·-

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 of Transportation 

Docket Operations 

1200 New Jersey Ave., SE 

Washington, DC.20590 

,-, - ,- l ;-.. l ' .. 

#~ .. ..~: ~.~ t ',. '. ~:·;,·r~ i "'" < 

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 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. 45.23{b); 14 CFR 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 (a).~ (b):. : ._~f-' -, •. r' . . /~··. . 

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 operator of Small Unmanned Aircraft 

Systems ("sUAS11

) equipped to offer on-demand commercial sUAS operations for 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-power generation 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. hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. To include, FAA Certificate of Waiver or Authorization (COA) that are issued to 

Aviation Management Systems, llC. 

As described below, the requested exemption would permit the operation of green 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 

enhancements to the already safe operations using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation'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'' '''""''~ .,,,n ... ~~·- •.. ., .. _ ... , ... , ,. .. ~ ..... ,. 

The name and address of the 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: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.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 submitted to fulfill Congress~ goal in passing Section 333(a) 

through (c) of the Reform Act: This law directs.the Secretary of Tr.ansportation to consider whether 

certain unmanned aircraft,systems mayop€1rate~safely in the-n.ational airspace system (NAS) before 

completion of the rulemaking requ'jred under.Sectipn :332 of the Reform Act, In making this 

. ,' 

Page 2 of 10 
determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability 

• Operation of the UAS in close proximity to airports and populated areas 

• Operation of the UAS within visual line of sight of the operator 

Reform Act Section 333 (a). lastly, if the Secretary determines that such vehicles "may operate safely in 

the national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." /d. Section 333(c) (emphasis added) 

Applicant interprets this provision to place the duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator to craft conditions for the safe 

operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. The Federal Aviation Act expressly grants the FAA the authority to 

issue exemptions. This statutor1 authority by its ·terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act that includes SUASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds 

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 operator shall be certified on each sUAS type before designation as a vehicle operator (VO) 

for each sUAS type. Before Aviation Management Systems, 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/mishaps that involve injury or damage shall be reported to the FAA within 10 

business days of the incident/mishap. A safety mind frame of each operator is critical to the success of 

the Aviation Management Systems, LLC. and shall be grounds for termination when Safety of Flight 

(SOF) and overall ground safety is not applied. 

Aviation Management Systems, LLC. sUASs are vertical take-off and 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 a speed of no more than 87 knots (100 MPH), operation not to exceed manufacturer 

recommended airspeed, and have the capability to hover and move in the vertical and horizontal plane 

simultaneously. The sUAS assets will operate only in line of sight and wilt operate only within a sterile 

area. Such operations will insure that the sUAS will "not create a hazard to users of the national 

airspace system or the public." 

Reform Act Section 333 (b). Given the small size ofthe sUASs involved and the restricted sterile 

environment within which they will operate, the applicant falls squarely within the zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also, due to the size ofthe UASs and the 

restricted areas in which the relevant sUASs will operate, approval of the application presents no 

national security issue. Given the clear direction in Section 333 of the Reform Act, the authority 

Page 3 of 10 
contained in the Federal Aviation Act, as amended; the strong equivalent level of safety 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 of the 

requested exemptions is in the public interest .. 

Applicant experience is provided;Jhe owner, a CFII rated aviator with over 25 years of continuous 

CONUS and OCONUS aviation experience. Extensive experience in aviation training and certification 

requirements in accordance with publishedFAR/AIM. 

AIRCRAFT AND 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 four configurations: Quad copter, 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 that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe operations 

conducted-with conventional. aircraft;. These limitations anp conditions to which Av.iation Management 

Systems, LLC. agrees to be bound when conducting commercial operations under an FAA issued 

exemption include: 

1. The sUAS will weigh between 0.55lbs and 551bs. 

2. Flights will be operated within visual line of sight (VLOS) of a vehicle operator (VO) and/or observer. 

3. Maximum total flight time for each operational flight will not exceed the capabilities and limitations 

of the 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 of no more than 400 feet AGL. 

5. Range of operation and. altitude shall be decreased when operating in' close vicinity of airfields that 

are not controlled by air traffic control (ATC) in .Class G.airspace. Where airfields are controlled by ATC 

or other forms, coordination and permissive operations shall be c.oordinated with the appropriate 

Page 4 of 10 
airspace control authority (ACA), i.e. Class B, Class C, Class, D, and Class E airspace. Class A airspace shall 

be avoided. Operation under Class E airspace and imposing a self-imposed safety buffer below the Class 

E airspace shall only be conducted after proper coordination with the Class E airspace ACA. Safety 

buffers shall be reasonable and flights shall be cancelled if-Safety of Flight (SOF) is ever a concern by the 

ACA or of the sUAS VO. 

6. Minimum crew for each operation ·will consist of the sUAS vehicl~ operator (VO). ··If visual line-ofsight (VLOS) is an issue during sUAS flight operations, an observer shall be utilized. When operating 

specific sUAS air vehicles during specific missions, a Payload Operator (PO) shall be a part of the aircrew. 

7. sUAS VO shall be trained and certified in the sUAS type operating and have visual acuity, correctable 

by glasses or contacts, of 20/20 and not be color blind. 

8. sUAS VO shall perform as the Pilot in Command (PIC) duties and be responsible for the sUAS SOF. 

Consideration to obstacles, safe launch/recovery area, LOS, sUAS capabilities and limitations, sUAS 

Operational Brief, pre/post flight 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 to fly 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" of the flight operations area. 

Area shall be surveyed by the aircrew prior to sUAS operational flight commencement. sUAS operations 

within the aforementioned operations area shall not commence unless, if applicable, required ACA 

coordination has been completed, agreed upon, and authorized. 

12. A sUAS brief shall be conducted in regard to the 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 of the safety perimeter shall be present 

for this briefing. 

13. The operator shall obtain the consent of all 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 that they 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. If the sUAS is the subject of a 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 capability to abort a flight 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 (other than the company owned 

sUAS), and damage to property (other than company owned) shall be reported appropriately. 

21. "Right of way" shall always be given to all other manned and unmanned· air vehicles in every 

scenario and event without exception: Special consideration shall always begranted in every event that 

requires actions that would prevent death of injury of any person. 

Page 5 of 10 
22. Aviation Management Systems, LLC. shall file a UAS NOT AM in support of all sUAS Operations on 

the behalf of the sUAS VO. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)} and Section.333 ofthe Reform Act both authorize the FAA to 

exempt aircraft (rom the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed-wing or rotary-wing) operating with an 

airworthiness certificate without the 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 or flammable liquid fuels, and operates exclusively within a safe area as set out in the Manual. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by 

both the operator, pursuant to the Manual's requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as is now 

done with conventional filming during filming services. Security of the filming location adds to and 

provides a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. This type of local 

operations area security is also found within the industrial and manufacturing areas, specific national, 

state, local, and privately controlled areas, and during local emergencies that are supported. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security 

posed by the sUAS, due to its size, speed of operation, location ofoperation, lack ofexplosive materials 

or flammable liquid fuels, and inabiiity to carry a substantial external load. 

14 C.F.R. §45.23 (b). Marking of the Aircraft. The regulation requires:. When marks include only the 

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 to the 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 entrance to the cabin, cockpit or pilptstation on which the . 1 " - ... . 

word "Experimental" can be placed. Given the site of the sUAV, two-inch lettering will be impossible. 

The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent 

level of safety will 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 with the 

sUAS will see the identification of the sUAS as marked appropriately with 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 air vehicle as. directed by the FAA 14 CFR. The FAA 

has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A. 

. ',, .• :"'. ~ ... ~ 1 ' 

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 not carry a pilot or. 

Page 6 oflO 
passengers, the proposed operations can achieve the equivalent level of safety of current operations by 

requiring the PIC operating the aircraft to have a private pilot's license rather than 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 living thing on board. The area of cperation is controll~d and 

restricted, and all flights are planned and coordinated in advance. The level of safety provided by the 

requirements included in the Manual exceeds that provided by a single individual holding a commercial 

pilot's certificate operating a conventional aircraft. The risks associated with the operation of the sUAS 

are so diminished from the level of risk associated with commercial operations contemplated by Part 61 

when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds 

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a 

civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the 

aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the Manual for 

maintenance and use of safety check lists prior to each flight, as set forth in Sections (j), {I) and {q), an 

equivalent level of safety will be provided. 

i4 C.F.R. §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 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 of this chapter, unless it is available in the aircraft, a current 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 

or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by 

keeping the flight manual at the GCS within the reach of the sUAS vehicle operator f<?r immediate 

access. The FAA has issued the following exemptions to this regulation.: Exemption Nos. 8607, 8737, 

8738,9299,9299A,9565,9565B,10167, 10167A, 10602,32827,and10700. 

14 C.F.R. §91.103: Preflight action. This regulation requires each pilot in command to take certain 

actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The sUAS vehicle operator will take all actions 

including reviewing weather, flight battery requirements, launch paths and landing approaches, and 

aircraft pre-flight check parameters and data before committing to a AV Launch. 

14 C.F.R. §91.109: Flight instruction. Section 91.103 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. sUAS's, and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Flight control is accomplished through the use of the GCS Hand Controller Unit 

(HCU) that communicates with the aircraft via radio communications. The FAA has approved exemptions 

for flight training without fully functional dual controls for a number of aircraft and for flight instruction 

in experimental aircraft. See Exemption Nos. 5778K 8t 9862A. The equivalent level of safety provided by 

the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the 

aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes. Section 91.119 establishes safe altitudes for operation of 

civil aircraft. Section 91.119 (d) allows helicoptersto be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes prescribed for 

Page 7 of 10 
helicopters by the FAA. As this exemption is for a sUAS that is for not only sUAS fixed-wing AVs, but also 

SUAS rotary-winged and the exemption requests authority to operate at altitudes up to400 AGL, an 

exemption may be needed to allow such operations. As set forth herein, except for the limited 

conditions'stated in the Manual, the sUAS will never operate at higher than 400 AGL unless authorized 

by a COA. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the required ACA coordination, 

permission of the property owner or local officials, and other unforeseen requirements that may arise. 

Due to the advance notice to the property owner and participants in the aerial activity, all affected 

individuals will be aware of the planned sUAS flight operations. Compared to flight operations with 

aircraft or rotorcraft, weighting far more than the maximum 551bs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently presented with 

conventional aircraft operating at or below 400 AGL other industries. In addition, the low-altitude 

operations of the SUAS will ensure separation between these sUAS operations and the operations of 

conventional aircraft th~t must comply with Section 91.119. 

. ·. ~ t t\" .• .• t ,;- ;; ,., . " ~- li· . ... ...- '. "'•"·""! ..... :"\. -· ... 

14 C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set " ... to the elevation of the 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 of safety will be achieved by the sUAS vehicle operator, pursuant to the Manual and Safety Check 

list, confirming the altitude of the 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 to fly to the first point of intended landing, and, 

assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) At 

night, to fly after that for at least 45 minutes." The battery powering the 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 of its proposed operations within a predetermined area, a longer 

time frame for flight in daylight VFR conditions is reasonable. Applicant believes that im exemption 

from 14 CFR §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 a tightly controlled area where only people and property owners or official representatives who have 

signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of 

risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. • . ' ,. .. '" , ' f . ; "" " ·. •F'lo ·~ -" ._ 

Additionally, limiting sUAS flights to extreme minimum flight time would greatly reduce the utility for 

which the exemption will be granted. Applicant believes that an equivalent level of safety can be 

achieved by limiting flights to the manufacture's flight endurance specifications and self-imposing 

minimum reserve battery life to force a controlled landing safely without exceeding the manufacturer's 

maximum flight endurance specifications. This restriction would be more than adequate to return the 

sUAS to its planned launch/recovery site from anywhere within its limited operating area. Similar 

exemptions have been granted to other operations, 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 it the following: (1) An appropriate and current airworthiness 

Page 8 of 10 
'_ ...... ,-·-

certificate .... (b) No person may operate a civi(aircraft unless the airworthiness certificate required by 

paragraph (a) of this 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· or to display them on the SUAS. An 

equivalent level of safety will be achieved by keeping these documents at the GCS where the sUAS 

vehicle operator operating the AV will have immediate access to them, ~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 or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ... ," and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. The operator pursuant to the flight manual and operating handbook will accomplish 

maintenance. An equivalent level of safety will be achieved due to the nature of these sUAS's based on 

their sized and will carry a small payload and operate only in observed controlled areas for limited 

periods of time. If mechanical issues arise, the SUAS can land immediately and will be operating from no 

higher than 400 feet AGL unless otherwise authorized through a FAA. COA. The operator will ensure that 

the sUAS is in working order prior to initiating flight 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 most familiar 

with the aircraft and best suited tci maintain the aircraft in an airw~rthy condition to provide the 

equivalent level of safety .. 

Summary 

Pursuant to 14 C.F.R. Part 11, the following 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; 14 C.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 of exemptions allowing commercial operations of sUAS's, will enhance safety 

by reducing risk while operating within the NAS .. Conventional operations, using jet or piston power. 

aircraft, operate at extremely low altitudes just feet from the subjects being filmed or equipment being 

inspected and in extreme proximity to people and structures and present the risks associated with 

vehicles that weigh in the neighborhood of 4,000 lbs, carrying large amounts of Jet A, JP-8 or other fuel. 

Such aircraft must fly to and from the operational location. In contrast, a sUAS weighing fewer than 

551bs. and powered by batteries eliminates virtually all of that risk given by the reduced mass and lack of 

combustible fuel carried on board. The sUAS is carried to the operation site and not flown. The SUAS 

will carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights. The operation of sUAS's, weighing between 0.55 lbs and 55 lbs, shall be 

conducted in the strict conditions aforementioned, will provide an equivalent level of safety supporting 

the grant of the 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 a far safer air vehicle flight than conventional 

Page 9 of 10 
aircraft operations utilizing combustible fuels and rotating blades operating within close proximity to the 

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 of the sUAS operational flight shall be utilized for the appropriate purpose. All 

sUAS operations shali be conducted in consideration to the direction to government entities set forth in 

the Presidential Memorandum, Promoting Economic Competitiveness While Safeguarding Privacy, Civil 

Rights, and Civil Liberties in Domestic Use of Unmanned Aircraft Systems (February 15, 2015}. The grant 

of this exemption request will provide improved safety in sUAS operations. Satisfaction of the criteria 

provided in Section 333 of the Reform Act of 2012--size, weight, speed, operating capabilities, proximity 

to airports and populated areas and operation within visual line of sight and national security- provide 

more than adequate justification for the grant of the requested exemptions allowing commercial 

operation of applicant's commercial and private sUAS. 

Page 10 of 10 

........