U.S. Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Regulatory Docket No. _______________
Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Submitted on
Michael A Billquist 6320 Theden St. Shawnee, KS 66218 913
- 764
-0123 Mab629@gmail.com

### TABLE OF CONTENTS

**GLO SSARY OF ABBREVIATIONS** 
................................ ................................ ................................ .................... 3 **INTRODUCTION AND OVERVIEW**
................................ ................................ ................................ ................. 4 **CHARACTERISTICS OF THE UAS**
................................ ................................ ................................ .................... 5 **UAS OPERATOR REQUIREMENTS**
................................ ................................ ................................ ................. 6 **UAS OPERATING PARAMETERS**
................................ ................................ ................................ ................... 7 **APPLICATIONS AND PUBLIC INTEREST**
................................ ................................ ................................ ......... 9 **SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER**
................................ ............................ 11 **CONCLUSIONS**
................................ ................................ ................................ ................................ ............ 11 **APPENDIX A: REGULATIONS REQUIRING EXEMPTION**
................................ ................................ .............. 12

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System MPH Miles Per Hour NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SVFR Special Visual Flight Rules UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VO Visual Observer

### INTRODUCTION AND OVERVIEW

Dear Madam/Sir,
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Michael A Billquist, seeks an exemption from the Federal Aviation Regulations listed below:

 14 C.F.R. 21, subpart H

 14 C.F.R. 61.3

 14 C.F.R. 61.113(a)&(b)

 14 C.F.R. 61.133(a)

 14 C.F.R. 91.9(b)(2)

 14 C.F.R. 91.103(b)

 14 C.F.R. 91.105

 14 C.F. R. 91.109(a)

 14 C.F.R. 91.119

 14 C.F.R. 91.121

 14 C.F.R. 91.151(a)

 14 C.F.R. 91.203(a) & (b)

 14 C.F.R. 91.319(a)(1)

 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) The requested exemption would authorize Michael A Billquist to conduct commercial operations using the DJI Phantom 3 Professional and DJI Phantom 2 (UAS) for forensic engineering and fire investigation applications. These applications would primarily consi st of roofing inspections, structural inspections, and fire scene documentation. As well as aerial video photography of real estate, special events, wedding cinematography and emergency disaster response. I currently hold a FAA private pilot’s license, re maining current, and have interests in amateur radio, flying and videography. I am currently involved in Emergency Preparedness teams. The UAS’s will be operated only by myself who holds the FAA issued private pilot license.

### CHARACTERISTICS OF THE UAS

The DJI Phantom 3 P rofessional and DJI Phantom 2 are all very similar UAS. One exception is that the Phantom 3 P rofessional includes an integrated camera, while a third party camera can be affixed to the Phantom 2. The Phantom 3 Professional and Phantom 2 has a diagonal motor

-to
- motor distance of approximately 14 inches. Both UA are constructed primarily of frangible materials (plastic) and weigh less than 3 pounds each. The Phantom 2 is powered by a 5200 mAh 3S LiPo battery. The Phantom 3 Professional is powered by a 4480 mAh 4S LiPo battery. The max flight speed of the Phantom 2 is approximately 34 mph, while the max flight speed of the Phantom 3 Professional is approximately 36 mph. All three UA contain an on

- board GPS and an inertial measurement unit for flight stabilization and automatic failsafe return to home in case of a lost control signal. Additionally, these UAS offer geo

-fencing and max altitude features to restrict the maximum vertical and horizontal distance the aircraft will fly from its home p oint. The Phantom 3 Professional offer the added feature of displaying real time flight data, including battery status, altitude and distance from home, within the DJI App. Each UA operated by Michael A Billquist for commercial use will be registered in ac cordance with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart C, in a size as large as practical for the size of the UA. All UAS operated by Michael A Billquist will be maintained in accordance with the manufacture’s ma intenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertinent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the UAS’s m aintenance log. Maintenance log entries will include the date, UAS ID number, registration number, current UAS flight time, a description of work performed, and the name of the individual who completed the work. Any UAS that has undergone maintenance or al terations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight, prior to use in any commercial operations. The functional test flight must be conducted in such a man ner so as to not pose an undue hazard to persons and property. The PIC who conducts the functional test flight must make an entry in the aircraft records. A pre

-flight inspection of the UAS will be completed by the PIC prior to each flight operation. If th e 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. Michael A Billquist’ s UAS will comply with all applicable manufacturer safety bulletins. Additional information on the aircraft specifications, performance limitations, operating procedures, and pre

-flight inspections is contained in the attached documents. The safety and reliabili ty of the DJI Phantom 2 and Phantom 3 Professional UAS is further supported by the fact that numerous FAA exemptions have previously been approved for their use in commercial operations.

### UAS OPERATOR REQUIREMENTS

Relief from certain requirements of Se ction 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Michael A Billquist to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an a irman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 and DJI Phantom 3 Professional UASs in a manner consistent with this exemption, includi ng evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Michael A Billquist, acting as PIC of a UAS, will be identified prior to any flight and will not change once the flight has begun. The P IC is the individual in operational control of the flight operation from beginning to end and is responsible for safe flight of the UA. All PIC flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR § 61.51(b).

### UAS OPERATING PARAMETERS

In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all Michael A Billquist commercial UAS operations will be conducted in accordance with the following specific operating limitations:

 The UA may not be operated at a speed exceeding 30 knots (34 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

 All operations shall be conducted in accordance with an ATO

- issued COA.

 All UA operations will occur at or below 500 ft AGL or the maximum altitude specified in the COA limitations, unless the purpose of the flight is to inspect a building or structure which is taller than 500 ft. If the purpose of the flight is to inspect a building or structure which is taller than 500 ft then the max altitude of the UA will be restricted to 20 ft above the highest point of that building or structure. All altitudes mu st be reported in feet AGL.

 No UA will be operated within 3 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 den oted 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 Michael A Billquist. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

 No UA will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling ATC office is obtained or the flight is otherwise permitted by a COA i ssued to Michael A Billquist. The letter of agreement from ATC must be made available to the Administrator or any law enforcement official upon request.

 The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires th e 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.

 A grant of exemption must be accessible during UAS operations and made ava ilable to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the grant of exemption, the conditions and limitations in the grant of exemption take precedence and must be followed
.
 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.

 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.

 Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition fo r safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited fromoperating until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. All mai ntenance and alterations must be properly documented in the aircraft records.

 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. The PIC who conducts the functional test flight must make an entry in the aircraft records.

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

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

 The PIC is prohibited from beginning a flight unless the UA’s battery level is at 75% or higher. The PIC must begin returning the UA to the designated landing area when the battery level drops below 25%.

 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.

 The UA must remain clear and give way to all manned aviation operations and activities at all times.

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

 UA will not be operated directly over nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. UA will not be operated over any open

- air assembly of people.

 Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

-80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov
.

### APPLICATIONS AND PUBLIC INTEREST

The request ed exemption would allow Michael A Billquist to operate the DJI Phantom 3 Professional and the DJI Phantom 2 for the purposes of forensic engineering inspections and fire cause and origin investigations. These inspections and investigations are completed o n both residential and commercial properties and are typically conducted in support of the property insurance industry. Use of UAS for these applications will offer significant advantages related to safety, time, and cost. Most properties throughout the co untry are insured, and property owners have an interest in insurance underwriting, coverage, and claims processing; therefore it is clear that grant of this exemption would be in the public interest. Current options for gathering the data which under this exemption would be collected using UA, include use of ladders, lifts, and manned aircraft. Use of ladders and lifts are inherently dangerous and result in numerous injuries each year. Use of manned aircraft is typically not feasible and therefore valuable information remains beyond the reach of the investigator. In most cases, use of a UA is quicker and easier than any other alternative and often yields better information. Granting the present Petition will further the public interest by allowing Michael A Billquist to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 and DJI Phantom 3 Professional UASs will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Michael A Billquist’s proposed operation of the DJI Phantom 2 and DJI Phantom 3 Professional UASs will be realized without impl icating any privacy issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 2 and DJI Phantom 3 Professional UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowin g the use of a DJI Phantom 2 or DJI Phantom 3 Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducin g the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 and DJI Phantom 3 Professional UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 and Phantom 3 Professional UASs. Conducting aerial acquisitions with the DJI Phantom 2 and DJI Phantom 3 Professional UASs, instead of manned aircraft, will greatly benefit the public by drastical ly reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 and DJI Phantom 3 Professional UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engineaircraft that are typically utilized for aerial video and photography, while burning approximately

20
-30 gallons per hour of leaded av iation fuel. The DJI Phantom 2 and DJI Phantom 3 Professional UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the DJI Phantom 2 and DJI Phantom 3 Professional UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Phantom 3 Professional UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respect ively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical potential for collateral damage to life and property on the ground , and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video a nd Photography Operations With The DJI Phantom 2 and DJI Phantom 3 Professional UASs Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 and DJI Phantom 3 Professional UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 and DJI Phantom 3 Professional UASs will allow United States based companies, like Michael A Billquist, to remain competitive and contribute to growth of the U.S. econo my. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain com petitive. Operating the battery powered DJI Phantom 2 and DJI Phantom 3 Professional UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 2 and DJI Phantom 3 Professional UASs, companies such as Michael A Billquist, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 and DJI Phantom 3 Professional UASs, provides a stable workforce that increases consu mer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. Due to their small size and the fact they carry no fuel, the two models of the DJI Phantom pose a very low risk of damage to persons or structures on the ground. Because these UA are electric powered, they create no harmful emissions and make very little noise.

### SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Michael A Billquist requests the grant of an exemption to the following specific sections of the Title 14 Code of federal Regulations which would allow it to operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b) , 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.417



### CONCLUSIONS Michael A Billquist respectfully requests that the FAA grant the exemption sought in this request
. Michael A Billquist believes that considering the small size and weight of the UAS, the strict operating guidelines proposed herein, it is clearly demonstrated that the UAS will be operated safely in the national air space (NAS) with an equivalent or gre ater level of safety compared to manned aircraft. I am prepared to modify or amend any part of this request as deemed necessary by the FAA to satisfy the need for an equivalent level of safety. Please contact me at any time if you require additional inform ation or clarification.

Sincerely,

Michael A Billquist 6320 Theden St. Shawnee, KS 66218 913
- 764
-0123 Mab629@gmail.com

### APPENDIX A: REGULATIONS REQUIRING EXEMPTION

Michael A Billquist requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Phantom 3 Professional and Phantom 2 UAS: 

### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Section 91.20 3 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the size of the UA, its very light weight, and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. An analysis of these different criteria demonstrates that the UA operated without an airworthin ess certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. 

### 14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 6 **1.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot**  **Privileges and Limitations** The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of the United Sta tes, unless that person: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authoriza tion. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may be used. The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an aircraft for co mpensation or hire. Subparagraph (b) allows a private pilot to 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; (2) The aircraft does not carry pass engers or property for compensation or hire. Given the size, weight, speed, operational limitations, and range of the UAS, Michael A Billquist proposes that I as operator of the UAS should not be required to hold a commercial pilot certification. Instead , operators should be required to: Hold at least an FAA issued private, recreational, or sport pilot certificate. All operators will either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) coveringregulations and issues pertinent to commercial operation of the Phantom 3, Phantom 2 Vision+

and Phantom 2 UAS. 

### 14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard r**equirements.** This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. Michael A Billquist proposes to provide an equivalent level of safety by maintaining a copy of all documents used by the operator to ensure the safe operation and flight of the UAS as well as documentation of an exemption and COA with the ground control station and accessible to the PIC during flight operations. 

### 14 C.F.R. § 91.103: Preflight action This regulation requires that each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include runway lengths at airports of intended use, and the following takeoff and landing dist ance information. This regulation is not applicable due to the fact Michael A Billquist UAS operations will not occur at an airfield. To provide an equivalent level of safety, the PIC will complete a preflight inspection as directed by the manufacturer’s m anuals. 

### 14 C.F.R § 91.105: Flight Crewmembers at Stations The regulation states that required crewmembers must be at their stations in the aircraft during specific portions of a flight. This is not applicable since the UAS carry no crewmembers. An equi valent level of safety will be maintained by ensuring that the PIC is identified prior to any flight and that the PIC does not change during a flight. The PIC will maintain control of the UAS for the duration of the flight. 

### 14 CFR § 91.119: Minimum Safe **Altitudes** The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the UA will be operating at a maximum of 500 feet AGL, these operations cannot comply with this requirement. The equivalent level of safety will be achieved given the size, weight and speed of the UAS. Additionally the UAS will be operated in a defined and relatively small AOI. Moreover, the UA will not be operated over any open

- air assembly of persons or over any person not involved with the operation. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. 

### 14 CFR 91.121 **– Altimet** **er settings**This section requires that 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 below 18,000 feet MSL to:

 The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
 If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an approp riate available station;
 In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. To provide an equivalent level of safety, the UAS utilize a GPS system, barometric pressure sensors, and internal gyroscopes to calculate the altitude. 

### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions The regulation provides that no person may begin a flight in an airplane under day

-VFR conditions unles s there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Given the area of operation for the UAS, Michael A Billquist believes that an equivalent level of safety is achieved by requiring at least 75% battery power in order to begin a flight and requiring the UA to return to land when the battery power reaches 25%. 

### 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows:
 No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate.
 No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authori zation issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, Michael A Billquist proposes to maintain a copy of all documents used by the operator to ensure the safe operation and flight of the UAS as well as documentation of an exemption and COA with the ground control station and these will be available to the Administrator or any law enforcement official upon request. 

### 14 CF **R 91, Subpart E (91.405, 91.407, 91.409, 91.417) -**  **Maintenance, Preventive Maintenance, and Alterations**  The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with P arts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection forthe issuance of an airwort hiness certificate. Section 91.417(a) requires the owner or operator to

keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. Michael A Billquist proposes that the maintenance, as well as preflight inspections of the UAS will be accomplished by the PIC. All maintenance will be conducted and logged in accordance with the manufacturer’s specifications. An equivalent level of safety will be achieved because the UAS are small in size, are not complex mechanical devices, and will carry no external payload.