	will	give	an	overview	of	the	amendments	we	would	like	to	make	and will follow	with	

the	specific	comments,	new	additions	and	associated	pages	effected.

Amendment	Overview:

1) ‘C9D-BD	(Butterfly	Dragon)	– custom	UAS’	is	a	Gryphon	Dynamics	X8

Although	C9D specified	that	the	C9D-BD	is	a	custom	UAS,	it	is	in fact	an	airframe	that	has	

previously	been	exempt	by	the	FAA	for	other	companies	(Exemption	No.	11158):	a	Gryphon	

Dynamics	X8.	The	supporting	documentation	specifies	the	exact	components	of	this	UAS. It	is	

not	a	‘custom’	UAS,	it only	has	a	few	custom	parts non-critical to	flight,	i.e. camera	isolation

system,	battery	mounts	and	weatherproof	top	cover	for	the	flight	electronics.

2) Videography	and	film	is	NOT	for	closed-set	filming	operations

We	are	not	requesting	an	exemption	to	do	closed-set	filming.	We	understand	that closed-set	

filming	requires	additional	manuals,	which	we	have	not	submitted. Our	videography	will	be	

limited	to	real-estate,	marketing	videos	and	non-closed	set	film	operations.
2

3) All	operations	will	be	restricted	to	below	400ft

Cloud9Drones	requested operations	up	to	the	height	listed	in	the	NPRM:	500ft.	We	also	

requested	to	operate	in	some	cases	above	500ft.	Since	such	requests	will	warrant	further	

review	by	the	FAA,	C9D	would	like	to	reduce	those	requests	to	a	maximum	altitude	of	400ft,	as	

permitted	by	other	exempt	companies.

4)	Pilots	will	require	a	sports	license	and	valid	US	driver’s license

Cloud9Drones	specified	that	commercial	pilots	with	third	class	medicals	would	perform	

operations.	This	was	due	to	a	request	to	operate above	400ft,	which	could	require a	pilot	with	

more	experience.	In	light	of	the	recent	exemptions	requiring	a	sports	license	and	a	valid	US	

driver’s license,	C9D would	like	to	reduce	its pilot qualifications	from	commercial	pilot	license	

with	a	third	class medical	to	at	least	a	sport	pilot’s	certificate	or	higher	rating with	a	valid	US	

driver’s	license.

Thus,	Cloud9Drones	will	now	require	an	exemption	from	14	C.F.R.	§	61.113	(a)	&	(b):	Private	

Pilot	Privileges	and	Limitations:	Pilot	in	Command.

Additional Aircraft

Additionally,	C9D	would	like	to	add	the	following	aircraft	to	it’s	fleet	of	UAS’.

• DJI	Phantom	3

• 3D	Robotics	Solo

The	manuals	have	been	submitted	separately	to	the	333	Exemptions	office.

The	name and	address	of	the	applicant	is:	

Cloud9Drones LLC

Attn:	 Jacob	Rachniowski	 - Managing	Partner

Ph:		512-567-7351	

Email:	 Jacob@cloud9drones.com	

Address: 2606	Wilson	St.	#	802,	Austin,	TX,	

78704

Taylor	Davis

Ph:		405-406-7730

Email:	 Taylor@cloud9drones.com	

Email:	 Jacob@cloud9drones.com	
3

Amendment	Details:

1) ‘C9D-BD	(Butterfly	Dragon)	– custom	UAS’	is	a	Gryphon	Dynamics	X8

Document	Name:	‘C9D	Request	for	Exemption’

Page:	3

Original	Text:

C9D intends to operate the following aircraft:

1. C9D-BD (Butterfly Dragon) – custom UAS

New	Text:

C9D intends to operate the following aircraft:

1. C9D-BD (Butterfly Dragon) – Gryphon Dynamics X8

2) Videography	and	film	is	NOT	for	closed-set	filming	operations

Document	Name:	‘C9D	Request	for	Exemption’

Page: 1

Original Text:

Equipped to conduct aerial inspections of towers/tall structures for multiple industries, and 

videography for film and marketing,

New Text:

Equipped to conduct aerial inspections of towers/tall structures for multiple industries, and 

videography for film (with the exception of closed-sets) and marketing,

Document	Name:	‘C9D	Request	for	Exemption’

Page: 4

Original	Text:

C9D also intends to provide aerial videography for the film and marketing industries

New	Text:

C9D also intends to provide aerial videography for the film (with the exception of closed-sets)

and marketing industries

Document	Name:	‘C9D	Request	for	Exemption’

Page: 13

Original	Text:

To allow commercial operation for inspection of towers/tall structures and videography for film 
4

and marketing purposes,

New	Text:

To allow commercial operation for inspection of towers/tall structures and videography for film

(with the exception of closed-sets) and marketing purposes,

Document	Name:	‘Intended	Operations	and	Public	Interest

Page: 4

Original Text:

• Aerial	videography	for	film	or	marketing purposes

New Text:

• Aerial	videography	for	film	(with the exception of closed-sets) or	marketing	purposes

3)	All	operations	will	be	restricted	to	below	400ft

Document	Name:	‘C9D	Request	for	Exemption’

Page: 3

Original Text:

at	an	altitude	of	no	more	than 500	feet

New Text:

at	an	altitude	of	no	more	than	400 feet

Document	Name:	‘C9D	Request	for	Exemption’

Page: 10

Original Text:

Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	Flights	

will	be	operated	above	500	ft for	inspections	of	structures	that	have	FAA	lighting.	In	these	less	

common	operating	situations,	the	UAS	will	not	be	operated	over	10ft	above	the	height	of	the	

FAA	marked	tower,	nor	will	the	UAS	operate	over	a	50ft	radius	from	the	center	of	the	marked	

structure.

New Text:

Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	Flights	

will	be	operated	above	500	ft	for	inspections	of	structures	that	have	FAA	lighting.	In	these	less	

common	operating	situations,	the	UAS	will not	be	operated	over	10ft	above	the	height	of	the	

FAA	marked	tower,	nor	will	the	UAS	operate	over	a	50ft	radius	from	the	center	of	the	marked	

structure.
5

Document	Name:	’Operating	Manual’

Page: 3

Original Text:

Aircraft	shall	remain	under	500ft	AGL,	or	no more	than	10ft	above	a	FAA	marked	structure	

under	inspection	and	no	more	than	80ft	horizontal	distance	away	from	the	tower.	Specific	

details	are	specified	in	the	‘Intended	Operations	and	Public	Interest	Manual.’

New Text:

Aircraft	shall	remain	under	400ft AGL,	or	no	more	than	10ft	above	a	FAA	marked	structure	

under	inspection	and	no	more	than	80ft	horizontal	distance	away	from	the	tower. Specific	

details	are	specified	in	the	‘Intended	Operations	and	Public	Interest	Manual.’

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 4

Original Text:

Altitude	limited	below	500ft	AGL	in	all	cases	with	the	exception	of	inspections	of	towers	above	

500ft	marked	with	FAA	lighting.	In	these	cases	operations	will	be	limited	to	10ft	above	the	

marked	tower	and	no	more	than	80ft	horizontal	distance	from	the	tower.

New Text:

Altitude	limited	below	400ft	AGL	in	all	cases with	the	exception	of	inspections	of	towers	above	

500ft	marked	with	FAA	lighting.	In	these	cases	operations	will	be	limited	to	10ft	above	the	

marked	tower	and	no	more	than	80ft	horizontal	distance	from	the	tower.

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 4

Remove “Reasoning	for	Higher	Altitude	Operations	for	Tower	Inspection”	Section

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 5

Original Text:

C9D	UAS	operations	will	not	exceed	10ft	vertical	distance	and	not	exceed	80ft	horizontal	

distance	from	the	marked	structure.

New Text:

C9D	UAS	operations	will	not	exceed	10ft	vertical	distance	and	not	exceed	80ft	horizontal	

distance	from	the	marked	structure.		C9D	UAS	operations	will	not	exceed	at	an	altitude	of	no	

more	than	400 feet AGL.
6

Document	Name:	‘C9D	Intended	Operations	and	Public	Interest’

Page: 14

Original Text:

By	permitting	C9D	to	operate	above	500ft	and	no	higher	than	10ft	AGL	of	the	tower	under	

inspection,

New Text:

By	permitting	C9D	to	operate	up	to	400ft	AGL above	500ft	and	no	higher	than	10ft	AGL	of	the	

tower	under	inspection,

4)	Pilots	will	require	a	sports	license	and	valid	US	driver’s	license

Document	Name:	‘C9D	Request	for	Exemption’

Page: 1

Original Text:

The	UAS	PIC	will	be	an	FAA	licensed	airman	with	a	commercial	pilot’s	certificate	and	third	class	

medical

New Text:

The	UAS	PIC	will	be	an	FAA	licensed	airman	with	at	least	a sport	pilot’s	certificate	or	higher	

rating and	valid	US	driver’s	license

No	Exemption	Necessary:

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

C9D	will	require	that	UAS	pilots	have	a	commercial	pilots	license	and	a	third	class	medical.	In	

addition	to	these	requirements,	the	PIC	will	have	to	complete	UAS	training	as	specified	in	the	

C9D	Operator	Qualifications	and	Training	Manual.

New Text:

Exemption	Requested	From:

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.	

C9D	will	require	that	UAS	pilots	have	at	least	a	sport	pilot’s	certificate	or	higher	rating and	a	

valid	US	driver’s	license.	In	addition	to	these	requirements,	the	PIC	will	have	to	complete	UAS	

training	as	specified	in	the	C9D	Operator	Qualifications	and	Training	Manual.

Document	Name:	‘C9D	Request	for	Exemption’

Page: 10

Original Text:
7

The	Pilot	In	Command	(PIC)	must	possess	a	commercial	pilot	certificate	and	at	least	a	current

third-class	medical	certificate.	

New Text:

The	Pilot	In	Command	(PIC)	must	possess	at	least	a	sport	pilot’s	certificate	or	higher	rating and	

at	least	a	valid	US	driver’s	license.

Document	Name:	‘C9D	Operator	Qualifications	and	Training	Manual’

Page: 3

Original Text:

• Hold	at	least	a	Private	Pilot	License

• Maintain	at	least	a	3rd Class	Medical

New Text:

• Hold at	least	a	sport	pilot’s	certificate	or	higher	rating

• Hold	a	valid	US	driver’s	license