WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

July 15, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue SE 

Washington, DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012

Dear Sir or Madam,

This petition is being submitted on our behalf without legal counsel or consulting services.

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (Reform Act) and 14 C.F.R. Part 11, GRADD CO. (Global Robot And 

Drone Deployment), an operator of Small Unmanned Aircraft Systems (sUAS), hereby applies 

for an exemption from Federal Aviation Regulations (FARs) identified below, to allow 

commercial operations of sUAS.

The proposed operations include the following:

• Aerial Photography and Videography

• Aerial Surveying

• Agriculture

• Bridge Inspection

• Construction Site Inspection and Monitoring

• Data Acquisition

• Education and Research

• Flare Stack Inspection

• Pipeline Inspection and Patrolling

• Public Entity Support Operations

• Utility and Power Generation Systems Inspections and Patrolling

• Wildlife and Forestry Monitoring

As described more fully below, the requested exemption would permit the operation of sUAS 

under controlled conditions in airspace that is limited, predetermined, and controlled as to access. 

Approval of this exemption will have many benefits to the industries listed above, as technical 

and inherently dangerous operations can be performed in a safer and more controlled manner by 

sUAS and their operators. Additionally, sUAS will provide economic benefit to these industries 

by improving efficiency and quality, and virtually eliminating human risk.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

The name and address of the applicant is:

Company Name: GRADD CO. (Global Robot And Drone Deployment)

Owner Name: Reza Karamooz

Address: 2900 Meade Avenue, Suite #1

Las Vegas, NV 89102

Phone: 702-879-9100

Email: info@gradd.co

Regulations from which the exemption is requested:

• 14 CFR Part 21, Subpart H – Airworthiness Certificates

• 14 CFR 45.23 (b) – Aircraft Marking

• 14 CFR 61.113 (a) – Pilot in Command

• 14 CFR 91.7 (a) – Civil Aircraft Airworthiness

• 14 CFR 91.9 (b) (2) – Document/Flight Manuals

• 14 CFR 91.103 – Preflight Action

• 14 CFR 91.109 – Flight Instruction

• 14 CFR 91.119 – Minimum Safe Altitude

• 14 CFR 91.121 – Altimeter Setting

• 14 CFR 91.151 (a) (1) – Fuel Requirements for VFR Flight

• 14 CFR 91.203 (a) & (b) – Civil Aircraft: Certifications Required

• 14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b) – Maintenance and Maintenance 

Inspections

The extent of relief for each section or sections of 14 CFR are outlined in Appendix A.

The requested exemption would authorize GRADD to operate the DJI Inspire 1, DJI Phantom 1, 

DJI Phantom 2 Vision +, DJI Phantom 3, DJI S900, and DJI S1000+ for the proposed operations. 

All sUAS flights utilizing the list of sUAS will be conducted over private or controlled access 

property with the knowledge and consent of the property owner. When persons are found in 

photos or videography, a reasonable effort will be made to identify and notify persons, and their 

photos/footage used only with their consent. The commercial operations of GRADD will adhere 

to strict operating requirements and conditions to ensure an equivalent standard level of safety to 

currently authorized operations using manned aircraft.

In addition, GRADD will adhere to a modified Model Aircraft Operating Standards, outlined 

below:

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and 

will operate at sites that are ‘sufficient distance’ from populated areas within the sterile 

area described in the Flight Operations Procedure Manual. Such operations will ensure 

that the sUAS will “not create a hazard to users of the national airspace system or the 

public.”
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

• When flying the sUAS within three (3) miles of an airport, airport operators will be 

notified and the operator will give the right-of-way to avoid flying in the proximity of full 

scale aircraft.

• Maximum flight time for each operation will be 60 minutes.

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve 

flight time to safely land the sUAS.

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 

feet AGL.

• Minimum crew for each operation shall consist of a sUAS pilot and a visual sUAS 

observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including all payload 

(e.g., sensors, camera, lens, and stabilized gimbal).

• The sUAS will operate at speeds of no more than 87 knots (100 mph), can hover, and 

can simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which it 

will operate, GRADD’s operations adhere to the Reform Act’s safety requirements.

Current options for the listed applications, which under this exemption would be performed 

using sUAS, may include use of ladders, lifts, and manned aircraft. Use of ladders and lifts are 

inherently dangerous and result in numerous injuries each year. Use of manned aircraft is not 

always practical or feasible. In most cases, use of a sUAS is quicker and easier than any other 

alternative and often yields better results.

Due to their small size and the fact that they carry no fuel, all models of the DJI UAS proposed 

in the exemption pose a very low risk of damage to persons or structures on the ground. Because 

these sUAS are electric powered, they create no harmful emissions and make very little noise 

(compared to traditional aircraft).

Under the requested exemption, GRADD will ensure all operators have completed sUAS 

education and training programs including all applicable regulations and guidance documents; 

including aeronautical background information such as Charts, NOTAMS and Aircraft Circulars; 

Radio Communications Procedures; Human Factors and Crew Resource Management; Basic 

sUAS Aerodynamics; Weather factors; Airmanship and Decisionmaking and Safe Operations 

Procedures. In addition to the sUAS education and training programs, GRADD ensures the 

Operator in Command (OIC) has a minimum of a FAA Private Pilot License.

We respectively request exemption under Section 333 to enable GRADD to operate efficient, 

limited, low-risk commercial sUAS operations for the activities stated respecting at all times the 

space and privacy of citizens and property while keeping airspace safe.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

Summary the FAA may publish in the Federal Register

GRADD seeks an exemption from the following Regulations: 14 CFR Part 21, Subpart H; 14 

CFR 45.23 (b); 14 CFR 61.113 (a); 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 

CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) and 14 CFR 91.417 (a) & (b) to 

commercially operate its small unmanned aircraft systems to support a variety of industry and 

business applications, to include, but not limited to, Aerial Photography and Videography, Aerial

Surveying, Agriculture, Bridge Inspection, Construction Site Inspection and Monitoring, Data 

Acquisition, Education and Research, Flare Stack Inspection, Pipeline Inspection and Patrolling, 

Public Entity Support Operations, Utility and Power Generation Systems Inspections and 

Patrolling, and Wildlife and Forestry Monitoring. Granting GRADD’s request for exemption will 

reduce current risk levels and thereby enhance safety.

Further, GRADD sUAS will operate at lower altitudes (up to 400 feet AGL) in predetermined 

and controlled airspace, weigh less than 55 pounds, and will travel at speeds less than 87 knots 

(100 mph). They will provide at least an equivalent level of safety as that achieved under current 

Federal Aviation Regulations.

GRADD respectfully requests that the Federal Aviation Administration (FAA) grant its 

exemption request without delay. The FAA has the authority to issue the exemption sought by 

GRADD pursuant to the Federal Aviation Act, 85 P.L.726 (1958).

Sincerely Requested,

Reza Karamooz

President & CEO

GRADD CO.

2900 Meade Ave. Suite #1

Las Vegas, NV 89102

702-879-9100

Document prepared by:

Stephen Hong Daniel Wang

Technical Research Director Lead Test Engineer

stephen@gradd.co daniel@gradd.co

702-879-5525 702-879-8835
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

APPENDIX A: Justification of Requested Exemptions in Title 14 CFR

14 CFR Part 21, Subpart H – Airworthiness Certificates

The procedural requirements for the issuance of airworthiness certificates as required by 

14 C.F.R. § 91.203 (a) (1).

Given the small size of the sUAS, the controlled operating areas, limitations and conditions, 

GRADD will adhere to during flight operations, 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” 

with consideration “of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS.”

The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from 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 UAS 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 rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed.

The UAS to be operated are less than 55 lbs. fully loaded, carry neither a pilot nor passenger, 

carry no explosive materials or flammable liquid fuels, and will operate exclusively within a 

secured and designated area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by the operator pursuant to the Manual’s requirements. The 

FAA will have advance notice of all operations. These safety enhancements provide 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. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the UAS, 

due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

14 CFR 45.23 (b) – Aircraft Marking

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.

An exemption will be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the word “Experimental” can be placed. Given the size of the UAS, two-inch 

lettering may not be possible. 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 UAS 

marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the UAS will see the identification of the UAS as “Experimental.”

14 CFR 61.113 (a) – Pilot in Command

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds 

a private pilot certificate may act as 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.

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have 

only a private pilot’s license rather than a commercial pilot’s license to operate a sUAS. The 

risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR 61.

14 CFR 91.7 (a) – Civil Aircraft Airworthiness

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

Inasmuch as there will be no airworthiness certificate issued for the UAS, GRADD seeks an 

exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition 

to be operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the 

extent that the requirements of Part 21 are waived or found inapplicable. See Grant of Exemption 

to Astraeus Aerial, Docket No. FAA-2014-0352 at 13-14, 22. Accordingly, Petitioner requests 

that the requirements for § 91.7(a) be treated in accordance with Section V(A), supra. D. 1
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

14 CFR 91.9 (b) (2) – Document/Flight Manuals

(b) 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 there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof.

Given the small size and configuration of the UAS, it would be impossible to keep airworthiness 

documents and other aircraft manuals on board the UAS, because there is simply no room and 

the UAS has no cabin or cockpit.

14 CFR 91.103 – Preflight Action

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned 

flight cannot be completed, and any known traffic delays of which the pilot in 

command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following 

takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the 

takeoff and landing distance data contained therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature.

GRADD seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar 

with specific information before each flight, including information contained in the FAAapproved Flight Manual on board the aircraft. While the PIC will be familiar with all information 

necessary to safely conduct the flight, an exemption is requested to the extent that an FAAapproved Flight Manual is required.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

14 CFR 91.109 – Flight Instruction

(a) 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. 

However, instrument flight instruction may be given in an airplane that is equipped with 

a single, functioning throwover control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and

(2) The person manipulating the controls has at least a private pilot certificate 

with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throwover control wheel that controls 

the elevator and ailerons, in place of fixed, dual controls may be used for flight 

instruction to conduct a flight review required by §61.56 of this chapter, or to obtain 

recent flight experience or an instrument proficiency check required by §61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in 

command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the 

airplane, meets the requirements of §61.195(b), and has logged at least 25 hours 

of pilot-in-command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be 

conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a 

private pilot certificate with category and class ratings appropriate to the aircraft 

being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, 

or a competent observer in the aircraft adequately supplements the vision of the 

safety pilot; and

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with 

fully functioning dual controls. However, simulated instrument flight may be 

conducted in a single-engine airplane, equipped with a single, functioning, 

throwover control wheel, in place of fixed, dual controls of the elevator and 

ailerons, when—

(i) The safety pilot has determined that the flight can be conducted safely; 

and

(ii) The person manipulating the controls has at least a private pilot 

certificate with appropriate category and class ratings.

(d) No person may operate a civil aircraft that is being used for a flight test for an airline 

transport pilot certificate or a class or type rating on that certificate, or for a part 121 

proficiency flight test, unless the pilot seated at the controls, other than the pilot being 

checked, is fully qualified to act as pilot in command of the aircraft.

GRADD seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o 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." UASs and remotely 
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is 

accomplished through the use of a device that communicates with the aircraft via radio 

communications. Accordingly, an exemption will be required for the flight instruction 

requirements of 14 C.F.R. § 91.109(a).

14 CFR 91.119 – Minimum Safe Altitude

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.

GRADD requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because in order to perform the intended operations, the UAS will need 

to be operated lower than 400 feet AGL. Further, due to the nature of the proposed operations, 

persons involved in the flight may be closer than 500 feet.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

14 CFR 91.121 – Altimeter Setting

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available before 

departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

(b) The lowest usable flight level is determined by the atmospheric pressure in the area of 

operation as shown in the following table:

Current altimeter setting Lowest usable flight level

29.92 (or higher) 180

29.91 through 29.42 185

29.41 through 28.92 190

28.91 through 28.42 195

28.41 through 27.92 200

27.91 through 27.42 205

27.41 through 26.92 210

(c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum 

flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet 

and add the appropriate number of feet specified below, according to the current 

reported altimeter setting:

Current altimeter setting Adjustment factor

29.92 (or higher) None

29.91 through 29.42 500

29.41 through 28.92 1,000

28.91 through 28.42 1,500

28.41 through 27.92 2,000

27.91 through 27.42 2,500

27.41 through 26.92 3,000
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

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 operator, pursuant to the Manual and Safety Checklist, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151 (a) (1) – Fuel Requirements for VFR Flight

No person may begin 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; ...

Here, the technological limitations on UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption 

from the fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

14 CFR 91.203 (a) & (b) – Civil Aircraft: Certifications Required

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, 

a copy of the applicable operations specifications issued under §21.197(c) of this 

chapter, appropriate sections of the air carrier manual required by parts 121 and 

135 of this chapter containing that portion of the operations specifications issued 

under §21.197(c), or an authorization under §91.611) must have on it the 

registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special 

identification number, that has been affixed to an aircraft, may only be obtained 

upon application to an FAA Flight Standards district office.

(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 §47.31(c), or a registration certification issued under the laws 

of a foreign country.

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

paragraph (a) of this section 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.

Sections 91.203(a) and (b) requires all civil aircraft to have within them an appropriate and 

current airworthiness certificate and an effective U.S. registration certificate issued to its owner, 

which are displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

The size of the UAS would not permit carrying these documents, nor does the UAS have a 

cockpit or cabin. Should the exemption to 14 C.F.R. § 91.7(a) (Airworthiness Requirement) 

above, be granted, the display of an airworthiness certificate would become moot.

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the operator flying the UAS will have immediate access to them; to the extent they 

are applicable to the UAS.

14 CFR 91.405 (a); 407 (a) (1); 409 (a); 417 (a) & (b) – Maintenance and Maintenance 

Inspections

91. 405(a) Each owner or operator of an aircraft 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

91.407(a) No person may operate any 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 this chapter

91.409(a) (1)Except as provided in paragraph (c) of this section, no person may operate 

an aircraft unless, within the preceding 12 calendar months, it has had an annual 

inspection in accordance with part 43 of this chapter and has been approved for return to 

service by a person authorized by §43.7 of this chapter; or

(2) Except as provided in paragraph (c) of this section, 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.

91.417(a)Except for work performed in accordance with §§91.411 and 91.413, 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 100-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

(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.
WWW.GRADD.CO | 2900 MEADE AVE. #1 | LAS VEGAS, NV 89102 | 702-879-9100 T | 702-879-9101 F

(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.

91.417 (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.

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) only apply to 

aircraft with an airworthiness certificate, GRADD requests relief from these Sections because the 

UAS does not require an airworthiness certificate. The UAS meets the conditions of Section 333 

for operation without an airworthiness certificate. Accordingly, GRADD will use its trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the manufacturer's maintenance manual and as 

accomplished in the current COAs. Furthermore, GRADD will document and maintain all 

maintenance records for the UAS. GRADD is requesting relief from these sections, Section 

91.203 (a) and (b), 45.23 (b), 21.185 and 91.9(b) also would not apply.