Petition for Exemption by AirCover: James Hill 3710 Flight Avenue Redding, California 96002

AirCover has filed for an experimental airworthiness certificate for its small unmanned aircraft system to be operated in limited specific geographic locations for the purposes of testing, evaluation and demonstration. As part of its application for airworthiness , AirCover is required to apply for an exemption to 14 C.F.R. 91.9(b)(2) and 14 C.F.R. 19.203(a) & (b) because of the unique aspects of the UAS design.

- 14 C.F.R. 91.9(b)(2) requires a civil aircraft to have on board the current, approved rotorcraft flight manual, approved manual material, markings, and placards or any combination thereof.

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- 14 C.F.R. 19.203 (a) requires a civil aircraft to an airworthiness certificate on the aircraft and must display the airworthiness certificate in a visible location withi n the cockpit of the aircraft

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AirCover’s small unmanned aircraft is a battery powered quad

- rotor system with a gross weight of 3.7 lbs. The aircraft does not have a cockpit and does not have the ability to hold or display an airworthiness certificate. The operators of the small unmanned aircraft will have the current approved flight manual and airworthiness certificate with them at the ground station.
Therefore, AirCover specifically request that is be exempted from the requirement to have on board the aircraft the current, approved rotorcraft flight manual, approved manual material, markings, and placards or any combination thereof; and that is be exempted from maintaining and display its civil airworthiness certificate in a visible location within the cockpit. In lieu of the requirements of 91.9(b)(20 and 19.203(a), AirCover will maintain the current, approved rotorcraft flight manual, approved manual material, markings, and placards or any combination thereof and the civil airworthiness certificate with the ground station.
The requested exemption will not adversely affect the safety of flight. Having a manual onboard the small unmanned aircraft would be meaningless as the individual that needs to have access to the manual would not be on the aircraft. In addition, having the civil airworthiness certificate on board the unmanned aircraft would not provide regulators or potential occupants (as occupants are not possible) with notice of the aircraft’s civil airworthiness.

Given that t he FAA defines a n unmanned aircraft system as both the aircraft and the ground station , it would seem that the ground station would also be considered part of the aircraft . Therefore, arguably having the manual and airworthiness certificate with the ground station would comply with the spirit of 14 C.F.R. 91.9(b)(2) and 14 C.F.R. 19.203(a).
All proposed operations will be conducted within a defined incident parameter. Each flight will be less than 45 minutes in duration. The operators will notify ATC in advance of the flights and will post aNotice to Airman regarding the proposed operations. The operations will be conducted by line of sight and less than 400 feet AGL. The operations will not obtain imagery or data of any individual’s private property.
The requeste d exemption would benefit the public because of the nature of AirCover intended operations. AirCover’s product is a cost effective tool for public safety and agriculture. Currently, public safety and government agencies conduct agricultural research can apply for and operate an unmanned aircraft. However, a manufacturer cannot operate an unmanned aircraft without an airworthiness certificate. Without an airworthiness certificate, AirCover is unable to provide demonstration and training programs for publ ic safety. Moreover, AirCover partners with various research entities and public safety to conduct mock operations, including programs with state homeland security agencies and Iowa Department of Agriculture

. The use of the aircraft is for the public ben efit.
**The following summary may be used to publish in the Federal Register:**
AirCover has petitioned the FAA for an exemption to the requirements set forth in 14 C.F.R. 91.9(b)(2) and 14 C.F.R. 19.203(a) & (b). These two regulations require an aircraft to have onboard current, approved rotorcraft flight manual, approved manual material, markings, and placards or any combination thereof and the civil airworthiness certificate. Because of the unique aspects of the UAS design, it is unable to have onboard th e aircraft these documents. However, these documents will be in the position of the operator at the ground station, which is deemed part of the aircraft by the FAA. The exemption to these regulations will not adversely affect the safety of flight.

The re quested exemption will permit AirCover to obtain an experimental airworthiness certificate to allow it to provide training and demonstration flight in a defined geographic area. All proposed operations will be conducted within a defined incident parameter . Each flight will be less than 45 minutes in duration. The operators will notify ATC in advance of the flights and will post a Notice to Airman regarding the proposed operations. The operations will be conducted by line of sight and less than 400 feet AGL. The operations will not obtain imagery or data of any individual’s private property.