U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Re: Petition of Veracity Maintenance for 333 Exemption

Pursuant to 14 C.F.R. Part 11, Veracity Maintenance. (“Veracity Maintenance” or “Petitioner”) 

hereby applies for an exemption in order to conduct commercial use operations with the unmanned 

aerial systems XBOW and Raptor Multirotors and the Atlas Helicopter (“UAS”). In accordance with the 

requirements of the Federal Aviation Administration (“FAA”), Petitioner’s UAS operations have been 

designed to achieve a level of safety equivalent to that provided by the FAA regulations from which an 

exemption is requested. In support of its exemption request, Veracity Maintenance provides the 

following information.

Petitioner

Veracity Maintenance is established by a Retired(CW2) Chief Warrant Officer who was an 

exemplary Black Hawk UH 60 Pilot with over 1350 manned flight hours in Iraq and Afghanistan. He has 6 

Air medals, 3 ARCOMS, 3 AAM's , Global War on Terrorisim medals and Expeditionary Medals. Not only 

is the Petitioner an established Military Combat Pilot, he also is a established UAV Pilot with experience 

with the Scaneagle, Aerosonde, and Tigershark UAS systems with over 4800 hours of logged flight hours 

in a Combat Theater with UAS systems. The Petitioner is a established Pilot both in the Manned flight 

and Unmanned flight industries and not Just a RC Hobbyist claiming to have an exceptional amount of 

flight hours that they only accrued from flying at low altitudes at a RC Hobby field. Veracity Maintenance

is now looking to put the experience and professionalism that they have used in Iraq and Afghanistan to 

use here in our NAS. Veracity Maintenance will provide a service to the Commercial Industry that is at 

the Top of the unmanned aviation field in experience and professionalism. Veracity Maintenance is now 

proposing to use its aircraft for the commercial use of various aerial inspections , surveys, security, and 

disaster ISR operations. 

Proposed Commercial Uses

Veracity Maintenance proposes to use the DJI INSPIRE 1, DJI Phantom 2, DJI Phantom 3, XBOW , 

Raptor Multirotors, and the Atlas Helicopter small UAS aircraft for multiple commercial applications, 

including safety inspections, security, disaster ISR operations and aerial surveying of the following 

remote or difficult-to-access facilities:

• Oil and Gas platforms

• Flare booms/stacks- both onshore and offshore

• Refineries and processing stations

• Pipelines & Right of Ways

• Power lines & Right of Ways
• Bridges and infrastructure including rail bridges

• Wind turbines

• Solar farms

• Search and Rescue

• Wildfire ISR operations

• Tower Inspections

Veracity Maintenance also envisions UAS operations in support of emergency response activities on 

behalf of the National Transportation Safety Board, the Department of the Interior’s Bureau of Safety 

and Environmental Enforcement, the U.S. Coast Guard, and any other federal or state government 

agency which may require its services and personnel.

All of Veracity Maintenance's proposed UAS operations are intended to facilitate safety 

inspections and aerial surveying in areas where the performance of those functions using today's 

current methods involves a substantial risk of injury. Many of these Operations must be performed in 

hazardous environments which may be performed much more efficiently by an unmanned aircraft with 

the ability to hover and capture images at close range. The commercial UAS applications that Veracity 

Maintenance proposes will result in a significant enhancement of safety, by reducing the risks associated 

with current inspection methods, and enhancing current inspection techniques.

Proposed UAS Aircraft

Veracity Maintenance plans to conduct commercial UAS operations with the DJI Inspire 

1, DJI Phantom 2, DJI Phantom 3, XBOW, Raptor Multirotors, and the Atlas Helicopter . The Inspire 1, 

Phantom 2, Phantom 3, and XBOW are a small UAS with a maximum takeoff weight of 18lbs. The Raptor 

is a small UAS with a takeoff weight of 25lbs and the Atlas helicopter UAS has a takeoff weight of 21lbs 

At all times while conducting commercial operations, Veracity Maintenance will operate ALL AIRCRAFT 

under line-of-sight conditions. The Veracity Maintenance Operator will maintain control with a control 

system, i.e., IPAD, LAPTOP, or pilot control box, in response to commands from a Veracity Maintenance

employee with specialized flight training; aircraft will perform commercial operations autonomously or 

manually in accordance with a pre-programmed/determined flight plan. The DJI Inspire 1, DJI Phantom 

2, DJI Phantom 3, XBOW, and Raptor have four battery powered motors. In the event that the Uplink 

between the control system and the Inspire 1, XBOW or the Raptor is lost or disrupted, the aircraft are 

designed to hover for approximately 5 seconds attempting to regain the Uplink. If the UAS has GPS 

communications and is unable to re-establish communications with the control station, all aircraft rely 

on an auto-pilot feature that returns the UAS aircraft to the home point via the original flight path from 

the launch point. This will help eliminate “fly-away” incidents.

Operating Conditions

Veracity Maintenance will conduct commercial operations with the DJI Inspire 1, DJI Phantom 2, 

DJI Phantom 3, XBOW, Raptor Multirotors and the Atlas Helicopter only in accordance with a highlydetailed set of safeguards governing all phases of flight operations. Veracity Maintenance will always

place a priority upon minimizing risk to personnel, equipment, and the environment. To ensure the 
highest level of safety, UAS flight operations will only be conducted after an extensive Pre flight briefing 

(including Veracity Maintenance and client personnel) a complete systems and communications check 

and a Risk analysis have been conducted.

All UAS flights will be conducted by a minimum of three qualified personnel, including a 

qualified Mission Commander. No flights may be initiated unless a preflight checklist has been 

completed and signed by mission essential personnel. The checklist procedure will include a detailed 

inspection of the DJI Inspire 1, DJI Phantom 2, DJI Phantom 3,XBOW, Raptor, or Atlas and essential 

communications systems prior to the initiation of any operations. Most importantly from a safety 

perspective, operations directly overhead are not permitted. 

There are several additional mandates that Veracity Maintenance employees must observe in 

connection with all commercial operations with Inspire 1, DJI Phantom 2, DJI Phantom 3, XBOW, Raptor, 

and Atlas UAS systems including the following:

• No flights through an established Air Defense Identification Zone (ADIZ)

• UAS flights shall not exceed 500 feet above ground or above the sea level per FAA 

Advisory Circular 91-57

• All flights will be conducted in Class G airspace

• All flights will be conducted within line-of-sight of UAS operator

• All flights will be conducted in accordance with Class G airspace visibility requirements

• Wind speed shall not exceed 25 knots

• UAS operations will be conducted only during daylight hours

• A Notice to Airmen (NOTAM) will be filed with the FAA prior to each UAS operation

• All Chronicle UAS crews will have an air-air radio system for communication with low 

flying air traffic in the area surrounding UAS operations (programmed with 123.025

common Air-Air Frequency, and the local frequency for the area of operation)

• All Chronicle UAS crews will have an up to date Helicopter Safety Advisory Conference 

Air Frequency card.

At no point in time will Veracity Maintenance aircraft be allowed to share airspace with commercial 

aircraft. If conducting operations within three miles from any manned airport runway, Veracity 

Maintenance will notify the airport operator or the airport tower, as the case may be, in compliance 

with FAA Advisory Circular 91-57. Veracity Maintenance will terminate any UAS operations when an 

approaching commercial aircraft is within five nautical miles.
Operator Requirements

Veracity Maintenance's commercial UAS operations will build on its years of experience as an 

exemplary operator of UAS's in a Combat Theater of Operations. All Veracity Maintenance employees 

will have undergone and successfully completed a rigorous competency assessment evaluation before 

being able to operate the DJI Inspire 1, DJI Phantom 2, DJI Phantom 3, XBOW, Raptor, and Atlas UAS 

systems. Operators must demonstrate not only a superior knowledge of the technical issues associated 

with UAS systems, including the full range of the capabilities and limitations of the Inspire 1, Phantom 2, 

Phantom 3, XBOW, Raptor, and Atlas, but also must show sound piloting techniques and the ability to 

navigate around structures. Veracity Maintenance will enforce the company’s policy of “working under 

the more stringent rule.”

Veracity Maintenance operators will undergo an extensive program of simulator training as well as 

hands on flight training in a simulated inspection environment. Simulator training will allow these 

employees to gain experience with the specific flight characteristics of the Inspire 1, Phantom 2, 

Phantom 3, XBOW, Raptor, and Atlas prior to any actual commercial operations.

The following requirements will apply to any commercial UAS operations conducted by Veracity 

Maintenance:

• A pilot-in-command (PIC) will be designated at all times for each flight

• The PIC will be directly responsible for, and have final authority over the operation of 

the UAS

• The PIC will not perform concurrent duties as the visual observer

• The PIC will be qualified on the aircraft he is flying/operating

• The PIC will exercise control over the UAS both manually and autonomously in the case 

of an (EP) emergency procedure or situation governing a manual operation.

Given their hours and experience with piloting UAS systems in a Combat Theater in Afghanistan 

and Iraq, the amount of required simulator training, and the operational procedures applicable to 

Veracity Maintenance employees operating the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and 

Atlas for commercial purposes, Veracity Maintenance PIC's should not be required to hold an FAA pilot 

certificate. The commercial UAS operations by Veracity Maintenance will imitate the conditions under 

which the FAA will issue a Certificate of Waiver or Authorization to UAS operators without requiring 

pilot certification. All operations will be in Class G airspace, conducted during daylight hours under 

visual line-of-sight flight procedures no more than one-half nautical mile laterally from the PIC. All 

Veracity Maintenance PICs also will hold, at a minimum, a valid FAA second-class medical certificate. In 

accordance with the qualifications established by the FAA for the pilots of UAS aircraft operating 

pursuant to a COA. PICs should therefore be deemed qualified once they have successfully completed an 
FAA private pilot ground instruction course and passed the FAA Private Pilot examination or an FAArecognized equivalent. 

The manager for Veracity Maintenance's commercial UAS operations is Julio Jo, a UAS industry 

expert. Julio Jo has over 1350 hours of Piloting a UH-60 Blackhawk in the United States Army in a 

Combat environment, and over 4800 hours of logged flight hours in Afghanistan and Iraq Combat 

Theaters on 3 different ELOS UAS Systems. This knowledge and experience has been incorporated into 

the training, flight procedures, maintenance, and recordkeeping developed for Veracity Maintenance's

commercial UAS operations.

Exemption Request

Veracity Maintenance is requesting an exemption from FAA regulations in order to conduct 

commercial UAS operations with the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas aircraft. 

Attached as Exhibit A is a list of each FAA regulation from which Veracity Maintenance is requesting an 

exemption and the justification for each such exemption. In accordance with FAA requirements, in the 

case of each requested exemption, Veracity Maintenance is suggesting alternate methods of compliance 

that will provide a level of safety equivalent to that provided by the regulation from which an exemption 

is sought.

Veracity Maintenance's request is consistent with the FAA’s policies for the granting of 

exemptions. It also is in accordance with the direction provided by Congress in Section 333 of the FAA 

Modernization and Reform Act of 2012 (“FAA Modernization Act”), instructing the Secretary of 

Transportation to determine which UAS aircraft operating “within visual line of sight” may be integrated 

into the National Airspace System (“NAS”) before the development of regulations governing the 

commercial use of other types of UAS aircraft. Because of the relatively small size, light weight, speed 

and operational capabilities of the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas, as well as 

the strict visual line of sight protocols under which these UAS will be operated. The Inspire 1, Phantom 

2, Phantom 3, XBOW, Raptor and Atlas aircraft may be safely operated without creating a hazard to 

other users of the NAS or a threat to national security. The Inspire 1, Phantom 2, Phantom 3, XBOW,

Raptor, and Atlas operated as proposed herein, is therefore the type of UAS that ought to be the subject 

of operational approval by the Department of Transportation prior to the issuance of regulations 

governing the operation of small unmanned aircraft systems generally.

The UAS operations to be conducted by Veracity Maintenance pursuant to the requested 

exemption offer significant safety enhancements over current methods of providing the same 

commercial services. Veracity Maintenance's aircraft have the ability to fly into difficult-to-access areas 
that present considerable hazards to other methods of inspection, including those involving close-up 

inspections by human beings by means of Rope Access. In evaluating Veracity Maintenance's request 

for an exemption, the FAA should consider not just the ability of Veracity Maintenance to achieve a level 

of safety equal to or greater than that afforded by the regulations from which an exemption is sought, 

but also the safety benefits to be achieved from using UAS aircraft for services now performed by other 

means at considerable greater risk to human life. As demonstrated below, the FAA can allow these 

benefits to be realized without compromising its obligation to promote the highest level of aviation 

safety.

Respectfully submitted,

 

Julio Jo, VP

 Veracity Maintenance

julio.jo@chronicleuas.com

 469-396-5127

EXHIBIT A

VERACITY MAINTENANCE's – EXEMPTION REQUEST

Veracity Maintenance requests an exemption from the following regulations of the Federal 

Aviation Administration:

Veracity Maintenance is willing to include any markings that may be required by the FAA in 

connection with its commercial UAS operations, with the understanding that the surface area of the 

XBOW, Raptor , and Atlas will not permit lettering that is larger than one inch in height
1. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 C.F.R. § 91.203: Civil Aircraft: Certifications Required

Under 14 C.F.R. § 91.203, all U.S.-registered aircraft are required to have a certificate of 

airworthiness issued by the FAA. Part 21, Subpart H of the FAA’s regulations establishes the procedural 

requirements for the issuance of airworthiness certificates by the FAA. 

Equivalent level of safety analysis: The strict operational limitations under which Veracity Maintenance

will conduct flights for commercial UAS applications (e.g., daylight operations, use of Class G airspace, all 

flights within line-of-sight of the operator) are at least as restrictive as the limitations that apply to the 

operation of limited or restricted category, experimental or provisionally-certificated aircraft. The 

Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas do not carry a pilot or any other passengers 

and their small size reduce the danger that any collisions with the ground or structures will involve 

anything more than the loss of the UAS aircraft. Autonomous programming, that upon loss of the 

uplink with its ground control station, will guarantee the aircraft will return to its preprogrammed 

"Home" waypoint and eliminates the potential for “fly away” incidents. Veracity Maintenance will follow 

the rules also outlined in the NPRM 107.13 for the restrictions on guarantying the airworthiness of the 

aircraft before operations. 

2. 14 C.F.R. § 61.133(a): Commercial Pilot Privileges and Limitations

FAA regulations generally require that an aircraft may engage in operations for compensation or 

hire only if it is flown by a person holding a commercial pilot certificate. 14 C.F.R. § 61.133(a). Veracity 

Maintenance submits that hands-on experience with the flight characteristics of the XBOW, Raptor, and 

Atlas aircraft generally are a far more effective guarantee of flight safety than a commercial pilot 

certificate would be in connection with Veracity Maintenance's proposed commercial UAS program.

Equivalent level of safety analysis. A joystick / tablet / Ipad operated UAS, such as the Inspire 1, 

Phantom 2, Phantom 3, XBOW, Raptor, and Atlas have flight characteristics substantially different from 

a manned aircraft. The propulsion system and control surfaces on the Inspire 1, Phantom 2, Phantom 3,

XBOW, Raptor, and Atlas respond to inputs that are transmitted remotely from either a joystick / laptop 

/ or Ipad located on the control station. A commercially licensed pilot would need to “unlearn” the 

principles of flying a manned aircraft in order to successfully operate the Inspire 1, Phantom 2, Phantom 

3, XBOW, Raptor, and Atlas . Whereas, an operator who had done all of his or her “flying” on the Inspire 

1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas , with no previous flight experience with manned 

aircraft, would know no other type of aviation but would be intimately familiar with the maneuvering of 

the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas UAS.
Veracity Maintenance therefore emphasizes UAS training (both simulator and actual) and flight 

experience for those employees who will operate the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, 

and Atlas for commercial services. A Veracity Maintenance operator will not be able to fill the role of an 

operator of Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, or Atlas commercial services until 

successfully completing a minimum of 15 hours of UAS training flights (45 twenty-minute flights). 

Currency flights will also be required of operators who have exceeded a 90 day window with no logged 

flight hours, for a minimum of 1 hour as either actual flight, or as a recorded and logged simulator flight.

The above-listed hours will be recorded in ASA-SP-30 pilot logbooks subject to inspection by FAA 

personnel at any time.

By requiring extensive flight experience with the Inspire 1,Phantom 2, Phantom 3, XBOW,

Raptor, and Atlas prior to conducting commercial operations, Veracity Maintenance operators will have 

a better grasp of the handling of that aircraft and the EP's (emergency procedures) in the event of an 

emergency than they would by holding a commercial pilot certificate for an entirely different type of 

aircraft.

Veracity Maintenance will conduct extensive simulator training and flight training for each of its 

Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas operators. Simulator training is in addition 

to the hands-on training experience required of each Veracity Maintenance operator prior to conducting 

commercial operations with the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas aircraft. The 

amount of training – under simulator conditions and hands-on flight experience – that Veracity 

Maintenance operators must successfully complete before conducting commercial UAS services 

provides a level of experience specific to UAS flight operations that cannot be duplicated merely by 

holding a commercial pilot certificate. The Veracity Maintenance operators of the Inspire 1, Phantom 2, 

Phantom 3, XBOW, Raptor, and Atlas will be better qualified to conduct UAS flights than a 

commercially-licensed pilot, who has never operated a UAS aircraft, and is unfamiliar with its flight 

characteristics.

In addition to UAS operational experience and simulator flight training, Veracity Maintenance

operators will also be required that before becoming a UAS operator he / she must complete an FAAapproved private pilot ground instruction course and have successfully passed the FAA Private Pilot 

written examination or an FAA-recognized equivalent. Operators of Veracity Maintenance aircraft will 

therefore receive instruction in aeronautical navigation, meteorology and aviation regulations prior to 

conducting commercial UAS operations.

3. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.

Veracity Maintenance will follow the guidelines outlined in the NPRM 107.13 and NPRM 107.15 

for the matters of Airworthiness unless otherwise guided by the FAA.
4. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual, Marking and Placard Requirements.

This regulation requires that an approved flight manual, manual material, markings, placards or 

some combination thereof be placed onboard the aircraft. Neither Inspire 1, Phantom 2, Phantom 3, 

XBOW, Raptor, or Atlas have a configuration suitable for compliance with this requirement.

Equivalent level of safety analysis. The Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas are 

linked to a computer that serves as the ground control station and/or a pilot control box. The 

instruction manual for the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas will be on hand 

so as to be referenced by the operator if needed, in much the same way that pilots of commercial 

airliners are able to access flight manuals on tablet devices. All manual material, markings and placards 

relevant to the operation of the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas can be 

displayed on the screen of the computer that serves as the ground control station, as required. The 

instruction manuals for the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas will therefore be 

just as accessible as a flight manual carried onboard a commercial aircraft.

5. 14 C.F.R. § 91.109(a) and 14 C.F.R. § 91.109(c): Flight Instruction: Simulated 

Instrument Flight and Certain Flight Tests.

Under this regulation, aircraft used for training purposes must have dual flight controls, subject 

to certain exceptions. FAA regulations also require that whenever training is provided in a simulator, 

the simulator must have a second control seat occupied by a safety pilot who possesses at least a 

private pilot certificate with category and class ratings appropriate to the aircraft being flown. Neither 

Veracity Maintenance's aircraft nor the simulator used by Veracity Maintenance for flight training 

purposes complies with these FAA requirements.

Equivalent level of safety analysis. Veracity Maintenance has developed an extensive flight instruction 

training program for its Operators who will conduct commercial UAS operations. Flight instruction is 

provided through Veracity Maintenance and consists of ground instruction and flight training. Further 

training will be conducted with a computer flight simulator with a review of operator skills on a monthly 

basis. Pilots will be required to perform frequent training flights and currency flights, at either an FAAapproved field or on Veracity Maintenance property with suitable objects for pilots to navigate to and 

around in a simulated commercial inspection environment.

All training operations of the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas will be 

observed by a UAS operator Supervisor and will be able to observe all operator training by standing or 

sitting next to the computer that is used as the control station. Similarly, as flight simulations of the 

Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas also are displayed on a computer screen, a 

Veracity Maintenance operator with a high level of UAS flight experience is able to sit next to the 

operator and directly observe all phases of simulator training. In this manner, Veracity Maintenance will 
be able to satisfy the FAA’s interest in having simulator training observed by a highly-experienced 

operator.

The requirement for dual flight controls on an aircraft used for training purposes will be 

followed during actual flight training at a FAA approved Field or Veracity Maintenance property. 

6. 14 C.F.R. 91.119: Minimum Safe Altitudes: General

This regulation specifies the minimum altitude in various flight environments below which 

aircraft are not allowed to operate. Veracity Maintenance will conduct the commercial services it 

proposes below the FAA-specified maximum of 500 feet AGL and not any closer to vessels and 

structures than the minimum separation of 500 feet mandated by the FAA.

Equivalent level of safety analysis. The operation of the Inspire 1, XBOW, Raptor, and Atlas exclusively 

in Class G airspace (i.e., below 500 feet) is intended as a safety measure to provide a level of separation 

between commercial UAS operations and the operation of manned aircraft at altitudes above 500 feet 

AGL. Therefore, limiting the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas to flights below 

the 500 foot AGL maximum will enhance safety rather than compromise it. Veracity Maintenance will 

need to operate the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas closer than 500 feet to 

structures in order to conduct the inspections that will comprise the majority of Veracity Maintenance's 

commercial UAS services. However, Veracity Maintenance has flight procedures that include the 

company’s own requirements regarding the minimum level of separation between the Inspire 1, 

Phantom 2, Phantom 3, XBOW, Raptor, and Atlas and any nearby structures or facilities. In addition, the 

risk of damage to any nearby structures or facilities is reduced by the Inspire 1, Phantom 2, Phantom 3, 

XBOW, Raptor, and Atlas's small dimensions and the use of lightweight materials in their construction.

7. 14 C.F.R. § 91.121: Altimeter Settings

Pursuant to this regulation, an aircraft that is operating below 18,000 feet above Mean Sea Level 

must contain an altimeter that is set to one of several designated altimeter settings prior to departure. 

Neither the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, or Atlas includes an altimeter.

Equivalent level of safety analysis: The operation of the Inspire 1, Phantom 2, Phantom 3, XBOW, 

Raptor, and Atlas aircraft exclusively in Class G airspace (i.e., below 500 feet) away from commercial 

traffic and ATC-controlled airspace reduces the need for an altimeter onboard the Inspire 1, Phantom 2, 

Phantom 3, XBOW, Raptor, and Atlas aircraft. The altitude of the Inspire 1, Phantom 2, Phantom 3,

XBOW, Raptor, and Atlas aircraft above Mean Sea Level and its GPS coordinates will be displayed on the 

screen of the remote ground control station used by the Veracity Maintenance operator to perform any 

commercial services. The operator will have continuous situational awareness of the UAS altitude and 

position, as flight operations will be conducted under line-of-sight flight procedures. 

8. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions.

FAA regulations require that a rotorcraft operating under VFR conditions have sufficient fuel to 

fly to the first point of intended landing and, assuming normal cruising speed, to fly for at least an 

additional 20 minutes.
Equivalent level of safety analysis. Veracity Maintenance will follow the guidelines set forth in the 

NPRM 107. 49(a)(4) requiring a small UAS to have a minimum of 5 minutes of reserve left after 

completion of the mission.

9. 14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Aircraft Maintenance and 

Inspections; Maintenance Records.

FAA regulations impose various requirements regarding the maintenance of civil aircraft, 

including periodic inspections, approval for return to service by a qualified mechanic following 

maintenance or repair, an airworthiness inspection and certain rules concerning maintenance 

recordkeeping. Veracity Maintenance's maintenance of its Inspire 1, Phantom 2, Phantom 3, XBOW, 

Raptor, and Atlas aircraft will not satisfy these requirements.

Equivalent level of safety analysis. Veracity Maintenance will maintain the Inspire 1, Phantom 2, 

Phantom 3, XBOW, Raptor, and Atlas in accordance with the manuals and operating handbook provided 

by the manufacturer. Because of the Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas's small 

size and lightweight construction, Veracity Maintenance will be able to subject it to an extensive 

examination after every flight. All pre and post-flight maintenance, equipment failures, charge cycle 

logs, fault/repair logs, inspections and general maintenance records will be kept on file for a minimum 

of five years. Veracity Maintenance has developed a lengthy pre/post-flight checklist; any aircraft which 

is unable to meet all the requirements for safe operation will be removed from service immediately and 

will not return to service until any defects have been repaired. Moreover, if mechanical issues arise, the 

Inspire 1, Phantom 2, Phantom 3, XBOW, Raptor, and Atlas can land immediately as they will be 

operating at an altitude no higher than 500 feet.

The manufacturers periodically update parts and firmware and software for these UAS aircraft. 

Each time a UAS is tested in the office, checks for the most recent stable software issued by the 

manufacturer will be performed. If any parts have been updated by the manufacturer, Veracity 

Maintenance will immediately place them on order to ensure its UAS aircraft have the most updated 

equipment and software. 

The number of hours that a UAS is in operation will be logged by Veracity Maintenance to 

ensure proper life of components as well as the flight packs that provide power. Once a Veracity 

Maintenance aircraft has been removed from service its unique ID and serial number will not be reissued.