April 25, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Regarding Exemption Request of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Attachments: A) E384 Maintenance Manual

 B) E384 Operations Manual

 C) E384 Training Syllabus

Dear Sir or Madam:

Ryan Nolin, an unmanned aircraft systems (UAS) consultant, and UAS operator, is 

requesting an exemption from the Federal Aviation Regulations listed below pursuant to 

section 333 of the FAA Modernization and Reform Act of 2012. 

The granted exemptions would allow Ryan Nolin to safely and properly operate small 

Unmanned Aircraft Systems (sUAS) for the commercial purpose of precision imaging for 

agricultural, forestry, wildlife management and survey industries. By following the 

procedures outlined in this document and attached appendices or established by the 

FAA, Ryan Nolin believes an equivalent level of safety can be achieved to current Federal 

Aviation Regulations (FARs).

Because the sUAS Ryan Nolin plans to operate (Event 38 E384) weighs less than 10lbs, is 

made of foam, and is electric powered, operations produce less noise, less air pollution 

and congestion in the National Airspace (NAS). These reasons are all in the well being of 

the general public.

Being a sUAS also has the added benefit of reducing risks to personnel and property in 

the air and on the ground. Because flight operations will require consent from 

landowners, operate below 500 feet and operate in a similar fashion to current manned 

aircraft no new privacy issues will arise.

The requested exemption is in the public interest of our nation. By granting this 

exemption Ryan Nolin, the public and surrounding communities will all benefit from 

added economic, environmental and positive sUAS outlook impacts.

Ryan Nolin

439 Lancelot Lane

Lexington, KY 40517

Phone: 802-318-3456

Email: ryan@skyviewcustoms.com
The Specific sections of 14 CFR from which Ryan Nolin seeks exemption:

14 C.F.R Part 21 Subpart H

14 C.F.R 61.113 (a)&(b)

14 C.F.R 91.7 (a)

14 C.F.R 91.151

14 C.F.R 91.405 (a)

14 C.F.R. 91.407 (a)(1)

14 C.F.R. 91.409 (a)(1) & (a)(2)

14 C.F.R 91.417 (a) (b)

Appendix A discusses why each C.F.R is appropriate for exemption, how an equivalent 

level of safety is achieved and how it is in the public’s interest.

Characteristics of the Aircraft: 

Ryan Nolin will operate the E384 fixed wing sUAS, which is manufactured by Event38 of 

Akron, Ohio. The principle construction material for the E384 airframe is EPO foam, 

carbon fiber tail boom with an all up weight (AUW) no greater than 10lbs. The E384 is 

powered by a single lithium polymer battery that drives a single brushless motor. The 

E384 has a maximum flight time of 100 minutes with operating speed of 27 mph. The 

pilot in command (PIC) will communicate with the E384 with a 2.4 ghz remote control 

radio and a 915mhz data telemetry radio connected to a ground control (GC) computer. 

The E384 aircraft has several failsafe systems in place:

 In the event of the loss of remote control (unlikely due to visual line of sight 

(VLOS) operations under 400ft) the E384 will perform a “return to home” 

command.

 In the event of the loss of ground control connection (unlikely due to VLOS 

operations under 400ft) the E384 will perform “return to home” command.

 In the event of a low battery (less than 20%) the E384 will perform a “return to 

home” command.

In addition to the above failsafes, a gps guided “Geofence” will prevent the E384 from 

flying beyond its intended flight path.

Ryan Nolin holds an Airframe and Powerplant certificate (#3474636) and will thus 

perform all E384 maintenance. Maintenance procedures will be followed in accordance 

with Event38 maintenance manuals (attachment A). All maintenance procedures will be 

logged.

Similar aircraft is already approved for operation. See exemption #11166
Proposed procedural and operational standards

Pilot In Command (PIC) and Visual Observer

 As PIC, Ryan Nolin will have at minimum a Sport Pilot’s license.

 A visual observer (VO) will maintain contact with the PIC and be used to ensure 

the E384 remains in VLOS and will fully understand all operating limitations set 

forth in this petition.

 Flights will be conducted during day-light hours and under Visual Flight Rules 

(VFR).

 Flights will be conducted within VLOS of the PIC and VO.

 As PIC, Ryan Nolin will complete Event 38 training for the E384 aircraft in 

accordance with the Event38 training syllabus (attachment C). 

 As PIC, Ryan Nolin will be responsible for all aircraft and preflight inspections.

Flight Operational Limits

 All required permissions/permits from governmental agencies will be obtained 

prior to each flight.

 Permission from relevant property owners will be obtained prior to each 

operation.

 Preflight Safety briefings will be conducted before each flight to discuss potential 

safety hazards and operational boundaries.

 Flight plans will not extend past the 100-minute flight limit of the E384 aircraft.

 All flights will be conducted no more than 400 feet above ground level (AGL) and 

5 miles from any airport.

 All flight operations will be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures.

 Operations over congested areas will be avoided.

 The E384 will take off and land next to the PIC and VO.

 Alternate emergency landing zones will be established during the preflight safety 

briefing.

 The E384 will always give way to manned aircraft.

 A ground control station will always be present in the area of the PIC and VO to 

relay real-time E384 information, such as battery level, altitudes, speeds, 

location and global positioning system (GPS) health.

 Certificates of Approval (COA) will be secured before each flight as required by 

FAA regulations.

 The PIC will abort flights in the event of obstacles or emergencies.

 The E384 aircraft will be registered in accordance with 14CFR Part 47 and have 

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

Markings will be as large as practical.

 All documents used by the operator to ensure safe operation and flight of the 

E384 will be available to the PIC at the ground control station of the sUAS 

anytime the aircraft is operating. 

Safety in the National Airspace and on the ground is the priority for operations. By 

following the above guidelines, in addition to Event 38 Operations Manual (attachment 

B), Ryan Nolin is confident an equal or greater level of safety to current manned aviation 

is achieved. 

See similar operations that have been granted exemptions: #11062, #11109, #11166, #11213, #11379, 

#11285
Appendix A

Specific Sections of 14 CFR from which Ryan Nolin Seeks Exemption

Below are the sections from which Ryan Nolin seeks exemption, with specifics on the 

extent of relief sought, reason for relief, and why exemption would not adversely affect 

safety. 

Part 21 Subpart H – Airworthiness Certification 

Part 21 Subpart H establishes the requirements for the issuance of an airworthiness 

certificate. Ryan Nolin seeks complete exemption from Part 21 Subpart H pursuant with 

Section 333, which authorizes the FAA to exempt a UAS from the requirements of an 

airworthiness certificate based on consideration of the following: size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

VLOS.

An equal level of safety will be achieved with the operational limitations established in 

this document (refer to page 3 of the Event38 Operational limitations (attachment B)) 

for all E384 flights conducted by Ryan Nolin. The E384 sUAS operates with an all up 

weight (AUW) of less than 10lbs and maximum airspeed of 30mph. All flights will occur 

within VLOS of the PIC and VO, at an altitude of 400 ft. AGL or less, and only over 

designated areas. Based on the required standards and limitations the E384 can safely 

operate without creating a hazard to any other aircraft, people, or structures on the 

ground. 

Similar aircraft is already approved for operation. See Exemption #11166

61.113 (a) – Private Pilot Privileges and Limitations; Pilot In Command: Commercial 

Pilot Privileges and Limitations

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Due to its size, weight, and operational limitations the E384 sUAS will not carry any 

persons on board. The proposed operations will not adversely affect safety by requiring 

the PIC of aircraft to have a commercial pilot certificate, as long as they

have passed, at minimum, a sport pilots certification. The safe operation of a sUAS 

benefits more from hands on experience and training in comparison to a commercial 

pilot’s license. Ryan Nolin respectfully states that, since there are no standards for 

either private or commercial UAS pilot certificates, knowledge of airspace regulations 

and dexterity in the control and operation of the UAS acquired from actual operation of 

the aircraft will
be the most important factors in establishing an equivalent level of safety. By following 

the Event38 training syllabus (attachment C) with the E384 sUAS the proper knowledge 

of airmanship can be achieved to maintain safe flight operations.

91. 121 – Altimeter Settings 

91.121 requires aircraft to maintain a cruising level or flight level in reference to a 

current reported altimeter setting. The altitude information on E384 is provided to the 

PIC via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a 

radio communication telemetry data link, which downlinks from the E384 sUAS to the 

GCS for active monitoring of the flight path. 

Also since the E384 will be operating at or below 400 ft. AGL, there is no need to 

maintain hemispherical cruising altitudes for de-confliction with manned aircraft. For 

these reasons Ryan Nolin seeks exemption from this regulation. 

During arming sequence the E384 sets a reference AGL altitude at home locations using 

GPS and barometric pressure sensors. An equal level of safety will be achieved through 

the E384’s GPS and flight control, which provides altitude and location data during flight 

to the PIC via the ground control station. The previous safety protocols are outlined in 

the Preflight checklist within the Event 38 Operations Manual. Checking the GPS readout ensures that it’s within tolerance prior to commencing flight operations. This, 

combined with the fact that the aircraft’s altitude will be visually monitored by the PIC 

and Safety Observer, ensures an equal level of safety is achieved without referencing an 

altimeter setting. Furthermore, by operating at or below 400 ft. AGL the E384 sUAS will 

not create a hazard to any manned aircraft.

91.151-Fuel Requirements for Flight in VFR Conditions

91.151 provides that no person may begin a flight in an airplane under day visual flight 

reference (VFR) conditions unless there is enough fuel to fly to the first point of 

intended landing and to fly after that for at least 30 minutes. Because the E384 sUAS is 

electric-powered, this requirement is inapplicable. Safety features on E384 prevent 

arming and take-off in “Low battery” conditions as well as “return to launch” during 

“low battery” conditions. These features, teamed with the small size and weight of the 

UAV should more than achieve an equivalent level of safety. 

14 CFR Subpart E (91.401 - 91.417): Maintenance, Preventive Maintenance, and

Alterations

91.405 (a)-States that the 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.

91.407 (a) (1)-Specifies that 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) (2)- Specifies, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 and has been approved for return to

service by a person authorized by Sec. 43.7
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21.

91.417 (a) (b)-requires the owner or operator to keep records showing certain 

maintenance work that has been accomplished by certificated mechanics, under Part 43, 

or licensed pilots and records of approval of the aircraft for return to service.

Ryan Nolin seeks full exemption from sections (91.405 (a), 91.407 (a), 91.409 (a(1,2)), 

91.417 (a,b) due to the fact that these sections apply to an aircraft with an airworthiness 

certificate for which Ryan Nolin is already seeking exemption. 

An equal level of safety will be achieved by using the E384 Operations Manual 

(Reference Attachment B) and E384 Maintenance Manual (Reference Attachment A) 

which provide instructions for preventive and corrective aircraft maintenance. The PIC 

will be responsible for conducting maintenance in accordance with these procedures. 

Ryan Nolin, with the knowledge learned as a licensed Airframe and Powerplant 

mechanic (License #3474636), will ensure that all preventive and corrective 

maintenance performed on the E384 sUAS will be documented.

Summary for Federal Register

Pursuant with section 333 of the FAA Modernization and Reform Act of 2012, Ryan 

Nolin seeks exemption from the following Federal Aviation Regulations that are found 

under Title 14 of the Code of Federal Regulations: Part 21 Subpart H, 61.113 (a)&(b), 

91.151, 91.405 (a), 91.407 (a)(1), 91.409 (a)(1) & (a)(2), 91.417 (a)(b). Granted 

exemptions from these regulations would allow Ryan Nolin to safely and properly 

operate the E384 sUAS for the commercial purpose of precision imaging for agricultural, 

forestry, wildlife management and survey industries.

Ryan Nolin is prepared to modify or amend any part of this request to satisfy the need 

for an equivalent level of safety. Ryan Nolin can be contacted at any time (see contact 

information below) if you require additional information or clarification.

Respectfully,

Ryan Nolin

Phone: (802)-318-3456

Email: ryan@skyviewcustoms.com