Any PIC operating our UAS will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), 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. The PIC will also have accumulated and logged a minimum of 5 hours as 

a UAS pilot operating the same make and model of UAS to be used for operations. In addition to the 

hour requirements, the PIC will accomplish 3 take-offs and landings in the preceding 90 days (for 

currency purposes) prior to any flight. 

Specific Exemptions Requested 

Given the size, weight, speed, and limited operating area associated with the UA, we feel an 

exemption from 14 CFR part 21, Subpart H(Airworthiness Certificates) and § 

91.203(a) and (b) (Certifications required), subject to certain conditions and limitations, 

is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and 

Section 333 of P.L. 112-95 (Section 333). 

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. Regardless of this, we can mark the UAS in the largest possible lettering by placing the 

word "Experimental" on its fuselage as required by § 45.29(f) so that anyone will see the markings. 

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an 

airworthiness certificate, since there is currently no certificate applicable to our operation, this 

regulation is inapplicable. 

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, 

as a safety precaution we will perform a preflight inspection of the UAS before each flight as outlined 

in the attached operating documents. 

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board the aircraft and given its size, this 

regulation is inapplicable. We believe an equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the UAS ground station. 

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil 

aircraft, but it allows helicopters to be operated at lower altitudes in certain conditions. We will not 

operate our UAS above the altitude of 300 feet above ground level (AGL) and will also only operate in 

safe areas away from the public and traffic, thus "providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes." Given the size, weight, maneuverability, and 

speed of the UAS, an equivalent or higher level of safety will be achieved. 

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the 

UAS utilizes electronic GPS with a barometric sensor. 

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. 

The UAV is 100% electric and two low battery alerts are issued - per the operating documents, the 

UAV will be landed at the first alert. Also, our flights will last only 5-10 minutes each, and the UAS has 

an automated function, which results in immediate landing when a low battery is detected. The PIC