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19 Dec 15
Gregory Bertrand Boylan President Aviation Management Systems, LLC. 3502 Cazador lane Fallbrook, CA 92028 C: (949)584-2437 gaboylan@msn.com

U. S. Department ofTransportation Docket Operations 1200 NewJersey Ave., SE Washington, DC.20590 ,-, - ,- l ;-.. l '

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Subj: AVIATION MANAGEMENT SYSTEMS, LLC.SECTION 333 SUBMISSION TO FM FOR APPLICATIONS/ PETITIONS/EXEMPTIONS AND ANY OTHER ITEMS FOR WHICH A DOCKET DOES NOT EXIST.

Ref: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from 14 C.F.R. 45.23{b); 14CFR Part 21;14 CFR 61.113 (a) 

### &(b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203{a) 

### & {b); 91.405 (a); 91.407{a) (1); 91.409 (a) (2);91.417

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Sir or Mada!Jl,

Pursuant to Section 333 o.f.the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Aviation Management Systems/ LLC., an operatorofSmall Unmanned Aircraft Systems ("sUAS 11 ) equipped to offer on-demand commercial sUAS operationsfor a host of industries and applications. These include: ·

• Aerial search and rescue operational support
• Infrastructure inspection
• Agricultural monitoring and support
• Industrial refinery and manufacturer plant inspection
• Accident/Incident survey and investigative support
• Flare stack inspection
• Private security monitoring

• Utility-powergeneration system inspections.and patrolling

• Pipeline inspection and patrolling.
• Wildlife and forestry monitoring
• Aerial surveying and mapping'

• Construction site inspection and monitoring

• Public Entity Support Operations
• Maritime aerial operations

• Reality and wedding videography and imagery
P_age 1 of 10• sUAS consulting.

Aviation Management Systems, llC. herebyapplies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits sUASs, so long as such operations are conducted within and underthe conditions outlined herein or as may be established bythe FAA as required by Section 333. To include, FAA Certificate of Waiver orAuthorization (COA) that are issued to Aviation Management Systems, llC.

As described below, the requested exemption would permitthe operation ofgreen minded sUASs relatively inexpensively under controlled conditions in the National Airspace System (NAS) that is 1) limited, 2) predetermined, 3) controlled**sU.~S** access and operation, and 4) would provide safety enhancementstothe already safe operations using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary ofTransportation's (the FAA Administrator's) responsibilities to "

...establish requirements for the safe operation of such aircraft systems in the national airspace**system.,~'**..**S~<::.tiPn,3J3{<::LofJ,he.~e{orro** Act,.,",r''**'''""''~**

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The name and address ofthe applicant is:

Aviation Management Systems, LLC. Attn: Gregory Bertrand Boylan 3502 Cazador lane Fallbrook, CA 92028 Ph: (949)584-2437 Email: gaboylan@msn.com
Regulations from which the exemption i:; requested:

14CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14C.F.R. 91.109 14 C.F. 

### R. 91.119 14C.F.R. 

### 91.121

.•

...., 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exemption application is expressly submittedtofulfill**Congress~** goal in passing Section 333(a) through (c) ofthe Reform Act: This lawdirects.the Secretary ofTr.ansportation to consider whether certain unmanned aircraft,systems**mayop€1rate~safely** in the-n.ational airspace system (NAS) before completion ofthe rulemaking requ'jred under.Sectipn:332 ofthe Reform Act, In makingthis



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### determination, the Secretary is required to determine which types of UASs do not create a hazard to
users ofthe NAS orthe public or pose athreat to national security in light ofthefollowing:

• The UAS's size, weight, speed, and operational capability
• Operation ofthe UAS in close proximity to airports and populated areas
• Operation ofthe UAS within visual line ofsight ofthe operator

Reform Act Section 333 (a). lastly, ifthe Secretary determinesthat such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements forthe safe operation ofsuch aircraft in the national airspace system." 

### /d. Section 333(c) (emphasis added) Applicant interpretsthis provision to place the duty on the Administratorto not only process applicationsfor exemptions under Section 333, butfortheAdministratorto craft conditions forthe safe operation ofthe UAS, if it should be determined thatthe conditions set forth herein do notfulfill the statutory requirements forapproval. The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. This statutor1 authority

### by its·terms includes exempting civil aircraft, as theterm is defined under §40101 ofthe Actthat includes SUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement ofa regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthistitle ifthe Administratorfinds the exemption in the public interest. 49 U.S.C. §44701(f) 

### See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Each vehicle operatorshall be certified on each sUAS type before designation as avehicle operator (VO) for each sUAS type. Before Aviation ManagementSystems, LLC. sUAS assets are authorized for autonomous aircrew operational flights; currency and designations shall be maintained and authorized by Aviation Management Systems, LLC. All records for personnel and sUAS shall be made available upon request by an FAA Administrator or law enforcement agency or representative. Preflight and post flight inspections shall be conducted as Standard Operating Procedure (SOP) within Aviation Management Systems, LLC. Incidents/mishapsthat involve injury or damage shall be reported tothe FAA within 10 business days ofthe incident/mishap. A safety mind frame ofeach operator is critical tothe success of the Aviation ManagementSystems, LLC. and shall be grounds fortermination when Safety of Flight (SOF) and overall ground safety is not applied.

Aviation Management Systems, LLC. sUASs are vertical take-offand landing (VTOL) rotary-winged air vehicles (AV) and fixed-wing AV, weighting 55 lbs or less including payload. They oper-ate, under normal conditions at aspeed ofno morethan 87 knots (100 MPH), operation notto exceed manufacturer recommended airspeed, and have the capability to hover and move in thevertical and horizontal plane simultaneously. The sUAS assets will operate only in line ofsight and wilt operate only within a sterile
area. Such operations will insure thatthe sUAS will "not create a hazard to users ofthe national airspace system orthe public."

Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted sterile environment within which they will operate, the applicantfalls squarely within the zone ofsafety (an equivalent level ofsafety) in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations of UASs tocommence immediately. Also, due to the size ofthe UASs and the restricted areas in which the relevant sUASs will operate, approval ofthe application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority
Page 3 of 10contained in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs, the grant ofthe requested exemptions is in the public interest

.. Applicant experience is provided;Jhe owner, a CFII rated aviatorwith over 25 years ofcontinuous CONUS and OCONUS aviation experience. Extensive experience in aviation training and certification requirements in accordance with publishedFAR/AIM.



### AIRCRAFTAND EQUIVALENT LEVEL OF SAFETY

The applicant will operate the following aircraft:

1. DJI Inspire 1 2. DJI Spreading Wings S1000 and S900 3. DJI Phantom 2 4. DJI Phantom 3 5. Aeryon Sky Ranger 6. 3DR X8-M and Solo 7. Prioria Hex and Maveric 8. Hoverfly LiveSky, H-Frame, and BigSky 60 9. Physical Sciences Instant Eye 10. XFold Rig with fourconfigurations: Quadcopter, Hexcopter, Octocopter, and x12 Copter 11. lnovaDrone: lnova One and Eagle One 12. R/C Rotors and Aerial Media.: Matrix Prof. Mutli**Roto~** Frame 

### & Octo Heavy Lift Prof. Multi Rotor Frame Ronin Edition -. 13. Microdrones: MD4-1000 14. Yuneec Tornado H920

. 15. Yuneec Typhoon 0500 Series 16. Swift Radioplanes Lynx M

The applicant proposes thatthe exemption requested herein applyto civil aircraft that have the characteristics and that operate withthe limitations listed herein. These limitations provide for at least
an equivalent oreven higher level ofsafetyto operations underthe current regulatory structure because the proposed operations represent a safety enhancementtothe already safe operations conducted-with conventional.aircraft;. These limitations anp conditions towhich Av.iation Management Systems, LLC. agrees to be bound when conducting commercial operations underan FAA issued exemption include:

1. The sUAS willweigh between 0.55lbs and 551bs. 2. Flights will be operated within visual line ofsight (VLOS) ofavehicle operator (VO) and/orobserver. 3. Maximum total flight time for each operational flight will not exceed the capabilities and limitations ofthe sUAS type operated per manufacture specifications and recommendations

.. Flights will be terminated at no less than 15% battery power reserve during any flight to ensure Safety of Flight (SOF). 4. Day flights will be operated at

## an altitude ofno morethan 400 feet AGL. 5. Range ofoperation and.altitude shall be decreased when operating in' close vicinity of airfields that
are not controlled by airtraffic control (ATC) in .Class G.airspace. Where airfields are controlled by ATC
or otherforms, coordination and permissive operations shall be c.oordinated with the appropriate
Page 4 of 10airspace control authority (ACA), i.e. Class B, Class C, Class, D, and Class Eairspace. Class A airspace shall be avoided. Operation under Class Eairspace and imposing a self-imposed safety buffer below the Class Eairspace shall only be conducted after proper coordination withthe Class Eairspace ACA. Safety buffers shall be reasonable and flights shall be cancelled if-Safety of Flight (SOF) is ever a concern by the ACA or ofthe sUAS VO. 6. Minimum crew for each operation ·will consist ofthe sUAS**vehicl~** operator (VO). ··Ifvisual line-ofsight (VLOS) is an issue during sUAS flight operations, an observer shall be utilized. When operating specific sUAS airvehicles during specific missions, a Payload Operator (PO) shall be a part ofthe aircrew. 7. sUAS VO shall be trained and certified in the sUAS type operating and have visual acuity, correctable by glasses or contacts, of20/20 and not be color blind. 8. sUAS VO shall perform as the Pilot in Command (PIC) duties and be responsible forthe sUAS SOF. Consideration to obstacles, safe launch/recovery area, LOS, sUAS capabilities and limitations, sUAS Operational Brief, pre/postflight operations, and Aviation Management Systems, LLC. imposed airspace control measures and procedures shall be adhered to, i.e. mandatory ascending/descending Elevator Points, Emergency Holding Points, etc. 9. A sUAS flight path shall never be programmed tofly over another sUAS launch/recovery site and/or Ground Control Station (GCS). 10. Multiple sUAS launch/recovery sites shall ensure that sUAS VOs coordinate through positive communication during sUAS operations and shall stagger AV launches and landings to ensure SOF. 11. The sUAS will only operate within an identified confined "Sterile Area" ofthe flight operations area. Area shall be surveyed by the aircrew priorto sUAS operational flight commencement. sUAS operations within the aforementioned operations area shall not commence unless, ifapplicable, required ACA coordination has been completed, agreed upon, and authorized. 12. A sUAS briefshall be conducted in regard tothe day's planned sUAS operations. sUAS Brief shall be conducted before sUAS flight operations commence. The sUAS Brief is mandatory and all participating personnel who will be performing duties within the boundaries ofthe safety perimeter shall be present forthis briefing. 13. The operator shall obtain the consent ofall persons involved and ensure that only consenting persons will be allowed within a safe distance from the sUAS launch/recovery site (GCS) as deemed by· the PIC. 14. sUAS VO shall maintain current proficiency in all sUAS type thatthey are certified with. 15. During all sUAS operations, where an observer is utilized, positive communication shall be maintained between the sUAS VO and the observer. 16. Written and/or oral permission from the relevant property holders shall be obtained. 17. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies**wh~n** applicable. 18. Ifthe sUAS is the subject ofa Loss of Link (LOL) emergency or a GPS Loss emergency, the sUAS will have the capability to return to a pre-determined location within the operating area, i.e. manual control, and/or land safely, i.e. "land immediately" feature or similar. 19. The sUAS will have the capabilityto abort aflight in case of emergencies and the VO shall conduct established Aviation Management Systems, LLC. Emergency Procedures and manufacturer established emergency procedures. 20. All sUAS incidents that involve death, injury, damage to equipment (otherthan the company owned sUAS), and damage to property (otherthan company owned) shall be reported appropriately. 21. "Right ofway" shall always be given to all other manned and unmanned·airvehicles in every scenario and event without exception: Special consideration shall always begranted in every eventthat requires actions that would prevent death of injury ofany person.
Page 5 of 1022. Aviation Management Systems, LLC. shall file a UAS NOTAM in support ofall sUAS Operations on the behalfofthe sUAS VO.



### 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14C.F.R. §91.203 (a) 

### (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated withthe aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)} and Section.333 ofthe Reform Act both authorize the FAAto exempt aircraft (rom the requirementfor an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular UAS. In all cases, an analysis ofthesecriteria demonstratesthatthe sUAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at leastas safe, or safer, than a conventional aircraft (fixed-wing or rotary-wing) operatingwith an airworthiness certificate withoutthe re.strictions.(md c;onditions proposed

..The sUAS,t.o be**operated~·** hereunder is less than 

## SS lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within a safe area as set out in the Manual. Unlike other civil aircraft, operations underthisexemption will be tightly controlled and monitored by boththe operator, pursuant to the Manual's requirements, and underthe requirements and in compliance with local public safety requirements, to provide securityforthe area of operation as is now donewith conventional filming duringfilming services. Security ofthe filming location adds to and provides a greaterdegree ofsafetytothe public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. This type oflocal operations area security is also found within the industrial and manufacturing areas, specific national, state, local, and privately controlledareas, and during local emergenciesthatare supported. Lastly, application ofthese same criteria demonstrates thatthere is nocredible threatto national security posed bythe sUAS, dueto its size, speed ofoperation, location ofoperation, lack ofexplosive materials
orflammable liquid fuels, and inabiiityto carry a substantial external load.



### 14C.F.R. §45.23 (b). Markingofthe Aircraft. The regulation requires:. When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance tothe cabin, cockpit, or pilot station, in !.etters not less than 2 inches
nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the SUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrancetothe cabin, cockpit or pilptstation on which the

. 1 "

- ... . word "Experimental" can be placed. Given the site ofthe sUAV, two-inch letteringwill be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level ofsafetywill be provided by having the SUAV marked on its fuselage as required by §45.29 (f) where the sUAS air vehicle (AV) vehicle operator (VO), AV visual observer; and others working withthe sUAS will see the identification ofthe sUAS as marked appropriatelywith registered aircraft markings. Each Aviation Management Systems, LLC. sUAS air vehicle shall be. registered with the FAA and the FAA aircraft registration number shall be placed on the airvehicle as. directedbythe FAA 14 CFR. The FAA has issued the following exemptionstothis regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

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### 14 C.F.R. §1.113 (a) & 

### (b): Private:Pilot Privileges and Limitations:**P~lot** 

### in Command. Section 61.113 {a) & (b) limit private pilots to non·-comrnercial operations. ·Be.causethe UAS 

### will notcarry a pilot or.
Page 6 oflOpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrentoperations by requiring the PIC operating the aircraft to have a private pilot's license ratherthan a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no livingthing on board. The area ofcperation is**controll~d** and restricted, and all flights are planned and coordinated in advance. The level ofsafety provided bythe requirements included in the Manual exceeds that provided by asingle individual holding a commercial pilot's certificate operating a conventional aircraft. The risks associated with the operation ofthe sUAS
are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested with a private pilot as the PIC exceeds the present level ofsafety achieved by 14 C.F.R. §61.113 (a) 

### & (b).

14C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person mayoperate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Given the size ofthe aircraft and the requirements contained in the Manual for maintenance and use ofsafety check lists priorto each flight, as set forth in Sections 

### (j), {I) and {q), an equivalent level ofsafetywill be provided.

i4C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in theAircraft. Section 91.9 (b) (2) provides: "No person may operate a U.S.-registered civil aircraft

..." (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless it is available in the aircraft, acurrent approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration, has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room orcapacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping theflight manual atthe GCS within the reach ofthe sUAS vehicle operatorf<?r immediate
access. The FAA has issued thefollowing exemptionstothis regulation.: Exemption Nos. 8607, 8737, 8738,9299,9299A,9565,9565B,10167, 10167A, 10602,32827,and10700.

14C.F.R. §91.103: Preflightaction. This regulation requires each pilot in command totake certain actions before flightto insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The sUAS vehicle operatorwill take all actions including reviewing weather, flight battery requirements, launch paths and landing approaches, and aircraft pre-flight check parameters and data before committingto aAV Launch.

14C.F.R. §91.109: Flight instruction. Section 91.103 provides that no person may operate acivil aircraft (except a manned free balloon) that is being used forflight instruction unlessthat aircraft has fully functioning dual controls. sUAS's, and remotely piloted aircraft, bytheirdesign do not have fully functional dual controls. Flight control is accomplished through the use ofthe GCS Hand Controller Unit (HCU) that communicates with the aircraftvia radio communications. The FAA has approved exemptions forflighttraining withoutfully functional dual controlsfora numberofaircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

### 8t 9862A. The equivalent level ofsafety provided by thefact that neithera pilot nor passengers will be carried inthe aircraft and bythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum safe altitudes. Section 91.119 establishes safe altitudes foroperation of civil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, provided the person operating the helicoptercomplies with any route oraltitudes prescribed for
Page 7 of 10helicopters bythe FAA. As this exemption is for a sUAS that is for notonly sUAS fixed-wing AVs, butalso SUAS rotary-winged and the exemption requests authorityto operate at altitudes upto400 AGL, an exemption may be needed to allow such operations. As set forth herein, except forthe limited conditions'stated in the Manual, the sUAS will never operate at higherthan 400 AGL unless authorized by aCOA. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken withoutthe required ACA coordination, permission ofthe property owner or local officials, and other unforeseen requirements that may arise. Due tothe advance noticetothe property ownerand participants in the aerial activity, all affected individuals will be aware ofthe planned sUAS flight operations. Compared toflight operations with aircraft or rotorcraft, weightingfar more than the maximum 551bs. proposed herein and the lack of flammable fuel, any risk associated withthese operations is far less than those presently presented with conventional aircraft operating at or below400AGL other industries. In addition, the low-altitude operations ofthe SUAS will ensure separation between these sUAS operations and the operations of conventional aircraft**th~t** must comply with Section 91.119.

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### 14C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeterthat is set "

...tothe elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the sUAS vehicle operator, pursuanttothe Manual and Safety Check list, confirmingthe altitude ofthe launch/recovery site shown on the GPS altitude indicator before flight.



### 14 C.F.R. §91.151(a}: Fuel Requirements for Flight in VFR Conditions. Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel toflytothefirst point of intended landing, 

### and, assuming normal cruising speed- (1) During the day, tofly afterthatfor at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes." The battery poweringthe sUAS provides set flight endurances for each sUAS type. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be extremely limited or not be able to fly at all. Given the limitations on the sUAS's proposed flight area and the location ofits proposed operations within a predetermined area, a longer timeframe forflight in daylight VFR conditions is reasonable. Applicant believes that

## im exemption from 14CFR §91.151(a) falls within the scope of prior exemptions. 

### See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the sUAS, in atightly controlled area where only people and property owners orofficial representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engenderthetype of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS.

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._ Additionally, limiting sUAS flights to extreme minimum flight time would greatly reduce the utilityfor which the exemption will be granted. Applicant believes that an equivalent level ofsafety can be achieved by limitingflights tothe manufacture'sflight endurance specifications and self-imposing minimum reserve battery life toforce acontrolled landing safely without exceeding the manufacturer's maximum flight endurance specifications. This restriction would be more than adequate to returnthe sUAS to its planned launch/recovery site from anywhere within its limited operating area. Similar exemptions have been granted to otheroperations, including Exemptions 2689F, 5745, 10673, and 10808.



### 14 C.F.R. §91.203 (a) 

### and (b): Carrying Civil Aircraft CertifiCation and Registration. The regulation provides in pertinent part: (a) Except as provided in Se.ction 91.715, no person may '

. . operate a civil aircraft unless it**h~s** within itthefollowing: (1) An appropriate and current airworthiness
Page 8 of 10

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certificate

.... (b) No person may operate acivi(aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or a special flight**aut~odzation** 

### issued under §9L715 is displayed at the cabin or cockpit entrance so that: it is legible to**pa~sengers** 

### or crew

..ThesUAS, fully loaded, weighs no more than 55 lbs, no less than 0.55 lbs, and is operated without an onboard pilot. As such, there is no ability or place to carry certification and

### registrati~ndo!=uments· orto display them on the SUAS. An equivalent level ofsafety will be achieved by keeping these documents atthe GCS where the sUAS vehicle operator operating the AV will have immediate access tothem,**~o** 

### the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 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) 

### & (b): Maintenance Inspections. 

### These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...,"and others shall inspect or maintain the aircraft in compliance with Part 43. Given thatthese sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not applyto the applicant. The operator pursuant tothe flight manual and operating handbook will accomplish maintenance. An equivalent level ofsafety will be achieved due to the nature ofthese sUAS's based on their sized and will carry a small payload and operate only in observed controlled areas for limited periods oftime. If mechanical issues arise, the SUAS can land immediately and will be operating from no higherthan 400 feet AGL unless otherwise authorized through a FAA.COA. The operatorwill ensure that the sUAS is in working order priorto initiatingflight and perform required operator maintenance. Major maintenance events beyond basic operator maintenance shall be re(:orded in the sUAS equipment record jacket maintained by the applicant. Moreover, the vehicle operator is the person mostfamiliar with the aircraft and best suited tci maintain the aircraft in an

### airw~rthy condition to provide the equivalent level ofsafety

.. 

### Summary

Pursuant to 14 C.F.R. Part 11, thefollowing summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & 

### (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151{a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

### & (b) to operate commercially a small unmanned aircraft vehicle (SUAS) (55 lbs. or less). Approval ofexemptions allowing commercial operations ofsUAS's, will enhance safety by reducing risk while operating within the NAS

.. Conventional operations, usingjet or piston power. aircraft, operate at extremely low altitudesjust feet from the subjects being filmed or equipment being inspected and in extreme proximityto people and structures and present the risks associated with vehicles that weigh in the neighborhood of4,000 lbs, carrying large amounts ofJet A, JP-8 or otherfuel. Such aircraft must flyto and from the operational location. In contrast, a sUAS weighing fewerthan 551bs. and powered by batteries eliminates virtually all ofthat risk given by the reduced mass and lack of combustible fuel carried on board. The sUAS is carried tothe operation site and not flown. The SUAS will carry no passengers or crew and, therefore, will not expose them tothe risks associated with manned aircraft flights. The operation ofsUAS's, weighing between 0.55 lbs and 55 lbs, shall be conducted in the strict conditions aforementioned, will provide an equivalent level ofsafety supporting the grant ofthe exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations: These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment; resulting in afar safer airvehicle flight than conventional
Page 9 of 10aircraft operations utilizing combustible fuels and rotating blades operating within close proximitytothe ground, personnel, and equipment during all sUAS operations. Aviation Management Systems, LLC. has every intention to adhere to and comply with established policies, rules, guidelines, and established laws.


### Privacy
Privacy of personnel and property shall be adhered to. No person shall be surveilled unless proper authorization is provided by the appropriate authorizing agency or organization in accordance with established intelligence oversight practices and in compliance with all applicable regulations, orders, publications, and/or policies. All flights will occur over public, private, or controlled access property with the property owner's prior consent and knowledge, unless the area is deemed a public area. Navigational imagery may be used to support incident/mishap reporting as applicable. Only imagery supporting the purpose ofthe sUAS operational flight shall be utilized forthe appropriate purpose. All sUAS operations shali be conducted in consideration tothe direction to government entities set forth in the Presidential Memorandum, Promoting Economic Competitiveness While Safeguarding Privacy, Civil Rights, and Civil Liberties in Domestic Use ofUnmannedAircraftSystems (February 15, 2015}. The grant ofthis exemption request will provide improved safety in sUAS operations. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012--size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security- provide
more than adequate justification forthe grant ofthe requested exemptions allowing commercial operation ofapplicant's commercial and private sUAS.

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