June 23, 2015

Exemption No. 11778A Regulatory Docket No. FAA

– 20 15

– 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 da ted 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 all ow the petitioner to operate an unmanned ai rcraft 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 des cribing 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 p etitioner

.

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+

.2

In accordance with the statutory criteria provided in Section 333 of P ublic 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

, C ertification 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 No s

. 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 Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced s afety 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 th e 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 consi deration 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.3

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 restri ction. 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 re ported 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 m edical 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 ;

e lectronic 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 limi tations 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 operatin g documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised4

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 opera tor must petition for an amendment to its grant of exemption. The FA A’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 t hat 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal

G overnment. The PIC must also meet the flight revi ew 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 with5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (traini ng, 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 exempti on. However, training operations may only be conducted during dedicated training sessions. During

traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must ope rate 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). F lights 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 symbo l 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 s tatute miles from the PIC.

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

pre

- determined location within the pr ivate 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 cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or am ended 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.6

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 gi ve 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, vehicl es, 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. I f 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 control led

- 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 FA A'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 televisio n operations manual (MPTOM) as documented in this grant of exemption.7

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) w ith jurisdiction over the a rea 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 th e 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 involv ed 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 ex emption, 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 91.8

This exemption terminates on June 30, 2017 , unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

Enclosures1 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	10 th

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

document	will	give	an	overview	of	the	amendments	we	would	li ke	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	co mpanies	( 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,	batt ery	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	fil m ing.	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 ab ove	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.com3 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 film4 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: 1 0

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

str ucture.

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	sha ll	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	Op erations	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	an d	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

ma rked	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	drive r’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	a t	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	Pr ivileges	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	speci fied	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	3 rd Class	Medical

New Text:

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

• Hold	a	valid	US	driver’s	license