Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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Andrew Maroudas - Section 333 Exemption Petition 

May 27, 2015 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE

Washington, DC 20590-0001 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

Dear Sir or Madam: 

I, Andrew Maroudas, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and 14 C.F.R. Part 11 to request an exemption of the above referenced FARs to allow operation 

of a small ultra-lightweight unmanned aircraft system (UAS) for commercial purposes in the 

National Airspace System (NAS) regulated by the FAA. 

The applicant, Andrew Maroudas, is a licensed FAA Private Pilot (License Number 465894202). 

As described more fully, the granting of this exemption request would permit the operation of a 

small UAS for the main purpose of providing low altitude aerial photography/videography in the 

South Florida area to the general public, government, educational groups and to individuals for 

Real Estate and personal uses. Additionally, we request that we be allowed to use our system to 

benefit governmental first responders nearby who might require assistance, including fire 

fighters, rescue personnel, law enforcement agencies, and federal agencies, et al., while 

remaining subject to all limitations cited in this application as we do so.

Additionally, granting this exemption request would fulfill the Secretary of Transportation's 

FAA Administrator's responsibilities to "... establish requirements for the safe operation of such 

aircraft systems in the National Airspace System" under Section 333(c) of the Reform Act. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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I. Contact Information: 

Andrew Maroudas

6233 Osprey Ter

Coconut Creek, FL 33073

954-531-0591

amaroudas@hotmail.com

II. Regulations from which exemption is requested: 

14 CFR Part 21, 14 CFR 45.23(b), 14 CFR 61.113(a); 61.113(b), 14 CFR 91.7(a); 91.9(b)(2); 

91.103(b), 14 CFR 91.109; 91.119; 91.12l, 14 CFR 91.151(a); 91.203(a) & (b), 14 CFR Subpart 

E (91.405(a); 91.407(a)(l), 14 CFR Subpart E (91.409(a)(2); 91.417(a) & (b)), and FAA Policy

8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(l) (See addendum)

III. Extent of Relief and Reason: 

I am asking for the FAA to grant the amount of relief from each regulation as is deemed 

appropriate for the safe operation of the small UAS and inclusion into the NAS. 

The reason for the exemption request is because it is currently unlawful to fly UAS's in the NAS 

for commercial purposes thereby denying the general public the advantages associated with their 

use. 

IV. Benefit to the Public as a Whole: 

Aerial photography/videography has been around for a long time through manned fixed wing 

aircraft and helicopters. Manned fixed wing aircraft and helicopters are expensive to operate and 

to hire. Many people and businesses cannot afford the high cost of manned aircraft 

photography/videography. UAS operations allow for people and businesses to be able to utilize 

aerial photography/videography under a much smaller budget. Low-level oblique photos and 

video from several angles are far more effective than ground based imagery for displaying the 

characteristics of large, complex properties with several buildings and large trees. The benefits 

of reduced cost and improved quality of presentation from the U A will be valuable to and 

benefit many buyers and sellers of real property.

Congress has already proclaimed that it is in the public's interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. The lightweight 

UAS is battery powered and creates no emissions that can harm the environment. The 

consequences of an ultra-light weight UAS crashing is far less than a full size helicopter or fixed 

wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation 

to the public. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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V. This Exemption would increase safety due to the fact that all Flight Safety and 

Operational requirements as designated by the FAA will be complied with. The UA, 

powered by batteries, is smaller, lighter, requires no fuel, and is more maneuverable than larger 

aircraft running on combustible fuel. It operates at lower altitudes with no people on board, and 

will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 25 

minutes, with maximum air speed of 30 knots, this offers little or no risk to national security.

1) Operations will be conducted using DJI Phantom 2 VISION.

• A lightweight (maximum gross weight of 3 pounds), electric motors powered by batteries and 

operated with four rotors in the form of a quad-copter that takes off and lands vertically, 

manufactured by DJI.

• An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller; 

• A stock DJI digital camera capable of capturing imagery in the form of full color, high 

definition still photos and video; 

• A stock DJI on-board telemetry system that delivers flight data from the on-board flight 

computer to the stock DJI on-board radio transmitter including altitude AGL, airspeed, compass 

direction of flight and direction back to its launch site; 

• A stock DJI on-board radio transmitter that transmits live video from the on-board camera plus 

all the flight data from the telemetry system described above; 

2) The UA may not be flown at an indicated airspeed exceeding 30 knots. 

3) The UA must be operated at an altitude of no more than 300 feet above ground level (AGL), 

as indicated by the procedures specified in the operating documents. All altitudes reported to 

ATC must be in feet AGL. 

4) The UA must be operated within visual line of sight (VLOS) of the Pilot In Command (PIC) 

at all times. This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 

5) All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the 

VO can perform the functions prescribed in the operating documents. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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6) The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between 

the conditions and limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator's responsibility to track 

such revisions and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if he petitions for extension or 

amendment to the grant of exemption. If the operator determines that any update or revision 

would affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. 

7) Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the UAS, the UAS is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC 

who conducts the functional test flight must make an entry in the aircraft records. 

9) The pre-flight inspection section in the operating documents must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

10) The operator must follow the UAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

11) The operator must carry out its maintenance, inspections, and record keeping requirements, 

in accordance with the operating documents. Maintenance, inspection, and alterations must be 

noted in the aircraft records, including total flight hours, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

12) Each UAS operated under the exemption must comply with all manufacturer Safety 

Bulletins. 

13) The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

14) UAS operations must be conducted by a PIC possessing at least a private pilot certificate and 

at least a current third-class medical certificate. The PIC must also meet the flight review 

requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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15) Prior to operations conducted for the purpose of aerial photography/videography and 

augmenting real estate listing videos (or similar operations), the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 

Prior documented flight experience that was obtained in compliance with applicable regulations 

may satisfy this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. However, said 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 CFR 91.119. 

16) Prior to operations conducted for the purpose of aerial photography/videography and 

augmenting real estate listing videos (or similar operations), the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 5 hours as UAS pilot 

operating the make and model of the UAS to be used in operations under the exemption; 5 hours 

make and model time may be included in the 10 hours of multi-rotor time prescribed above. The 

PIC must accomplish 3 take-offs and landings in the preceding 90 days (for currency purposes). 

Training, proficiency, experience-building, and take-off and landing currency flights can be 

conducted under this grant of exemption to accomplish the required flight time and 90 day

currency. However, said training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights the PIC is required to 

operate the UA with appropriate distances in accordance with 14 CFR 91.119. 

17) The operator may not permit the PIC to operate the UAS for the purpose of aerial 

photography/videography and augmenting real estate listing videos (or similar operations), 

unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 61.51(b), the 

ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

18} UAS operations may not be conducted during night, as defined in 14 CFR 1.1. All 

operations must be conducted under visual meteorological conditions (VMC}. 

19) The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart. 

20) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibility is less than 3 statute miles from the PIC. 

21) If the UA loses communications or loses its GPS signal, it must return to a pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

22) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

6

23) The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 30% battery power remaining. 

24) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOT AM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. 

25) AII aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

26) Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

27) The documents required under 14 CFR 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

28) The UA must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

29) The UAS may not be operated by the PIC from any moving device or vehicle. 

30) The UA may not be operated over congested or densely populated areas. 

31) Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles 

or structures where the owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and; c. Operations nearer to the 

PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons 

per§ 91.119(a). 

32) AII operations shall be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from land 

owner/controller or authorized representative will be obtained for each flight to be conducted. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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33) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

Unless otherwise specified in the grant of exemption the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts

45, 47, 61, and 91. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. Please contact me at any time if you require additional information or 

clarification. I look forward to working with your office.

Thank you,

Andrew Maroudas

6233 Osprey Ter

Coconut Creek, FL 33073

954-531-0591

amaroudas@hotmail.com
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I request an exemption from the following regulations as well as any additional regulations that 

may technically apply to the operation of the UAS System: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 

21.191 Experimental certificates. 

Experimental certificates are issued for the following purposes: 

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, 

new aircraft installations, new aircraft operating techniques, or new uses for aircraft. 

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance 

of type and supplemental type certificates, flights to substantiate major design changes, and 

flights to show compliance with the function and reliability requirements of the regulations. 

Section 45.23(b) prescribes that 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 letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Section 61.113(a) and (b) prescribes that

(a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft 

that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for 

determining whether that aircraft is in condition for safe flight and that the PIC shall discontinue 

the flight when un-airworthy mechanical, electrical, or structural conditions occur. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

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Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in 

the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. 

Section 91.1 03(b) prescribes that a pilot shall for any flight, become familiar with runway

lengths at airports of intended use, and takeoff and landing distance information. 

Section 91.1 09(a) prescribes, in pertinent part, 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. 

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may

operate an aircraft below the following altitudes: 

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section. 

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set available within 100 NM of the aircraft "... to the 

elevation of the departure airport or an appropriate altimeter setting available before departure." 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR 

conditions unless 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. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

10

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it 

has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. 

registration certificate issued to its owner or, for operation within the United States, the second 

copy of the Aircraft registration Application as provided for in § 4 7.31(c). 

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless 

the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

At a maximum gross weight of 5.3 pounds, the UA is too small to carry documentation, does not 

have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent 

level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for 

this aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that 

aircraft inspected as prescribed in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired 

as prescribed in part 43 of the chapter. 

Section 91.407(a)(l) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under§ 43.7 of the same chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this chapter. 

Section 91.417(a) and (b) prescribes, in pertinent part, that

(a) Each registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 1 00-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

11

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by§ 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service. 

Concluding, the Phantom 2 Vision aircraft (UA) will not carry persons or property, will not carry

fuel, and will only fly under strict operational requirements. Combined with the UA's light

weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at 

least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. 

If an airworthiness certificate is not appropriate for this application, then we request an 

exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in 

general, citing the equivalent level of safety. 
Andrew Maroudas 954-531-0591

6233 Osprey Ter, Coconut Creek, FL 33073 amaroudas@hotmail.com

12

The UA is battery operated, and the maximum duration of flight from a single battery charge is 

25 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4 NM from the point 

of intended landing, a full battery charge at launch will ensure that we meet the reserve energy

requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy". 

It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in 

an airworthy condition prior to every flight and in addition conduct detailed inspections after 

every two hours of flight. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, 

checking electrical connections and updating software and firmware for the on-board computer. 

All other maintenance will be performed by the manufacturer or designated repair facility. The 

PIC will document work performed in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

The UA maximum gross weight is 3.0 pounds and the PIC is not on board. Both the PIC and the 

VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become 

medically incapacitated while the aircraft is in flight, the UA will return autonomously to the site 

of launching and land without crew intervention. 

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial 

pilot carrying passengers in a large aircraft is an unnecessary burden. 

The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in 

order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement 

above takeoff point is transmitted via radio from UA on-board computer to a display screen held 

by the PIC, providing a constant updated AGL readout. 

We propose that the minimum medical requirements for the PIC and VO to be in possession of a 

valid state issued driver's license. A licensed driver is medically qualified to operate a much 

larger vehicle.