Laymon

International LLC

Laymon International LLC 

Airworthiness Exemption Petition 

Supporting Information 

April 6, 2015 

Exploration, Mining and Minerals 

Import/Export

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Contents

l Operations Plan Summary 4

2 Information Supporting Petition 5

2.1 Petitioner’s Contact Information 5 

 2.2 Laymon International’s Operations Plan 5 

 2.2.1 sUAS System Description 6 

 2.2.2 Flight Conditions 6 

 2.3.2 Flight Operations 6 

 2.3 Privacy 7 

 2.4 Aircraft Safety 7 

 2.5 Public Safety 10

3 Special Exemption Requests 10

3.1 14 CFR 21(h) Airworthiness Certificates 10 

 

 3.2 14 CFR 43.7 Persons authorized to approve aircraft, airframes, 10 

 aircraft engines, propellers, appliances, or component 

 parts for return to service after maintenance, 

 preventative maintenance, rebuilding,or alteration 

 

 3.3 14 CFR 43.11 Content, form, disposition of records for inspections 10 

 conducted under parts 91 and 125 and 135.411(a)(1) 

 and 135.419 of this chapter 

 3.4 14 CFR 45.11 Marking of products 10 

 3.5 14 CFR 45.21 General 11 

 3.6 14 CFR 45.23 Display of marks; general 11 

 3.7 14 CFR 45.25 Location of marks on fixed wing aircraft 11 

 3.8 14 CFR 45.27 Location of marks on non fixed wing aircraft 11 

 3.9 14 CFR 45.29 Size marks 11 

 3.10 14 CFR 47.3(b)(2) Registration required 11 

 3.11 14 CFR 47.31(c) Application 11 

 

 

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3 Special Exemption Requests Continued...

3.12 14 CFR 61.113 Private Pilot Privileges and Limitations: 11 

 Pilot in Command 

 

3.13 14 CFR 91.7(a) Civil aircraft airworthiness 12 

 3.14 14 CFR 91.9(b)(c) Civil aircraft flight manual, markings, and placard 12 

 requirements 

 3.15 14 CFR 91.103(b)(2) Preflight action 12 

 3.16 14 CFR 91.105 Flight crew members at stations 12 

 3.17 14 CFR 91.109 Flight instructions, Simulated instrument flight 12 

 and certain flight tests 

 3.18 14 CFR 91.119(b)(c) Minimum safe altitudes: General 12 

 3.19 14 CFR 91.121 Altimeter readings 13 

 3.20 14 CFR 91.151 Fuel requirements for flight in VFR conditions 13 

 3.21 14 CFR 91.203(a)(b) Civil aircraft: Certification required 13 

 3.22 14 CFR 91.215 ATC Transponder and Altitude Reporting 13 

 Equipment and Use 

 3.23 14 CFR 91.405(a)(d) Maintenance Required 13 

 3.24 14 CFR 91.407 Operation after maintenance, preventive 13 

 maintenance, rebuilding, or alteration 

 3.25 14 CFR 91.409 Inspections 14 

 3.26 14 CFR 91.417 Maintenance records 14

List of Attachments:

 Attachment 1: DJI Inspire 1 Users Manual Version 1.0 

 Attachment 2: DJI Inspire 1 Safety Guidelines Version 1.0 

 Attachment 3: DJI Intelligent Flight Battery Safety Guidelines Version 1.0 

 Attachment 4: DJI Inspire 1 Maintenance Manual Version 1.0 

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1. Laymon International LLC Operations Plan Summary

TABLE 1: Operations Plan Summary

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Overview Laymon International LLC will operate a sUAS 

for mineral prospecting, data collection, 

mapping, and real property photography.

Applicant seeks an exemption from the 

following rules as outlined in 14 CFR Part ll

14 CFR 21(h); 14 CFR 43.7; 14 CFR 43.11; 14 

CFR 45.11; 14 CFR 45.21; 14 CFR 45.23; 14 

CFR 45.25; 14 CFR 45.27; 14 CFR 45.29; 14 

CFR 47.3(b)(2); 14 CFR 47.31(c); 14 CFR 

61.113; 14 CFR 91.7(a); 14 CFR 91.9(b)(c); 14 

CFR 91.103(b)(2); 14 CFR 91.105; 14 CFR 

91.109; 14 CFR 91.119(b)(c); 14 CFR 91.121; 

14 CFR 91.151; 14 CFR 91.203(a)(b); 14 CFR 

91.215; 14 CFR 91.405(a)(d); 14 CFR 91.407; 

14 CFR 91.409; and 14 CFR 91.417 

Aircraft Description sUAS used will be a DJI Inspire 1 weighing less 

than seven (7) pounds with max speed of 43 

knots

Flight Conditions All photogrammetry of mining claims as well as 

real property data collection, photography and 

exploration operations will be conducted under 

VFR, below 400 feet AGL and within 1500 feet 

laterally of the pilot. Flight ground speeds will 

be held to no more than 43 knots.

Flight Areas of Operation All flights will safely operate over private or 

publicly held lands that are over 5 nautical miles 

from airports, in class G airspace, and in 

accordance with all federal, state, and local 

laws.

Method for See and Avoid Pilot in command (PIC) will operate within a 

visual line of sight VLOS capability. PIC and VO 

will communicate verbally at all times.

Lost-Link and Flight Recovery In the rare event of lost-link, the DJI Inspire is 

pre-programmed for a safe designated return to 

home base controlled landing area.

Pilot Qualifications Laymon International veteran sUAS PIC’s are 

experienced in all areas of operations and flight 

training with the aircraft flown, as described in 

petitioner’s flight operations.

Inspection, Maintenance,Training, and Safety All Safety Management Systems, Maintenance, 

Inspection, and Training will be carried out as 

described in Laymon International’s Operations 

Manual and (attachments 1,2,3,4).
2. Information Supporting Petition

2.1 Petitioner’s Contact Information

Laymon International LLC 

 21143 Hawthorne Blvd. #418 

 Torrance, California 90503 

 Tel: 310-463-1259 

 Email: thomas_laymon@laymoninternational.com

2.2 Laymon International LLC Operations Plan

2.2.1 sUAS System Description

The approved exemption will permit the flight operation of a sUAS based on the DJI 

 Inspire 1 unmanned quad rotor aircraft. The complete flight ready aircraft weighs less 

 than seven (7) pounds with a max airspeed of 43 knots. Flight telemetry includes 

 altitude, flight speed, battery condition, and distance from home point. Return to 

 home point for radio loss of link is also integrated. 

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Table 2: Aircraft Specifications

Model T600 (DJI Inspire 1)

Weight (Battery Included) 2935 g

Hovering Accuracy (GPS Mode) Vertical: 0.5 m Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s Yaw: 150°/s

Max Tilt Angle 35°

Max Ascent Speed 5 m/s

Max Descent Speed 4 m/s

Max Speed 22 m/s (no wind)

Max Flight Altitude 4500 m

Max Wind Speed Resistance 10 m/s

Max Flight Time Approximately 18 minutes

Motor Model DJI 3510

Dimensions 438x451x301 mm

Table 3: Controller Specifications

Operating Frequency 5.725~5.825 GHz / 2.400~2.483 GHz

Battery 6000 mAh LiPo 2S

Transmitting Distance 2 km
2.2.2 Flight Conditions

The sUAS will at all times fly within 1500 feet lateral to the PIC. Altitude will be no higher 

 than 400 feet AGL. Flight ground speeds shall not exceed 43 knots. All flights will be 

 within class G airspace and beyond 5 nautical miles of any airport. All flights will be day 

 time only, in the visual-line-of-sight and operated only during days of clear visibility and 

 low wind conditions. 

 Data Collection and photogrammetric flights of mining claims and real properties will be 

 done in very remote areas of Federal Bureau of Land Management lands in addition to 

 privately held property. Photo and video data will also be taken of potential mineral 

 prospect locations deemed too dangerous for full sized aircraft, to determine the value of 

 a more detailed exploration. 

 All flights will occur in potential mining and real property locations in the western states of 

 California,Nevada, Utah, Arizona, and Colorado. 

2.2.3 Flight Operations

All locations will be strictly controlled for access by only the PIC, observer and 

 other relevant safety personnel. The PIC will have 100+ hours of logged sUAS 

 experience and the observer/spotter will be an equally qualified sUAS pilot. 

 Airspace assessment must be completed both prior to preflight and again just prior 

 to take off. Flight planning for each flight includes obtaining any regulatory 

 permission, land-use permissions, preforming a risk assessment, and map study of 

 planned flight area. Observer and support ground crew members will secure 

 planned and alternate operating zones, establishing communications, and 

 identifying emergency contingencies.

The standard pre-flight check list and procedures are as follows:

1) The flight battery and transmitter battery must be fully charged.

 2) Always turn on the transmitter first and then the Quadcopter Multi-Rotor.

 3) Check for visible damage such as loose screws, broken, unbalanced or 

 damaged propellers, faulty connectors or solder joints, landing gear, etc.

 4) The propellers must be in a good condition and securely mounted. 

 5) The rotors must spin smoothly. Must ensure that there are no objects are in the 

 rotational plane of the propellers or within a distance that poses a risk of 

 obstruction.

 

 6) Confirm the appropriate audible beeps when switched on for GPS calibration 

 and communications link, and directional and battery charge lighting are on. 

 7) Ensure that the selected channel on the remote control is free and within range 

 of the transmitter.

 

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 8) Ensure the sensors are calibrated (when the motors are off move yaw and 

 throttle stick into upper left corner until it beeps).

 9) Check gimbal and camera functions. 

 10) After starting the motors, check that all motors are running and rotate evenly. 

 Initiate takeoff at a low altitude and confirm all flight controls and telemetry 

 are functioning normally. 

 During Flight:

1) Maintain visual line of sight with aircraft at all times. 

 2) Confirm aircraft altitude is no greater than 400 feet AGL at all times. 

 3) Confirm aircraft is within 1500 lateral feet of PIC at all times. 

 4) Keep ground speeds under 43 knots at all times. 

 5) Confirm all planned flight path airspace is free of all obstacles. 

 6) Monitor battery life and properly land sUAS within 25% battery life remaining. 

 7) Flight times shall never exceed 15 minutes in length. 

 8) If the sUAS loses communications or loses its GPS signal, the UAS will be 

 returned to the pre-determined location within the Security Perimeter and 

 land.

 9) Land in designated and controlled landing zone and properly power down 

 aircraft and transmitter. 

 Note: Additional safety guidelines are found in (attachments 1,2,3) 

2.3 Privacy

Due to the extreme remoteness of proposed flight locations there is little concern 

 flights will cause invasions of privacy. All flights will occur over controlled access of 

 both public or private property with prior property owners consent. Consent will be 

 secured in situations where privacy could become a concern. 

2.4 Aircraft Safety

Laymon International LLC agrees to be bound by the following operational conditions 

 while conducting commercial operations and that these limitations provide for an 

 equivalent or higher level of safety under the current regulations: 

 1) The sUAS must weigh 7 pounds or less including energy source(s). 

 2) The sUAS must be flown at a ground speed not exceeding 43 knots. 

 

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 3) Flights must be operated at an altitude not to exceed 400 feet above ground 

 level (AGL). Altitude must be reported in feet AGL. 

 4) The sUAS must be operated within a visual line of sight (VLOS) of the PIC and 

 visual observer (VO) at all times. The PIC must be able to use vision unaided 

 by any device other than corrective lens as specified on the PIC’s U. S. 

 drivers license. 

 5) All operations must utilize a visual observer. The VO will NOT take the place 

 of the PIC in maintaining VLOS capability. The PIC and VO must be able to 

 verbally communicate at all times. The PIC will confirm that the VO can 

 perform the duties required of a VO. 

 6) The Operators manual and grant of exemption will be made available to the 

 administrator upon request. The operator must follow the procedures as 

 outlined in the operator’s manual unless a discrepancy exists between the 

 conditions and limitations of the exemption in which case the conditions and 

 limitations of the exemption will take precedence and must be followed. 

 Operators and safety manuals will be made available during all sUAS flight 

 operations. 

 7) Prior to each flight the PIC must inspect the sUAS 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 aircraft is prohibited from operating until the 

 necessary maintenance has been performed and the sUAS is found to be in 

 a condition for safe flight. The Ground Control Station, if utilized, must be 

 included in the preflight inspection. All maintenance and alterations must be 

 properly documented in the aircraft records.

 8) The sUAS must NOT undergo any maintenance or alterations that affect the 

			 sUAS operation or flight characteristics, e.g., replacement of a flight critical 

			 component.

	 	 9) The operator must follow the manufacturer’s UAS aircraft/component, 

			 maintenance, overhaul, replacement, inspection, and life limit requirements.

	 	 10) Regarding distance from non-participating persons, the operator must ensure 

			 that no persons are allowed within 500 feet of the area except those consenting 

			 to be involved and necessary for insuring safety.

	 	 11) If the sUAS loses communications or loses its GPS signal, the sUAS must return 

			 to a pre-determined location within the security perimeter and land or be 

			 recovered in accordance with the operator’s manual (attachment 1). 

	 	 12) The sUAS must abort the flight in the event of unpredicted obstacles or 

			 emergencies in accordance with the operator’s manual (attachment1,2). 

	 	 13) Each sUAS flight operation must be completed within 15 minutes flight time or 

			 with 25% battery power remaining, whichever occurs first.

	 	

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	 	 14) All sUAS operated in accordance with an exemption must be identified by serial 

			 number, registered in accordance with 14 CFR part 47, and have an 

			 identification (N Number) markings in accordance with 14 CFR part 45, Subpart 

			 C. Markings must be as large as practicable.

	 	 15) Any sUAS operated must comply with all manufacturer Safety Bulletins.

	 	 16) The sUAS must remain clear and yield the right of way to all other manned 

			 operations and activities at all times. 

	 	 17) Operation of sUAS must not be conducted during night. All operations must be 

			 conducted under visual meteorological conditions (VMC).

	 	 18) The sUAS must not operate in Class B, C, or D airspace. The UA may not 

			 operate within 5 nautical miles of the geographic center of a non-towered airport. 

	 	 19) The PIC will only be permitted to operate after demonstrating the ability to 

			 operate in a safe manner including evasive and emergency maneuvers and 

			 maintaining proper distances from all structures, people, vessels, and vehicles. 

			 Dedicated training only sessions will take place to ensure the proficiency and 

			 experience of the PIC and will be done so with the appropriate distance from 

			 non participants. 

	 	 20) The sUAS may not be operated less than 500 feet below or less than 2000 feet 

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

			 PIC. 

	 	 21) If the sUAS loses communications or loses its GPS signal, the sUAS must return 

			 to a predetermined controlled landing area. 

	 	 22) The PIC is prohibited from beginning a flight unless given the weather, the sUAS 

			 has enough power to conduct its operation and have a minimum reserve power 

			 for five minutes flight time. 

	 	 23) The sUAS will display all assigned registration and identification numbers and 

			 markings as large as practical and in accordance with applicable CFR’s. 

	 	 24) The sUAS will not be operated from any moving vehicle or device. 

	 	 25) All operations shall be conducted over private or controlled property with 

			 permission from the property owner or authorized representative for each flight. 

	 	 26) NTSB will be notified within 24 hours of any incident, accident, or flight 

			 transgresses of lateral or vertical boundaries. 

	 	

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	 	 2.5 Public Safety

		


	 	 The safety achieved using an unmanned aircraft with no passengers or crew, 

 weighing considerable less than a full sized aircraft, and carrying no flammable fuel 

 load, operating under the flight conditions outlined in section 2.4, Aircraft Safety, would 

 be in the public interest. In addition, using a sUAS would reduce risk of injury to 

 personnel mapping and prospecting in remote areas where natural hazards such as 

 cliffs, ledges, ravines, and other natural obstacles commonly occur. 

 

3. Special Exemption Requests

3.1 14 CFR 21(h): Airworthiness Certificates

Laymon International LLC requests an exemption from 14 CFR 21(h). Based on the 

 light weight, minimal size, reduced speed, and use in controlled remote areas this 

 exemption meets the requirements for an equivalent level of safety as outlined in 

 Section 333. 

 

3.2 14 CFR 43.7: Persons authorized to approve aircraft, airframes, aircraft 

 engines, propellers, appliances, or component parts for return to 

 service after maintenance, preventative maintenance, 

 rebuilding,or alteration

Laymon International LLC requests an exemption from 14 CFR 43.7 Given the 

 sUAS is more similar to a model aircraft all inspections will be done as 

 recommended by the manufacturer. All repairs other than simple propeller changes 

 will be done by the manufacturer or one of their authorized repair centers. 

 Maintenance will be preformed as outline in the manufacturer’s maintenance 

 guidelines (attachment 4). All maintenance and repair will meet the requirements 

 for the equivalent level of safety pursuant to section 33 given the intended use and 

 remote location of the sUAS. 

3.3 14 CFR 43.11: Content, form, disposition of records for inspections conducted 

 under parts 91 and 125 and 135.411(a)(1) and 135.419 of this 

 chapter

 Laymon International LLC requests an exemption from 14 CFR 43.11. Currently the 

 FAA has not certified any inspections for sUAS and due to its size there is no room 

 for maintenance placards. Maintenance records will be kept on file by Laymon 

 International LLC. 

 

3.4 14 CFR 45.11: Marking of products

Laymon International LLC requests an exemption from 14 CFR 45.11. Due to it’s 

 small size and flight characteristics, fireproof placards would cause a potential 

 hazard to the aircraft with the additional weight or location. 

 

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3.5 14 CFR 45.21: General

 Laymon International LLC requests an exemption from 14 CFR 45.21. The FAA 

 currently has no registration procedures for sUASs however if a registration number 

 can be assigned, placement on the aircraft will be done in the most practical and 

 visible means available. 

3.6 14 CFR 45.23: Display of marks; general

 Laymon International LLC requests an exemption from 14 CFR 45.23. Due to the 

 small size of the sUAS full size aircraft marks are not feasible. If a designation is 

 assigned by the FAA, Laymon International LLC will place assigned designation 

 marks on the aircraft in the most practical and visible manner available. 

3.7 14 CFR 45.25: Location of marks on fixed wing aircraft

 Laymon International LLC requests an exemption from 14 CFR 45.25. The sUAS is 

 a multi rotor aircraft and does not possess fix wings and as such 14 CFR 45.25 is 

 inapplicable. 

3.8 14 CFR 45.27: Location of marks on non fixed wing aircraft

Laymon International LLC requests an exemption from 14 CFR 45.27. Due to the 

 sUASs small size it has no cabin, fuselage, boom, or tail. 

3.9 14 CFR 45.29: Size of Marks

 Laymon International LLC requests an exemption from 14 CFR 45.29. Due to size 

 constraints of the aircraft this requirement cannot be met. However with approval of 

 an exemption an aircraft mark will be affixed in the most practical locations. 

3.10 14 CFR 47.3(b)(2): Registration required

 Laymon International LLC requests an exemption from 14 CFR 47.3(b)(2). The FAA 

 currently has no procedures for registration of an sUAS. If a registration number is 

 assigned by the FAA, Laymon International LLC will place assigned designation 

 marks on the aircraft in the most practical and visible manner available. 

3.11 14 CFR 47.31(c): Application

 Laymon International LLC requests an exemption from 14 CFR 47.3(c). Currently 

 compliance for 14 CFR 47.31(c) is not possible since the FAA does not yet have 

 procedures to register sUAS. 

3.12 14 CFR 61.113: Private Pilot Privileges and Limitations: Pilot in Command

Laymon International LLC requests an exemption from 14 CFR 61.113. The PIC of 

 the sUAS does not possess a commercial or private pilots license. 

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 However, the proposed use of an unmanned aircraft with no passengers or crew, 

 weighing considerable less than a full sized aircraft, and carrying no flammable fuel 

 load, operating in remote areas, using a skilled sUAS PIC, will achieve the 

 equivalent level of safety of current operations by manned aircraft with a private 

 pilots license. 

3.13 14 CFR 91.7(a): Civil aircraft airworthiness

 Laymon International LLC requests an exemption from 14 CFR 91.7(a). Given the 

 rules of operation and maintenance listed above, an equivalent level of safety can be 

 achieved since no standard of air worthiness currently exists and no air worthiness 

 certificate can be issued. 

3.14 14 CFR 91.9(b)(c): Civil aircraft flight manual, markings, and placard 

 requirements

Laymon International LLC requests an exemption from 14 CFR 91.9(b)(c). There is 

 no method for approval of sUAS manuals currently, there is no place to carry such a 

 manual on board the aircraft, and no pilot on board to reference it. The flight manual 

 must however be kept at the ground control location for PIC reference. As referenced 

 earlier due to the aircraft small size full sized marking are not possible. With an 

 exemption the proper marking can however be prominently place on the sUAS in the 

 most visible manner. 

3.15 14 CFR 91.103(b)(2): Preflight action

Laymon International LLC requests an exemption from 14 CFR 91.103(b)(2). Since

 all flights are to be carried out 5 nautical miles from any airport and only in class G 

 airspace CFR 91.103(b)(2) does not apply. However, preflight operations will take 

 place with approval of an exemption. 

3.16 14 CFR 91.105: Flight crew members at stations

Laymon International LLC requests an exemption from 14 CFR 91.105 as there will 

 be no crew members aboard the sUAS.

3.17 14 CFR 91.109: Flight instructions, Simulated instrument flight and certain 

 flight tests

Laymon International LLC requests an exemption from 14 CFR 91.109. Remote 

 controlled sUAS are designed or constructed without dual controls. The equivalent 

 level of safety is provided by the limited size, speed, weight, and altitude of the 

 aircraft in addition to no pilot or crew aboard the aircraft. 

3.18 14 CFR 91.119(b)(c): Minimum safe altitudes: General

Laymon International LLC requests an exemption from 14 CFR 91.119(b)(c). 

 Laymon International LLC will operate the sUAS at an altitude not to exceed 400 feet 

 AGL for safety. With the sUAS’s small size and weight an equivalent level of safety to 

 manned flight can be maintained while flying closer than 500 feet from structures 

 and the ground. 

 

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3.19 14 CFR 91.121: Altimeter readings

Laymon International LLC requests an exemption from 14 CFR 14 CFR 91.121. The 

 sUAS being flown will have live feedback of altimeter and will maintain an altitude 

 below 400 feet AGL at all times. With PIC and VO using line of sight operation and 

 telemetry, equivalent safety levels will be met. 

3.20 14 CFR 91.151: Fuel requirements for flight in VFR conditions

 Laymon International LLC requests an exemption from 14 CFR 91.151. Petitioner 

 believes that an equivalent level of safety can be met by limiting flight times of the 

 sUAS to 15 minutes or until 25% battery charge remains whichever is greater. Due to 

 the limited flight times of a sUAS it is not possible to comply with Part 91.151. 

3.21 14 CFR 91.203(a)(b): Civil aircraft: Certification required

Laymon International LLC requests an exemption from 14 CFR 91.203(a)(b). 

 Currently there are no FAA procedures for providing an air worthiness certificate. 

 With the automatic return to home feature, in the rare event of a radio control link 

 disruption, the reduced speed, distance of flight, light weight, and 400 feet. AGL 

 altitude limit, and no on board flight crew will combine to provide a greater degree of 

 safety to the public than conventional flight operations with air worthiness 

 certificates. 

3.22 14 CFR 91.215: ATC Transponder and Altitude Reporting Equipment and Use

 

 Laymon International LLC requests an exemption from 14 CFR 91.215. ATC 

 transponders are not commercially available in a size and weight that can be affixed 

 to the sUAS and be flown safely. Given the flight operation parameters, their will be 

 no need for air traffic control communication and a request for exemption is 

 requested for CFR 91.215. 

3.23 14 CFR 91.405(a)(d): Maintenance Required

Laymon International LLC requests an exemption from 14 CFR 91.405(a)(d). Since 

 sUAS will be flown without passengers and these sections concern inspection 

 requirements for passengers, Laymon International LLC requests an exemption. As 

 noted earlier placard placement on the small form factor of an sUAS is not practical 

 and also should be exempted. Log books detailing repairs and maintenance will 

 be keep on file.

3.24 14 CFR 91.407: Operation after maintenance, preventive maintenance, 

 rebuilding, or alteration

 

 Laymon International LLC requests an exemption from 14 CFR 91.407. To achieve 

 an equivalent level of safety Laymon International LLC will follow the maintenance 

 requirements outlined in the DJI maintenance manual (attachment 4) as well as 

 maintain detailed inspection and maintenance records. 

 

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3.25 14 CFR 91.409: Inspections

 Laymon International LLC requests an exemption from 14 CFR 91.409. This 

 section is applicable more for large manned aircraft with longer flight times than that 

 of an sUAS. Laymon International LLC believes that the pre and post flight 

 inspections outlined in Section 2.2.3 above will meet the equivalent level of safety 

 required. 

3.26 14 CFR 91.417: Maintenance records

Laymon International LLC requests an exemption from 14 CFR 91.417 as it 

 pertains to aircraft with an air worthiness certificate. To achieve an equivalent level 

 of safety Laymon International LLC will keep all maintenance records and a 

 complete listing of parts replaced. 

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