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

GLOSSARY 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 consist 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, remaining 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 Professional and DJI Phantom 2 are all very similar UAS. One exception is that the 

Phantom 3 Professional 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 point. 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 accordance 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 

maintenance, 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 maintenance 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 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 use in any commercial 

operations. The functional test flight must be conducted in such a manner 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 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. 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 reliability 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 Section 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 airman 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, including 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 PIC 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 must 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 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 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 issued 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 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. 

 A grant of exemption must be accessible during UAS operations and made available 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 for safe flight. 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. All maintenance 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 requested 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 on 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 country 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 implicating 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 allowing 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 reducing 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 drastically 

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 engine 
aircraft that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation 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 respectively, 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 and 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. economy. 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 competitive. 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 

consumer 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 greater 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 

information 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 91.203 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 

airworthiness 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. § 61.113(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 States, 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 authorization. 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 compensation 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 passengers 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) covering 
regulations 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 requirements. 

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 distance 

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 manuals. 

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 

equivalent 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 – Altimeter 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 appropriate 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 unless 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 authorization 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 CFR 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 Parts 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 for 
the issuance of an airworthiness 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.