U.S. Department offransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Filed with www.regulations.gov April17,2015

Re: Petition for Exemption Under Section 333 oftheFAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear I'v1lidam, Sir, Pursuant to Section 333 oftheFAAModernization and Reform Act of2012(the "Reform Act"), P.L. 112-95, "Special Rules for Certain Unmanned Aircraft Systems" and 14 C.P.R. Part 11, TheodoreW. Tierney, d.b.a. Airfoil Enterprises Inc.("AFI")providing land surveying services inNewYork and Hawaii, seeks an exemptionfrom the Federal Aviation Regulations ("PARs") and listed below: 14 C.P.R. Part 21 14 C.P.R. 45.23 14 C.P.R. 45.29 14 C.P.R. 61.23 14 C.P.R. 61.3 14 C.P.R. 61.113(a) & (b) 14 C.P.R. 61.133(a) 14 C.P.R. 91.7(a) 14 C.P.R. 91.9 14 C.P.R. 91.109(a) 14 C.P.R. 91.119 14 C.P.R. 91.121 14 C.P.R. 91.151(a) 14 C.P.R. 91.203 14 CFR Subpart E (91.401- 91.417) Summarizedfor purposes ofFederal Register publication: Applicant seeks an exemptionfrom thefollowing rules:

. 14 C.F.R. Part21, 14 C.F.R. 45.23, 14 C.F.R. 45.29, 14 C.F.R. 61.23, 14 C.F.R. 61.3, 14 C.F.R.

, 1.113(a) &(b), 14 C.F.R. 61.133(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9, 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, 14 CFR Subpart E (91.401- 91.417) to operate commercially a small unmanned vehicle (55lbs orless) augmenting its landsurveying operations. Contact information for theApplicant i s :-Airfoil Enterprises Inc. mailing address: 165 West Islip Rd. West Islip, NY 11795 -TheodoreW.Tiemeyresidentialaddress: 46 Bayside Place Amityville, NY 11701 Phone: 516-241-5489 Email: tripilot50®gmail.com FAA private pilot certificate #3036030 New York State driver license #961104163 The requested exemptionwould authorize Airfoil Enterprises Inc.(AFT) to perform commercial operations that would enhance its existing Surveying and Mapping services, including but notlimited to imaging for Precision Agriculture applications, Digital Terrain Modeling,Infrastructure reconnaissanceand inventory with GIS applications for Private, Local, State andFederal entities. These services will be augmented by use ofeither or all ofthe following: TheInspire 1, quad electric motor UAS manufactured by DJI Inc. The requested exemption would authorize commercial operations using the UAS for land survey applications.These operations will be subject to strict operating and conditions defined bythe UAS manufacturer'sstandards and procedures in order to ensure at leastan equivalent level ofsafety to currently authorized operations using manned aircrafts. Upon receipt ofthe exemption contemplated herein, AFI shall, ifrequired, obtain aCertificate ofWaiver orAuthorization (COA) form the FAAAir Traffic Organization priorto conducting operation(s) in the NAS. Further, the professional services to be augmented by the uses contemplated herein are, by law, performed under the supervision ofaRegistered Land Surveyor whom, byvirtue ofhis or her experience and licensing, technical knowledge ofGPS, plane geometry, trigonometry and spherical geometry along with afull understanding ofthe rights ofall owners ofproperty both above and below its limits, inherently and uniquely make AFI aparticularly well suited entity for the safe and efficient commercial use ofUAS. Infact, certain aspects ofthe contemplated services using UAS are regulated by State Law and Regulation promulgating the licensing of land surveyorsand land assessors. Bythis petition, AFI seeks an exemption thatwill authorize itto use the DJI Inspire for commercial purposes provided its operators comply with any terms and conditions of the FAAs anticipatedgrant ofexemption, including the procedures and requirements set forth in the respective manufacturer'suser manuals. AFI requests the FAA treatthe DJI Inspire user manual as proprietary under 14 C.F.R. 11.35(b) and not include suchdocuments in the public docket. These manuals are, by reference, incorporated herein and arepartofexisting Petitions for Exemption under Section 333 ofthe FAA Reform Act and Part 11 oftheFederal Aviation Regulations, identified as follows:Docket ID:FAA-2015-0133 • Petition of: DJI Inc., for an exemption from portions of 14 C.F.R. Part 21; • Document Type: Other • Document Subtype: Petition(s) Status: Posted • Received Date: January 30, 20 15

Underthe requested exemption,AFI as operator ofthe DJI Inspire will ensure that the aircraft will be operated byan individual who has completed the UAS manufacturer'straining program for operationofthe UAS. 1. CHARACTERISTICSOFTHE AIRCRAFT The DJI Inspire is a small and ultra-light platform that perform precision aerialmappingand photography missions using onboard GPS and related proprietary flight management software thatallows the operator to plan safely and efficiently amission in 3D, and then monitor it in real time. An cameraattachedviaavibrationdampening gimbal takes a collection ofhigh-definition still images that are used later to generate photographs,maps and contour lines ofthe surveyed area. The four main characteristicsofthe UAS are:

a. Very light weight The low kinetic energy significantly reduces the risk ofhazardous situations. UAS i s equipped with an optical flow sensor that accurately and reliably senses the crafts proximity to the ground and objects on the ground, like persons, and will maintain hover to avoid potential collisions.b. Electric-powered The UAS is electric-powered.4brushless engine technology makes quiet and reliable. The propellers easily flex away in case ofcontact with any object.

c. Semi-automatic flight The artificial intelligence incorporatedwithin the UAS autopilot system continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS andtakes care ofall the aspects ofthe flight underthe supervision ofthe operator. d. Option for Manual control Additionally, the UAS provide an override capability that allows the operator to take manually initiate autonomous actions during the flight such as "return home", "land" or, "hold and resume the mission". The operator can also suspend automated operations andtake manual control ofthe aircraft should it become necessary to respond emergency circumstances, thanks tothe remote controller provided with the system. 2.APPLICATIONSAND ADDED VALUE OF THE UAS Mapping applications may include agricultural applications, mining, construction and survey/ GIS operations. There are many operational benefits related tothe use ofthis solution:

a. The UAS bring safety to daily survey operations: there is no need for the humans to access dangerous working areas anymore (mines, quarries, orpolluted sites). The missions can be programmed and reproduced reliably as often as needed for regularly updated maps. b. The UAS is a cost-effective solution. Itis cheaper to operate a UAS rather than an aircraft orother ground systems for the same results. Moreover, small UAS likethe DJI Inspire can helpAg businesses and farmers face the growing needs ofthe population whilereducing operational costs andenvironmentalimpactoflaunchingfull scale aircraftintothethe airtoperfonn the sameworkwhileconsumingdozens ofgallonsoffuel perhourandreleasingexcessgreenhouse gasses into ouratmosphere. This UAS will also enableoffer the ability to take up new challenges

- likewater or environmental managementthrough analysis ofvegetation index maps.

c. Users can save time and work more efficiently by using aUAS. Amission does not need along preparation time or long deployment constraints, or long waiting time for perfect weather conditions unlike, for example, the use ofsatellites. Initial results are accessible directly on-site, which is impossible with images provided by satellites ormanned aircrafts. d. Lastly, butpossibly most importantly, is the efficiency aspects ofthese systems in the development, production and maintenance ofthe infrastructure related to the national energy issues that are being played out inthe extraction oftight oil reserves in various parts ofthe United States. 3.APPLICABLELEGAL STANDARD UNDER SECTION 333a.Airworthiness assessment DJI Inspirehas demonstrated its respective airworthiness through many and varied national international projects, involving state/federal agencies oruniversities (among others the New Mexico State University: https:/ /newscenter.nmsu.edu/Articles/viewll0208/nmsu-uas-flightiest center-conducts-dji-airworthiness-assessment,and the USArmy Corps ofEngineers ("USACE") New Orleans, who coordinated with the Department ofArmy and the FAA to obtain all authorizations required in order to operate the Inspire 1 UAS). Moreover, DJI has obtained flight approvals for the DJI Inspire from the national civil aviation authority in many countries, including: Switzerland (flight approval for Visual Line ofSight "VLOS"operations) Canada (flight approval for VLOS operations) Australia (flight approval for VLOS operations) France (flight approval for Extended-VLOS operations) Germany (flight approval forVLOS operations) United Kingdom (flight approval for VLOS operations) Norway (flight approval for VLOS operations) Sweden (flight approval for VLOS operations)

- .Denmark (flight approval for VLOS operations)

b. Operating Conditions Grant ofthe exemption toAFI will be subject to the following operating conditions, the operator proposed the following conditions and/or limitations, which were accepted bythe FAA.1. The UAV will weigh lessthan 55 lbs. Fully loadedwith batterythe total operational weightofthe DJI Inspire is 6.25lbs as per official specificationspublished by the manufacturer DJI Inc

.. Proposed operations ofany other aircraft will require an amendment tothe grant ofexemption contemplated herein. 2. Flights will be operated within visual line ofsight (VLOS) ofaPilot in Command (PIC) and/or Visual Observer (VO).

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occurprior to the 30 minute limit.

4. Flights will be operated atan altitude ofno more than 400 feetAGL.

5. The UAS will only operate within aconfined, preprogrammed survey area.

6. Abriefing will be conducted in regard to the planned UAS operations prior to each day's flight mission. Itwill be mandatory that all personnel who will be performing dutieswithin the boundaries ofthe safety perimeter be present forthis briefing.

7. Pilot and observer will have been trained in operation ofUASgenerally and received up to-date information on the particular UAS to be operated as required in the respective the Manuals. The operator'smanual will be maintained andmade available to the Administratorupon request. Ifadiscrepancyexists between the conditions andlimitations ofan exemption and the procedures outlined inthe operator'smanual, the conditions and limitations herein take precedenceand must befollowed. Otherwise, the operator must follow the procedures as outlined in its operator'smanual. The operator may update orrevise its operator'smanual. Itis the operator'sresponsibility to track such revisions and present updated and revised documents to theAdministratorupon request. The operator must also present updated and revised documents ifitpetitions for extension or amendment. Ifthe operator determinesthat any update orrevision would affect the basis for which the FAA granted this exemption, then the operator must petition for amendment to their exemption. The FAA'sUAS Integration Office (AFS-80) may be contacted ifquestions arise regarding updates orrevisions to the operator'smanual. 8. PIC and VO will at all times be able to communicatebyvoice and/or text.

9. Written and/or oral permission from the relevant property holders will be obtained.10. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, orother appropriate governmental agencies.

11. IftheUAS looses communicationsorlooses its GPS signal, the UAS will have capabilityto return to apre-determined location within the Survey Area and land.

12. The UAS will have the capability to abort a flight in case ofunpredictedobstacles or emergencies. 13. Prior to each flight the PIC must inspect the UAS to ensure it is in acondition for safe flight. Ifthe inspection reveals acondition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in acondition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterationsmust beproperly documented in the aircraft records. 14. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics,e.g. replacement ofaflight critical component, must undergo a functional test flight in accordance with the operator'smanual. The PIC who conducts the functionaltest flight must make an entry in the UAS aircraft records ofthe flight. The requirementsand procedures for afunctional test flight and aircraft record entry must be added to the operator's manual.

15. The operator must follow the manufacturer'sUAS aircraft/component,maintenance, overhaul; replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirementsmust beestablished and identified in the operator'smanual. At aminimum,the following must be included inthe operator's manual:

a. Actuators I Servos b. Transmission (single rotor) c. Powerplant(motors) d. Propellers e. Electronic speed controller f. Batteries g.Mechanical dynamic components (single rotor) h. Remote command and Ground control station 

### j.Any other components as determined bythe operatorII

16. Ifplanned operations occur within 2miles ofCommercial Services Airport as defined by the FAA, the operator must obtain anAir Traffic Organization (ATO) issued Certificate ofWaiver orAuthorization (COA) priorto conducting any operations. This COA will also require the operator to request aNotice to Airman (NOTAM) not more than 72 hours in advance, butnot less than 48 hours prior to the operation. Additionally, factory installed preventtheDJI Inspirefrom operatingwithin aonemileradius ofan airport. 17. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFRpart 47, and have identification (N Number) markings in accordance with 14 CFRpart45, Subpart C. Markings must beas large as practicable. 18. The operator must develop procedures to document and maintain arecord ofthe UAS maintenance, preventative maintenance, alterations, status ofreplacement/overhaul component parts, and the total time in service ofthe UAS. The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections ofthe operator'smanual. 19. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 20. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UAS must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 21. The UAV must remain clear and yield the right ofway to all other manned operations andactivities atall times (including, butnot limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 22. UAV operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 23. The UAS cannot be operated by the PIC from any moving device orvehicle. 24. The UAS may not be operated lessthan 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is lessthan 3 statute miles from the PIC. 25. The UAS may not operate in Class B, C, orD airspace without written approval from the FAA. The UAS may not operate within 5nautical miles ofthe geographic center ofanon towered airport as denoted on acurrent FAA-published aeronautical chart unless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with aNOTAM as required by the operator'sCOA. The letter ofagreement with the airport management must be made available to the Administratoruponrequest.26.Any 1) incident, 2) accident, or 3)flight operation thattransgresses the lateral orvertical boundaries ofthe operational area as defined by the applicable COA must be reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to theNational Transportation Safety Board (NTSB)per instructions contained onthe NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, ortransgression is reviewed byAFS-80 and authorization to resume operations is provided.

With this petition intended that AFI will be able to provide safe, reliable and accurate land surveying services and information to its clients with the use ofthe latest innovative technology associated with remotely piloted aircraft. Your attention to this matter is appreciated.

Respectfully submitted,

TheodoreW. TierneyANNEXA EXEMPTION REQUEST AND EQUIVALENTLEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION AFI requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe OJ I Inspire UAS: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 Section 91.203 requires all civil aircraft to have a certificate ofairworthiness. 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 ofthe UAV, their very light weight and the limited operating area associated with its utilization, it is unnecessaryto go through the certificate ofairworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe UAS involved. An analysis ofthese different criteria demonstratesthat the UAS 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. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Given the size ofthe UAS, this requirement is impossible to match. 14. CFR §61.23: Medicalcertificates: Requirement and duration Regulations provide that a person: (1) Must hold a first-class medical certificate:

•When exercising the pilot-in-command privileges ofan airline transport pilot certificate; •When exercising the second-in-command privileges ofan airline transport pilot certificate in aflag or supplemental operation in part 121 ofthis chapter that requires three or more pilots; or •When serving as a required pilot flight crew member in an operation conducted under part 121 ofthis chapter ifthe pilot has reached his or her 60th birthday. (2) Must hold at least a second class medical certificate when exercising: ·Second-in-command privileges of an airline transport pilot certificate in part 121 ofthis chapter (other than operations specified in paragraph (a)(1)(ii) ofthis section); or • Privileges of a commercial pilot certificateGiven the size ofthe UAS, their structure, the limited flight area, and the safety features integrated in the autopilot (among others aflight termination system), A FI believes that an Equivalent Level of Safety can be reached ifthe operator has avalid driver's license. 14 C.F.R. §61.3:Requirementsfor certificates, ratings and authorizations 14 C.F.R. 

### §61.113(a} & (b); 61.133(a}: Private Pilot Privilegesand Limitations; Pilot in Command; CommercialPilot Privileges and Limitations The regulation provides that no person may serve as a required pilot flight crew member ofa civil aircraft ofthe 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 ofan aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command ofan 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 safety features ofthe UAS and the fact that the missions are pre-programmed and monitored in real-time with a specific flight management software, A F I proposes that operators ofthe UAS should not be required to hold a commercial or private pilot certification. Instead, operators should be required to:

• Have completed the UAS manufacturers training program for operation ofthe UAS. The manufacturer's training program for eBee operators has been already satisfactorily reviewed through the Application for Airworthiness Qualification Level (AQL) 3Airworthiness Release (AWR). The equivalent level ofsafety will be achieved by having an operator trained UAVs manufacturer, and using the integrated features ofthe aircraft to maintain a high level of safety during the different missions. 14 C.F.R. §91.7(a): Civil aircraftairworthiness Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe particular UAS. In all cases, an analysis of these criteria demonstratesthat the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 14 C.F.R. §91.9: Civil aircraftflight manual, marking, and placard requirementsThe equivalent level ofsafety will be achieved by keeping a hard copy ofthe user manual in In close proximity to the operator. The equivalent level ofsafety will be provided by having the UAS marked on its fuselage as required by §45.29 (f)where the pilot, observer and others working with the sUAV will see the identification ofthe UAS as "Experimental."The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. §91.109(a): Flightlnstruction The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The equivalent level ofsafety during the in-flight training will be achieved by the manufacturer or affiliate providing the training as described in the manufacturer's training program and through the use of experienced and qualified instructors familiar with the UAS. 14 CFR §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. The exemption requests authority to operate at altitudes up to 400 AGL, Itwill however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent The equivalent level of safety will be achieved given the size, weight, speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Compared to flight operations with aircraft weighing far more than those proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft.

14 CFR 91.121: Altimetersettings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set"

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption is requested. An equivalent level ofsafety will be achieved by the operator confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 C.F.R. §91.151(a): Fuel Requirementsfor Flightin VFR Conditions The regulation provides that no person may begin aflight 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. As the UAS are electric-powered, this requirement is inapplicable. In any event, given the contemplated operations, A FI believes that an equivalent level of safety is already achieved with the specific procedure preventing the UAS accepting a take-offorder is the battery level is below a given value. Moreover, the manufacturers have integrated low and critical battery level warnings and implemented a "return to home" action in these situations. 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) ofthis section or a special flight authorization issued under §91.715 is displayed at the cabinor cockpit entrance so that it is legible to passengers or crew. An equivalent level ofsafety will be achieved by keeping these documents atthe ground control point where the pilot flying the UAS will have immediate access to them, to the extent they are applicable to such UAS. The FAA has issued numerous exemptions to this regulation. A representative sample ofother exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 CFR Subpart E (91.401 - 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 compliancewith Parts 39 and 43. Paragraphs 91A07 and 91.409 require the aircraft to be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409 requires an annual inspection for the issuance of an airworthiness certificate. Section 91A17 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 ofapproval ofthe aircraft for return to service. AFI proposes that the maintenance ofthe UAS will be accomplished by the owner or the operator according to the manufacturers user manual Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the applicant Maintenancewill be accomplished by the operator pursuant to the flight manual and operating handbookas referenced herein. An equivalent level of safety will be achieved because these small UAS are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feetAGL. The operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.