October 22, 2014 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE Washington, DC 20590 ,f±· •..

; · .. ".../

Re: Exemption Request Under Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Draganfly Innovations Inc. ("Draganfly"), the developer and operator of the DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and DraganflyerGuardian (collectively, Draganflyer Systems) small Unmanned UAS Systems ("sUAS") seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed in Appendix

### A. Details of Draganfly and the DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian sUAS are described in Appendix B. Attached as Appendix C is a summary ofthis request. The requested exemption would permit Draganfly commercial operation of Draganfly's DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and DraganflyerGuardian(see details in Appendix B), each which weigh less 5.5 lbs with imaging payloads, to perform market research, aerial surveys, mapping, and inspections that consist ofstill photographs, video, and other data taken by onboard sensors. The Draganflyer Systems produce high quality imagery and datathat can be used independently or in the case ofsurveying and modelling, can be combined to produce precision digital point clouds, triangle models, and contour maps ofthe surveyed area. Applications forthese sUASs include assistance to law enforcement agencies for criminal investigation, traffic accident reconstruction and tactical support, emergency services emergency site management in cases of natural and manmade disasters as well as search and rescue, environmental monitoring, wildlife monitoring and enforcement, in inspection of sensitive infrastructure including oil and gas pipelines, flare stacks, power lines, communications towers, wind turbines, and surveying tasks such as precision agriculture, mining, transportation, and forestry. Use of Draganflyer Systems forthese emergency services, inspection and surveying applications reduces the need to operate conventional aircraft, providing data more safely, quickly, accurately, economically, and with reduced environmental impact. Operations underthe exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level ofsafety to currently authorized operations using manned UAS and underconditions as may be modified by the FAA as required by Section 333. Draganfly anticipates thatwhile it is filing this exemption request on its own behalf, its customers, in the future, will file exemption applications to allowthem to operate the Draganflyer X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian in commercial operations at their own locations, that require aerial data for law enforcement and emergency services orto support, inspections and surveys. Wherever possible, those filings will be substantially similarto this exemption application.

Page 1 of22As described more fully below, the requested exemption would authorize Draganflyto perform market research and commercial operations ofaerial inspections and surveys using the Draganfly Systems, all which are small in size less than 5.5 lbs and powered electrically by battery. Draganflyer Systems will be operated under controlled conditions at lowaltitude in airspacethat is limited in scope, as described morefully herein; with automated control features, as described below. Draganflyer Systems are designed to be operated by one person butflight operations generally involve two people: an operator and an observer. The operator is responsible forflying the sUAS, monitoring its status and flight dynamics while maintaining visual line ofsight, and keeping theflight within the specified factory limits (in terms ofwind, flight range, battery life, etc) to ensure safe operation ofthe sUAS itself. The observer is responsible for monitoring the airspacefor other UAS and hazards and instructing the operator before and during flight as necessaryto ensure safe separation to avoid any interferencewith these UAS and hazards. The operator also will be an individual who has passed an FAA approved or equivalent ground training exam and authorized Draganflytraining program forthe DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian. Finally, the airspace in which the Draganflyer Systemswill operate will be disclosed to and approved, as needed, by the FAA in advance. Draganfly respectfully submits that because Draganfly systems will be used atvery low altitudes, in lieu of having the same comparatively hazardous operations conducted by conventional fixed wing and rotary conventional aircraft, the FAA can have confidence thatthe operations will achieve at least an equivalent level orgreater level ofsafety. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities underSection 333(c) ofthe Reform Actto "establish requirementsforthe safe operation ofsuch UAS systems in the national airspace system."

The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). AppendixA discusses each rule listed above and explains why exemptions pursuanttothe proposal set forth in this letter are appropriate, provide an equivalent level ofsafety, and are in the public interest.

Page 2 of22THE APPLICABLE LEGAL STANDARD UNDER SECTION 333 Draganfly submits that granting ofthis exemption application for use of Draganflyer Systems in market research, surveying, mapping and inspection operations will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction ofsUASs into the national airspace system ("NAS") if it can be accomplished safely. This law directsthe Secretary ofTransportation to considerwhether certain sUASs may operate safely in the NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofsUASs do not create a hazard to users ofthe NAS orthe public or pose athreatto national security in light ofthe following: • The sUAS's size, weight, speed, and operational capability; • Operation ofthe sUAS in close proximity to airports and populated areas; and • Operation ofthe sUASwithin visual line ofsight ofthe operator. Reform Act§ 333(a)(1). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch UAS in the national airspace system." 

### /d. §333(c) (emphasis added).1 The Federal Aviation Act expressly grants the FAAthe authority to issue exemptions. This statutory authority, by its terms, includes exempting civil UAS, as the term is defined under §40101 oftheAct, from the requirement that all civil UAS must have a current airworthiness certificate and those regulations requiring commercial pilots to operate UAS in commercial service:TheAdministrator may grant an exemption from a requirement ofa regulation prescribed undersubsection (a) or (b) ofthis section orany ofsections 4470244716 ofthis title ifthe Administratorfinds the exemption is in the public interest. 49 U.S.C. §44701 (f). See also49 USC §44711 (a); 49 USC §44704; 14 CFR §91.203(a)(1). Granting ofthe requested exemption is in the public interest based on the cleardirection in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingly, the applicant respectfully requests that the FAA grantthe requested exemption without delay.

Applicant submits thatthis provision places a duty on the Administratorto not only process applications for exemptions under Section 333, but fortheAdministrator, ifhe deemsthe conditions proposed herein require modification in orderto allow approval, to supply conditions forthe safe operation ofthe sUAS. Draganflywelcomes the opportunityto consultwith FAA staffin orderto address any issues or concerns thatthis proposal may raise that they believe may require modification.

Page 3 of22Airworthiness ofthe DraganflyX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian The exemption application includes a critical element, evidence ofthe airworthiness of Draganfly's sUAS including the DraganflyerX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian. Draganfly believes that it has shown compliance through a history of granted flight operations and successful flights including many operationswith public agencies. The list ofgranted applicants includes but is not limited to: Mesa County Sheriff's Office, Grand Forks Sheriff's Department, Mobile County Emergency ManagementAgency, Canyon County Sheriff, Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North Western Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly has been operating the noted systems since 2008 underthe authority ofSpecial Flight Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and Pacific Regions. In addition our Draganfly Systems are being operated underthe authority ofTransport Canada -Special Flight Operations Certificates issued to the Royal Canadian Mounted Police at 21 locations, the Ontario Provincial Police(4 locations), Saskatoon Police Service, Prince Albert Police Service as well as a numberof universities and othercivilian businesses across Canada, to perform demonstration, research and development, public and commercial operations. Draganfly Systems are also being operated in an addition 48 other countries for applications ranging from emergency services to industrial inspections. The criteria setforth in the Order specify the substantive showings ofthe device's safety and fitness for operation to ensurethat the FAA has sufficient basis to evaluate the UAS's safety3. Draganfly Systems also have a significant set ofautomated features to ensure safe takeoff, flight and landing in many conditions, further details ofoperation can be found in Appendix B. Mandatory Operating Conditions Grant ofthe exemption to Draganflywill be subjectto the following mandatory conditions, which are based upon operating conditions setforth foroperation ofsUAS by public entities pursuant to Certificates ofAuthorization, with additional restrictions: • All operations to occur in Class G airspace. • Operations to avoid congested or populated areas, which are depicted in yellow on VFR charts. • Operations to be conducted over private or controlled access property. • Permission from land owner/controller required before commencing anyflight. • Operationsto occurduring Visual Flight Rules Meteorological Conditions (VMC). • UAS to remain within Visual Line of Sight (VLOS). • Operationsto occurduring daylight hours. • Above Ground Level (AGL) altitude to be restricted to 400 feet. • All operations conducted in vicinity ofairportto remain more than 2.5 NM from centerline azimuth of runway centerline measured from runway thresholds. • Operatorwill file a NOT AM for each flight. • All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, orotherappropriate governmental agencies. • All operations will include one pilot forflight control and one observerforVLOS enhancement ofsurrounding area nearthe UAS

Page 4 of22Operator Requirements Draganfly respectfully proposes that operator requirements should take into accountthe characteristics ofthe particular sUAS being operated. Draganflyer Systems provide many built in functional and safetyfeatures to assistthe operator in safe and reliable operation.2 The Draganflyer Systems provide two semi-autonomous flight modes using atwo joystick configuration and video interface. The user directsthe Draganflyer Systems in either a Manuai/Aititude(Manual) hold mode orGPS Position Hold to the areas of interest maintaining visual sight ofthe UAS at all times. Instrumentation indicating heading, bearing, altitude, climb rate, horizontal speed, GPS position, battery level, data link, GPS accuracy are additional navigation aids available to the pilot in control. Draganflyer Systems can be setfor maximum ceiling by the userwhen specified flight parameters are required. All flight operations are GPS capable making the system easyto navigate, and the flight control system also employs a variety ofsensors including gyros, accelerometers, magnetometers, barometric pressure, temperature, to ensurethe high stability and reliability. Draganflyer Systems have the ability to operate in both GPS mode and in GPS deprived environments and are easily switch between modes when required. Draganflyer Systems have battery level indicators allowing the pilotto monitor battery energy levels with built in warnings indicating low battery and critical battery levels where the helicopterwill begin an auto descent at a defined safe rate. In addition Draganflyer Systems have a "Return Home" capability fora command to return to the point of take-off, Return Home at loss of Data Link or Communications and a defaultAuto-land at its present position. At all times during flight operations, the operator can take immediate control of the system. Additional automated safetyfunctions and safety enhancing features ofthe Draganflyer Systems include: • Automated pre-flight system calibration checks • Automated condition orfault detection, warnings, and predefined responses to a number offlight and system conditions.

o Low battery with control orflight system

o High temperature or othersystem safetythresholds

o Lost link communication • Predefined responses include behavior such as return to home position and hover, return to home position and land, or land in current position • In the case of lost GPS, a manual userflight mode is enabled which allows the operatorto provide manual navigation inputs to assist in operating the UAS. Given these safetyfeatures, Draganfly proposes that operators of Draganflyer Systems should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: • have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilotwritten examination or FAA recognized equivalents including commercial or private license and ground school issued from an ICAO recognized country; • have completed Draganfly authorized training program for operation and maintenance ofthe sUAS. 2 Submitted underconfidentiality the following documents in support ofthis exemption application forthe DraganflyX4P, DraganflyerX4ES,Draganflyer X6 and Draganflyer Guardian Training Overview (Exhibit 1) and UserGuides (Exhibit 2) which includes Safety and PreFlight Checklists. It is estimated that since Oct 2008, Draganfly staffwill have log in excess of4,000 flight hours and in addition over300 customers world-wide will have performed thousands more offlights and logging over thousands of hours offlighttime with the Draganflyer systemswith both development and release versions. A significant amount offlighttime collected to understand and refine Draganfly's UAS products.

Page 5 of22I I**~** Draganfly notes thatthe FAA hasfound that safety factors permitted operation ofsUASs by operators with these qualifications in the case ofoperations pursuantto public COAs when the mandatory operating conditions specified above were present. See Federal Aviation Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The FAA hasthe statutory authority to grant exemptions to the requirementsfor and privileges associated with the grant ofairmen's certificates. 49 USC §44701 (f). In summary, applicant seeks an exemption from the FARs set forth above and in Appendix C to allow market research and commercial operations ofa small unmanned vehicle in surveying, mapping and inspection operations. Approval ofthe exemption allowing commercial operations of DraganflyerSystems for emergency services, law enforcement requirements, surveying, mapping and inspection operations will enhance safety by reducing risk. Conventional aerial survey and inspection operations using manned UAS involve very heavy aerial vehicles carrying significant quantities ofcombustible fuels, and a multi-person crew in piloting and observation roles. These operations require transit to and from the location ofthe activity, and often take place in congested environments including proximity to physical obstacles and/or presence ofthe general public. By contrast, Draganflyersystems all weigh lessthan 5.5 lbs including payloads and use a batteryfor power, is carried to/from the area ofactivity, removes the need forairborne pilots/observers, and poses less risk to people and infrastructure on the ground. Additionally, no national security issue is raised by the grant ofthe requested exemptions. Given the size, load carrying capacity, speed atwhich it operates, and thefactthat it carries no explosives orother dangerous materials, Draganflyer systems pose no threat to national security. Operation of Draganflyer systemsfor market research, emergency services, law enforcement requirements surveying, mapping and inspection operations in accordancewith the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting Draganflyfrom the requirements of Part 21.

The name and address ofthe applicant are: Draganfly Innovations Inc. Attn: Zenon Dragan Ph: 306-955-9907 Fax: 306-955-9906 Email: zenon.dragan@draganfly.com Address: 2108 St. GeorgeAve Saskatoon, Saskatchewan, Canada S7M OK? The primary contact forthis application is: Kevin Lauscher, kevin.lauscher@draganfly.com, 306-955-9907 ext 6111

Page 6 of22Draganfly Innovation Inc. believes satisfaction ofthe criteria set forth in Section 333 ofthe Reform Act- given Draganflyer Systems size, weight, speed, operating capabilities, lack of operational proximity to airports and populated areas, operation within visual line of sight, and lack ofthreatto national security as well as showing ofan equivalent level ofsafety as it may relate tothe requirementfor a pilot's license, provide more than adequatejustification forthe granting ofthe requested exemptionsthus allowing Draganfly commercial operation of Draganflyer Systems in market research, surveying, mapping and inspection operations in the United States ofAmerica.
Respectfully submitted,

# ~Dr- Zenon Dragan Draganfly Innovations Inc.

Page 7 of22APPENDIX A EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Draganfly requests an exemption from thefollowing regulations as well as any additional regulations that maytechnically apply to the operation ofthe Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR 

### § 91.203(a)(1) Section 91.203(a)(1) requires all civil UAS to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR§ 91.203(a)(1). Given the size ofthe UAS (5.51bs.) and the limited operating area associated with its utilization, it is unnecessaryto gothrough the certificate ofairworthiness process under Part 21 Subpart Hto 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 FAAto exempt aircraftfrom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe sUAS involved. In this case, an analysis ofthese criteria demonstratesthat the Draganflyer systems operated without an airworthiness certificate, underthe conditions proposed herein, will be at least as safe, orsafer, than a conventional UAS (fixed wing or rotorcraft) with an airworthiness certificate. Draganflyer Systemsweigh less than 5.5 lbs. fully loaded. Itwill not carry a pilot or passenger, will not carryflammable fuel, and will operate exclusivelywithin an area predisclosed and in compliance with conditions setforth herein. Operations underthis exemption will be tightly controlled and monitored by both the operator, pursuantto the conditions setforth above, and by local public safety requirements. The FAAwill have advance notice ofall operations through the filing of NOTAMs. Receipt ofthe prior permission ofthe land owner, the size ofthe UAS, the lack offlammable fuel, and the factthatthe UAS is carried to the location and notflown there all establish the equivalent level ofsafety. DraganflyerSystems provide at least an equivalent, level ofsafety3 to that ofsuch operations being conducted with conventional aircraftthatwould be orders of magnitude largerand would be carrying passengers, cargo, and flammable fuel. The automated safety features including redundant sensor systems as described in Appendix B and throughout this document highlightthe design intentions towards safety and reliability of Draganflyer Systems.

3 Transport Canada has issued a report referencing sUAS that states "This class of RPA is defined bythe maximum kinetic energy they possess and the maximum energy per unit area thatthey can impose on a human being. These RPAwere defined as "Low Energy RPA". This conclusion was based on avariety of information sources such as range safety guides and design guidelinesfor non-lethal weapons. It also noted that such aircraft, by theirvery design, have relatively short range and endurance. This coupled with their low mass, makesthem extremely unlikelyto pose a threatto manned aviation."

Page 8 of2214C.F.R. § 45.23 

### & 91.9(c): Marking ofthe Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting ofthe Roman capital letter "N" (denoting United States registration) followed by the registration number ofthe aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft orexperimental or provisionally certificated aircraft, the operator must also display on that aircraft neareach entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches no more than 6 inches high, the words "limited," "restricted," "light sport," "experimental," or "provisional," as applicable. Regulation 91.9(c) provides: No person may operate a U.S. registered civil aircraft unless that aircraft is identified in accordance with part 45 ofthis chapter. DraganflyerSystems have no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size ofthe sUAS, two inch lettering will be impossible. Official marking systemsforsmall UAS have notyet been established foroperations insidethe NAS. Draganflyersystems are currently marked with a fixed label measuring 1.8" x 0.4" containing Draganfly's logo as well as a Draganfly serial number located on the airframe deck plate nextto theflight battery insertion point. Draganfly is prepared to markthe inspection system with the name ofthe organization and location or origin and fulfill any other request by the FAAto this topic in accordance to§ 45.29(f) where the pilot, observer, and others working with the sUAS will see the identification ofthe sUAS. The FAA has issued the following exemptions to this regulation, see Exemption Nos. 8738, 10167,10167Aand 10700.

14C.F.R. 

### § 61.113(a) 

### &(b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations. Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, Draganflyer systems in this case are remotely controlled with no passengers or property ofothers on board. Section 61.133(a) requires an individual with a commercial pilot's license to be pilot in command of an aircraftfor compensation or hire. Draganfly respectfully proposes that operator requirements should take into accountthe characteristics ofthe particular sUAS. Due to Draganflyer Systems small size, endurance, range and payload capabilities, no passengers and no cargo would ever be carried. Commercial operations would be strictly limited to acquiring imaging data. Draganflyersystems have an all-digital software platform with advanced features previously restricted to full size unmanned UAS. Automated features and advanced controls enable safe, reliable operation.

Page 9 of22Draganfly Innovations considers flight safety a priority, no matterthe operating environment or project. When flown within the designed limitations, Draganflyer Systems offer superior safety over manned UAS by removing the need for people to be onboard in potentially dangerous situations. With multiple built-in safetyfeatures, the Draganfly platform is designed with safety in mind. • Draganflyer Systems automatically detects potential issues with configurable automated response behaviorsuch as a return home and land routine • Draganflyer Systems system self-calibrate all of its sensors and performs self-tests priorto takeoffto checkfor errors • Draganflyer SystemsAltitude limits. The Pilot in Command has the ability to set up maximum altitude limits to prevent climbing to altitudes where normal manned aviation takes place in Class G airspace • Draganflyer Systems display battery voltage and flighttime at all times • Low battery on the Draganfly systems triggers awarning alarm to return home, land and replace the battery • Critical battery on the Draganfly system initiates an automatic controlled descent and landing. • Ifthe Draganfly detects a lost linkto the control system the vehicle will perform its predefined Return to Home and Land orAuto land atthe location it is currently at

. • Auto detection of lost GPS warning the pilot to switch backto manual mode. Given these safety features, Draganfly proposes that operators of Draganflyer Systems should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: • have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA recognized equivalents including ICAO issued commercial, private license and ground school; • have completed Draganfly's training program for operation ofthe sUAS. Draganfly notes thatthe FAA hasfound that safety factors permitted operation ofsUASs by operators with these qualifications in the case ofoperations pursuantto public COAswhere the mandatory operating conditions specified above are present. See Federal Aviation Administration, Notice N8900.227, Unmanned UAS Systems (UAS) Operational Approval, at 2021 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equivalent level ofsafetywill be provided by allowing operation of Draganflyer Systemswithout a private pilot's certificate or a commercial pilot's certificate, underthe conditions setforth herein. The risks associated with the operation ofthe Draganflyersystems (given theirsize, speed, operational capabilities, and lack ofcombustible fuel) are so diminished from the level of risk associated with private pilot operations orcommercial operations contemplated by Part 61 with conventional UAS (fixed wing or rotorcraft), that allowing operations ofthe sUAS as set forth above meets orexceeds the present level ofsafety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise tothe level of requiring a commercial pilot to operate the UAS under§ 61.133(a).

Page 10of22I , I

14 C.F.R. § 91.7(a): Civil aircraftairworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Currently no standard exists for airworthiness ofa sUAS such as Draganflyer Systems. Given the size ofthe UAS and the previous COAs issued for Draganfly's DraganflyerX6, Draganflyer X4ES, an equivalent level ofsafety will be achieved by ensuring compliance with the Draganfly manuals priorto each flight.

14 C.F.R. 

### § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft. The regulation provides: No person may operate a U.S.registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unlessthere is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size and configuration of Draganflyer systemsthere is no ability or place to carry such a flight manual on the UAS, not only becausethere is no pilot on board, but becausethere is no room orcapacityto carry such an item on the UAS. The equivalent level ofsafety will be achieved by keeping the flight manual (see, e.g., User Guide, Exhibit 1) atthe ground control pointwhere the pilotflying the sUAS will have immediate access to it. The FAA has issued to othersthefollowing exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action This regulation requires; Each pilot in command shall, before beginning aflight, become familiarwith all available information concerning that flight. This information must includea) Foraflight under IFR or aflight not in the vicinity ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhich the pilot in command has been advised byATC; (b) For any flight, runway lengths at airports ofintended use, and the following takeoff and landing distance information: (1) For civil aircraftforwhich an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoffand landing distance data contained therein; and

Page 11of22(2) Forcivil aircraft otherthan those specified in paragraph (b)(1) ofthis section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

As operations will nottake place under IFR norwill they take place at airports and as FAA approved rotorcraftflight manuals will not be provided forthe aircraft an exemption will be needed. An equivalent level ofsafetywill be provided as setforth in the Draganflyer Systems User Manuals (exhibit 1) underthe 'Helicopter preflight' section. The pilot in command will take all actions including reviewing weather, potential hazards in and near landing and take-off areas as well as in the general flight area, Dragnflyer systems flight communications check and UAS performance data before initiation offlight.

14 C.F.R. 

### § 91.109(a) & 91.319(a)(1): Flight Instruction These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used forflight instruction unless that aircraft hasfully functioning dual controls. The Draganflyersystems are remotely piloted UAS and by design, do not have fully functional dual controls4. Flight control is accomplished through the use ofa control station that communicates with the UAS via radio communications. The flight plan is controlled manually in either manual mode or using GPS Positions Hold capabilities. If instruction is accomplished through atraining program, as setforth in Exhibit 1, an equivalent level ofsafety will be assured. The FAA has approved exemptions forflight training without fully functional dual controls for a numberof UAS and forflight instruction in experimental UAS. See Exemption Nos. 5778K & 9862A. The equivalent level ofsafetywill be achieved by the manufacturer providing the training as outlined, and through the use ofexperienced and qualified pilots familiarwith the Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian.

4 Dragnflyer Flight Controls can be paired fortraining or payload operator purpose as a Primary and Secondary Control system with the Primary Operator required to maintain pressure on a training button to allowflight controls.

Page 12 of2214CFR

### § 91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil UAS. Specifically, 91.119(c) limits UAS flying over areas otherthan congested areas to an altitude of500feet above the surface, except over open waterorsparsely populated areas. In those cases, the UAS may not be operated closerthan 500 feetto any person, vessel, vehicle, orstructure. As setforth herein, Draganflyer Systems will never operate at higherthan 400feetAGL and be operated in a mannerto avoid congested or populated areas. Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feetAGL, an exemption from Section 91.119(c) is needed. The equivalent level ofsafetywill be achieved given the size, weight, speed, and material with which Draganflyer Systems are built. Also, noflight will be taken withoutthe permission ofthe land owner orthose who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware oftheflights. Compared to aerial survey operations conducted with traditional manned aircraft weighing far more than 5.5 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraftthat must complywith Section 91.119.

14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed- (1) During the day, to fly afterthatfor at least 30 minutes; or (2) At night, tofly afterthat for at least45 minutes." The Draganflyer Systems batteries provide approximately 10
- 20 minutes of powered flight dependent on the model. Without an exemption from 

### § 14 CFR 91.151, the sUAS'sflights would not be possible. Given the limitations on its proposed operations and the location ofthose proposed operations, a shortertime frame forflight in daylightVFR conditions is reasonable. Draganfly believes that an exemption from 14 CFR 

### § 91.151(a) is safe and within the scope ofa prior exemption. 

### See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operating the sUAS, without 30 minutes of reserve fuel does not engenderthe type of risks that Section 91.151(a) was meantto prevent given the size and speed at which the sUAS operates. Thefactthat it carries no pilot, passenger, or cargo also enhances its safety. In the unlikely event thatthe Draganflyershould run out offuel, it would simply land (an auto-land function is initiated upon critical battery warning). Given its weight and construction material, the risks are less than contemplated by the current regulation. Draganfly believes that an equivalent level ofsafety can be achieved by maintaining 5 minutes of reserve fuel, which, would be morethan adequateto return the sUAS to its planned landing zone from anywhere in its operating area given thatthe systems are designed to be flown within direct unaided visual sight ofthe operator. For most operators this will be within 300 yards of the operator.

Page 13of22The FAA has granted similar exemptionsto others, including Exemptions 2689F, 5745, 10673 and 10808.

14 C.F.R. 

### § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a)

... no person may operate a civil aircraft unless it has

... an appropriate and current airworthiness certificate. (b) 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 atthe cabin or cockpit entrance so that it is legible to passengers or crew. DraganflyerSystemsfully loaded weighs approximately 5.5 lbs or less. As such, there is no ability or place to carry certification and registration documents orto displaythem on the sUAS. In addition, there is no pilot on board the UAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control pointwhere the pilotflying the sUAS will have immediate access to them. The FAA has issued numerous exemptionsto this regulation. A representative sample ofother exceptions includes Exemption Nos.9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. 

### § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operatororowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 of this chapter

..." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requires the owner oroperatorto keep records showing certain maintenance workthat has been accomplished by certificated mechanics, under Part43, or licensed pilots and records ofapproval ofthe aircraftfor return to service. The Draganflyersystems are nearly maintenancefree with the only moving parts on the flight airframe during operations are 2 ceramic bearings per motors. The motors are direct drive brushless motors. Checks done ofthe system will be performed by a qualified person priorto each flight and at predefined intervals as part ofthe Maintenance Schedule in the User Manual (see Exhibit 2). Preflight checklist includes: 1.Visual inspection ofthe airframe 2.Visual inspections of rotor integrity 3.Check charge ofall batteries (aerial vehicle, command station, radio repeater station) An equivalent level ofsafetywill be achieved because the sUAS is small in size, will carry only a light weight camera system payload, will operate only in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached UserGuide (System Maintenance section), the operator ofthe Draganflyer System will ensure thatthe sUAS is in working order priorto initiating flight, perform required maintenance, and keep a log ofany Page 14of22maintenance that is performed. Moreover, the operator is the person mostfamiliarwith the UAS and is best suited to maintain the UAS in an airworthy condition and to ensure an equivalent level ofsafety. The Draganflyer Systems' Maintenance guidelines ensure an equivalent level ofsafetyto the maintenance requirements in Part 91.

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APPENDIX 8 SMALL UNMANNED AERIAL SYSTEM DESCRIPTION Draganfly Corporate Overview: Draganfly Innovations Inc. is a Canadian company located in Saskatoon Saskatchewan, Canada. Draganfly is focused on providing micro unmanned aerial systems and is globally recognized as one ofthe market and technology leaders in this space. Key customers range from organizations such as Mesa County Sheriff's Office, Grand Forks Sheriff's Department, Mobile County Emergency ManagementAgency, Canyon County Sheriff, Illinois State Police, Orange County Sheriff's Office, University of North Dakota, North Western Michigan College, Texas A & M, Northern Plains UAS Test Site. In Canada, Draganfly Innovations has been operating the noted systems since 2008 underthe authority ofSpecial Flight Operations Certificates issued by Transport Canada in, the Prairie North, Ontario and Pacific Regions. In addition our Draganfly systems are being operated underthe authority of Transport Canada -Special Flight Operations Certificates bythe Royal Canadian Mounted Police at 17 locations, the Ontario Provincial Police (4 locations), Saskatoon Police Service, Prince Albert Police Service as well as a numberof universities and other civilian businesses across Canada, Draganfly systems have accumulated thousands of hours in global flight operations. Draganfly systems have been approved bythe FAAforoperational COAs and have a demonstrated safetytrack record. The Draganflys UAS platformswere thefirstto officially fly at the first operational the FAA's UAS Test Sites (Northern Plains UAS Test Site, North Dakota). Many customersfrom emergency services, to education to police and even commercial operations for industrial inspections have been given approval to fly in US, Canada, UK, Australia, Japan, and others airspaces. Draganfly Systems Overview: The DraganflyerX4P and DragnflyerX4ES systems can carry payloads up to 1.8 lbs. The DraganflyerX6 can carry payloads upto 0.741bs. The Draganflyer Guardian can carry a payload of0.9 lbs. The Draganfly systemsfly with a maximum wind threshold of30 M.P.H. for sustained winds and wind gusts up to 35 M.P.H. Draganflyers' system each have 11 sensors on board the UAS including 3 gyros, 3 magnetometers, 3 accelerometers, a barometric pressure sensor and GPS module automatically. This sensor package provides fordefaultflight of level flight and does not allowthe UAS to go beyond a 38 degree angle. Thistakes the difficult portion out offlying, the operator is only steering the UAS and adjusting its altitude. While in GPS mode the helicoptercompensates forwind atthe altitude the system is flying. The end result is a system capable ofgathering high quality aerial data at much higherwind thresholds. A traitthat is imperativefor many aerial inspection operations. While GPS Position Hold is available the UAS does not rely on itfor operations. When an operatorfinds themselves in a situation where GPS is either not available or has degraded, safe operations can still be carried out. While the Draganfly Systems have an operational range ofover Y2 a miles, the systems are designed to be flown within directvisual sight ofthe operatorat all times. Dependent on a person visual acuity most operation would take place within 300 yards ofthe operator.

s Control transmission signal is rated for in excess of% mile, however battery flight endurance limits require the operator to restrict maximum distance to ensure safe return ofthe sUAS.
Page 16 of22All flight operations take place as a result ofdirect input ofthe pilot in control. Flight adjustments are made based on atwojoystick control system which allows forvery precise movements and makes it extremely easyto navigate in either Manual or GPS Position Hold. When in Manual flight altitude is maintained based on barometric pressure and can be easily adjusted by the pilot in control using the leftjoystick. In GPS Position Hold mode, ifthe operator is not explicitly commanding the system to move, the system automatically holds its GPS position. Camera stability is further enhanced by a 2 axis brushless mountto ensure the most stability and least amount ofvibration regardless ofthe wind. The Draganflyer Systems have the option to be operated in both semi and fully autonomous flight modes. Using Draganfly Preflight planning software, preplanned flight paths can be uploaded to the helicopter priorto take offand after a controlled take offthe pilot can command the preprogramed flight path to be executed. Atanytime during the autonomous flight the pilot can immediately provide inputs to abortthe autonomous flight and take overthe flight system. With the ability to fly in both Manual Mode and GPS Position Hold as well as in a GPS deprived environment makes the Draganflyersystems the safest choice for both urban and nonurban environments. Draganflyersystems detect a loss ofGPS and warn the Pilot in Control ofthe status. Otherfaults that can be detected include: loss ofcommunication and low battery levels. In addition, the operator can create maximum flight altitudes so the system cannot go above a pre-set maximum altitude. The Draganflyer systems are operated entirely by visual based navigation with the operator maintaining direct sight ofthe SUAS at all times. This meansthe operatorcan fly in very technically challenging areas and does not rely on maps orGPS oran internet connection for operations. DraganflyX4P, DraganflyerX4ES, DragnflyerX6 and Draganflyer Guardian Operating Manual System user manuals available upon request.
Physical Characteristics
DraganflyerX4P and DraganflyerX4ES Dimensions: -Width: 87cm (34.25in) -Length: 87cm (34.25in) -Top Diameter: 1 07cm (42in) -Height: 30cm (12in) Weightand payload:

- Helicopterweightw/battery: 1,670g (3.71bs)

- Payload capacity: 800g (1.81bs)

- Maxtake-offweight: 2,470g (5.41bs) Flight characteristics:

- Max climb rate: 2m/s (6.5ft/s)

- Max descent rate: 2m/s (6.5ft/s)

- Maxturn rate: 90 degrees/sec

- Approx max airspeed: 50km/h (30mph)

- Minimum airspeed: Okm/h (Omph)

- Launch type: VTOL Page 17of22- Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meter distance: 72db

- Approx sound at 3 meters distance: 62db Fuel

- 5400 mAh Lithium polymer battery. Charging is done in the included battery charger and can be charged via standard wall outlet, orvia a 12 volt de source.
DraganflyerX6 Dimensions: -Width: 84cm (33in)

- Length: 90cm (35.5in) -Top Diameter: 99cm (39in)

- Height: 26.5cm (10.5in) Weightand payload:

- Helicopterweightw/battery &WiFi: 1,31Og (2.81bs) -Payload capacity: 335g (.741bs)

- Maxtake-offweight: 1,645g (3.61bs) Flight characteristics: -Max climb rate: 2m/s (6.5ft/s)

- Max descent rate: 2m/s (6.5ft/s)

- Maxturn rate: 90 degrees/sec

- Approx max airspeed: 50km/h (30mph)

- Minimum airspeed: Okm/h (Omph)

- Launch type: VTOL

- Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meter distance: 72db

- Approx sound at 3 meters distance: 62db Fuel

- 2700 mAh Lithium polymer battery. Charging is done in the included battery chargerand can be charged via standard wall outlet, orvia a 12 volt de source. Draganflyer Guardian Dimensions: -Width: 59.5cm (23.5in)

- Length: 59.5cm (23.5in) -Top Diameter: 72.5cm (28.5in)

- Height: 25.5cm (1Oin) Weight and payload:

- Helicopterweightw/battery: 1050g (2.31bs) -Payload capacity: 420g (.91bs)

- Maxtake-offweight: 1,470g (3.21bs) Flight characteristics:

- Max climb rate: 2m/s (6.5ft/s) -Max descent rate: 2m/s (6.5ft/s) -Maxturn rate: 90 degrees/sec

- Approx max airspeed: 50km/h (30mph)

- Minimum air speed: Okm/h (Omph)

- Launch type: VTOL Page 18of22-Max altitude ASL 2,438m (8,000ft)

- Approx sound at 1 meterdistance: 62db

- Approx sound at 3 meters distance: 50db 

### Fuel- 2700 mAh Lithium polymer battery. Charging is done in the included battery charger and can be charged via standard wall outlet, orvia a 12volt de source.



### Landing style/type -Autonomousvertical lift 

### Propulsion System • Engines- The DraganflyX4P, DraganflyerX4ES, Draganflyer Guardian are powered by 4 electric direct drive brushless DC motors. The DragnflyerX6 is powered by 6 electric direct drive brushless DC motors. • Batteries

- Lithium polymer batteries. Charge level status from the battery on the helicopter is continually monitored and real time levels are displayed on the control system used by the Pilot in Control. Predefined voltage levels indicating; Low Battery Warning

- (Low battery land immediately) warning alarm both visual and audible are provided to the Pilot. Critical BatteryWarning

- (Critical battery land immediately) warning alarm both visual and audible are provided to the Pilot, in addition the helicopterwill begin an auto descent and land at a controlled rate. At anytime during the batterywarnings full control ofthe helicopter is maintained. Ignoring the critical batterywarning and overriding the descent feature could result in a critical flight system failure. Charging is donewith the included battery charger and can be charged via standard wall outlet, orvia a 12 volt DC source.



### Maintenance -The UAS are nearly maintenancefree, the airframe has veryfew moving parts only 2 ceramic bearing per motor. Maintenance consists of inspections and verification of communications performed by a qualified person priorto each flight. Preflight checklist includes but is not limited to: • Visual inspection ofthe airframe including; side arms, landing gear, rotors, motors, canopy • Visual inspections of rotor integrity • All payload system connections and components • Check charge of all batteries (aerial vehicle, control system, video repeater station) 

### Reliability- The system is designed for maximum reliability and to maintain performance over its life. The only components experience routine wear are rotors, batteries, motors, and legs. Battery and motorconditions are monitored by the system with deviations reported to the operator. Contactwith other objects during flight may cause other components, particularly rotors, and motor arms, to become damaged and may cause aflight system failure. Damaged components are likelyto be detected during thefull visual inspection ofthe airframe performed before each flight.

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The UAV system detects numerous conditions which may make flying unsafe, such as reduced GPS accuracy, magnetic anomalies, low battery charge, battery cell imbalances, and temperature fluctuations. Degradation or loss of communications(Data Link) between the helicopter may initiate afailsafe action of Return to Home, where the helicopterwould return to its point oftake-offat its current altitude and then land oran Auto-land where the helicopterwill descend at a controlled rate at its current position. Forthe failsafe action of Return Homethe UAS must be in GPS Position hold, if not in GPS Position Hold the UAS will defaultto Autoland. In the event during a Return to Home initiation the helicoptersenses a low batterythe helicopterwill defaultto the Auto-land process. 

### Command and Control Systems The Draganflyer Control station allows the operator simultaneous control over UAS and payloads. Thejoysticks control allows forquick navigation while the display screen provides all essential flight datato the Pilot in Command. Telemetry data is transmitted to the command station at least once persecond. 

### Displayed on GCS: • UAS BarometricAltitude • UAS Bearing • UAS Heading • UAS Ground Speed • UAS Climb Rate • FlightTime • Data Link • UAS Position • GPS Satellite number ofSatellites • GPS Satellite POOP • GPS Satellite Errors • Control system battery level • Helicopter battery level • Helicopterattitude • Flight Time • Local Time • UAS FailsafeAction • UAS Status



### Onboard Flight Instruments- The UAV is equipped with an Inertial Navigation System (3 axis gyroscope, 3 axis magnetometer, 3 axis accelerometers, GPS receiver, barometric pressure sensor and GPS module. 

### On-board computer systems -The UAS is equipped onboard computersystems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.). 

### Onboard guidance and navigation equipment-The UAS can operate semi autonomously or autonomously; before autonomousflight is allowed to be executed the Pilot in Command must initiate and complete thetakeoffsequence then place the helicopter in GPS Mode. In the event GPS satellite coverage is not sufficient ordegrades, the Pilot in Command can immediatelytake control with Manual flight.
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### Frequency Allocations

- 900 MHz, 2.4 GHz, 5.8 GHz 

### Flighttermination link- to prevent a "fly away" or other potentially dangerous situation aflight termination link is available tothe operator at the control system. 

### Takeoffand Landing-The DraganflyX4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian has vertical lift autonomous launch. For launch procedures the UAS will takeoffand hover approximately 3-4 feet until further inputs are made bythe Pilot in Command. Horizontal position ofthe UAS is controlled by the Pilot in Command using the Rightjoystick. 

### Navigation System

- Operation ofthe helicopterfor navigational purposes is done by the pilot keeping the helicopter in direct line ofsight at all time. Autonomous flight (grid pattern and points of interest) is available ifa flight route has been uploaded to the UAS priorto takeoff. Autonomous flight can only executed once the pilot is satisfied the helicopter is operating correctly and the autonomousflight route is safe to execute. Once the autonomous route is completed the pilot resumes control for continued flight or landing. At any time during the autonomousflight the pilot is able to abortthe process and resume control ofthe UAS. 

### Redundant Systems -The UAS combines the inputfrom a multitude ofsensors. Even though the datafrom all sensors is required for optimal system performance, dependent on the sensor, a single sensor malfunction is likelyto result in degraded performance ratherthan leading to a fatal response. 

### Emergency Procedures and System Failures Sensor Failure- Failure ofonboard flight instruments/sensorswill degrade the UAS performance and will result in either afatal critical response or a non-fatal critical response, depending on the nature and severity. Ifthe UAS becomes unstable due to sensorfailure, this may result in loss of performance orfeatures but still allowforstable Pilot in Command flight, an automated landing or in extreme cases afatal response. 

### Motor Failure- This will cause afatal response in the UAS flight performance if one or more motors fails. 

### Airframe Failure- Depending on the nature and severity, this may result in decreasedflight performance ora fatal response. 

### Navigation System Failure- In a navigation system failure, degraded GPS will result in a response warning to the pilot where-by the system would be flown in manual mode. This will result in degraded GPS position performance, manual Pilot in Command flight will not be effected. 

### Power Failure -Acomplete batteryfailure which results in power loss to the UAS will result in afatal response. 

### Low Battery Condition

- Operatorwill be alerted of a low battery condition and will land the UAS as soon as able. 

### Critical Battery Condition

- Operatorwill be alerted ofa Critical low battery condition and will land the UAS as soon as able, the UAS will begin to descend at a controlled rate.
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### of22Line ofSight Loss -Allflight operations will be conducted with the UAS within visual sight of the pilot. Ifthe pilot's view becomes obstructed and line ofsight is lost, the pilot may instructthe UAS to hover in place until line ofsight is re-established, to return to the takeoff position, orto land at the current position. Security The system and communication links are encrypted by the manufacturer's proprietary software.

APPENDIXC SUMMARY OF DRAGANFL YSECTION 333 EXEMPTION REQUEST Draganfly hereby provides pursuantto Part 11 a summary of its exemption application to allow commercial operation ofthe Draganfly X4P, DraganflyerX4ES, DraganflyerX6 and Draganflyer Guardian small unmanned systems in market research, precision aerial survey work, mapping and inspections. An exemption is requested from the following regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2) & (c); 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). 20 of20

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