December31, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Ave., SE Washington DC 20590 ,,... i

Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and specified parts under 14 CFR, the Federal Aviation Regulations Dear Siror Madam: Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 CFR. Part 11, Houston Home Inspections, PLLC, an operatorof Unmanned Aircraft Systems ("UASs") for aerial image acquisition including but not limited to, the following industries: real estate inspections, aerial photography, event photography, hereby applies for an exemption from the Federal Aviation Regulations ("FARs") to allow commercial operation of its UASs. On orabout September21, 2015, the FAA granted exemptions to seven hundred thirty-three UAS operators. It is in good faith and without consul that this exemption requestwill follow the same outline ofthe exemptions granted forthe same general intents and purposes to commercially operate UASs. This application is submitted by: Company: Primary Partner: Address: Phone: Email: Houston Home Inspections, PLLC Robert S Emerick 32222 Tamina Rd., Suite A5 Magnolia, TX 77354 713-408-1129 shawn@houstoninspect.com Houston Home Inspections, PLLC's requested exemption would permit the operation of UAS under controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greatersafety in connection with aircraft operations. As established by the exemptions already granted by the FAA, approval of Houston Home Inspections, PLLC's exemption would enhance safety and fulfill the Secretary ofTransportation's (the FAAAdministrator's) responsibilities to "

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. Regulations from which the exemption is requested: 14 CFR 21 14 CFR 45.23(b) 14 CFR 45.27 14 CFR 45.29 14 CFR 61.113(a) and (b) 14 CFR 91.9 (b)(2) 14CFR91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 14 CFR 91.205 14 CFR 91.215 14 CFR 91.405 {a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(2) 14 CFR 91.417(a) & (b) 14 CFR 91.715

UASs operated by Houston Home Inspections, PLLC weigh less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). They operate atspeeds of no more than 50 knots, can hover, and can simultaneously move vertically and horizontally. Houston Home Inspections, PLLC will only operate its UASs in line ofsight operations. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public." Given the small size of Houston Home Inspections, 

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# -PLLC's UASs and the restricted secure environmentwithin which they will operate, Houston Home Inspections, PLLC's UAS operations adhere to the Reform Act's safety requirements. Additionally, due to the size ofthe UASs, permission from relevant property owners orotherapplicable parties, and the limited areas in which they will operate, approval ofthis application presents no national security issues. Based on the substantial level ofsafety surrounding the proposed operations, and the significant public benefit (enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant ofthe requested exemption is in the public interest. Accordingly, Houston Home Inspections, PLLC respectfully requests thatthe FAA grantthe requested exemption. Aircraft and Equivalent Level ofSafety The operating limitations proposed by Houston Home Inspections, PLLC provide forat least an equivalentor higher level ofsafety because operations furtherenhance safety of aerial image collection using conventional aircraft. The limitations and conditions include: The UAS will weigh less than 55 pounds. Flights will be operated within line ofsight ofa pilot and/orobserver. • Maximum flight time for each operational flight will be no more than 30 minutes. Flights will be terminated at no less than 25% battery power reserve should that occur priorto the 30-minute limit. Flights will be operated at an altitude below400 feetAGL, and not more than 200 feet above an elevated platform from which filming is planned. Minimum crewforeach operation will consist ofthe UAS Pilot, the Visual Observer, and the Camera Operator. A UAS pilotwill be Pilot in Command (PIC). • A briefing will be conducted for planned UAS operations priorto each day's flight. All personnel performing duties within the boundaries ofthe safety perimeterare required to attend. • The Pilot and observer must be trained in UAS operations. • The Observerand pilotwill be in communications at all times. All appropriate permissions and permits will be obtained from territorial, state, county, orcity jurisdictions, including local law enforcement, fire, orotherappropriate governmental agencies. Ifthe UAS loses communications or loses its GPS signal, the UAS will have the capabilityto return to a pre-determined location within the secure perimeterand land. The UAS will have the capability to abort aflight in case of unpredicted obstacles or emergencies.

14 CFR 21: Certification Procedures for Products and Parts This regulation is designed for manned aircraft. It is not suitable foroff- the

- shelfor production UAS. All parts come from the manufacturer. Substantive replacement parts (i.e. motors, propellerblades, radio transmitters, etc.) also come from the manufactureroran authorized vendorwith approved after-marketcomponents and will ensure correct equipment is used to replace substantive parts ofthe UAS craft.

14 CFR 45.23(b): Display of Marks: general**Nor~ally,** a.small decal orsticker label with non-standard alphanumeric markings (as

### mentioned~~ 14 CFR

### ~5.29) should be able to be affixed the UAS in some location. However, if unable to

### a~1x some kmd oflabel with the vehicle's registration numberon it, other identifiable

### nu~bers Will be used from the craft, such as manufacturer's serial numberand/oradesignated veh1cle numberfrom the operator,

### ~ous~on Home Inspections, PLLC, Inc. that can be used to cross reference the UAS to the registration numberas assigned by the FAA. Across reference Page2ofsaid numbers will be documented by the operatorand available in the operator's private records. 14 CFR 45.27: Location of marks: nonfixed -wing aircraft Specifically, §45.27(a) states thatfor Rotorcraft: Each operatorofa rotorcraft must displayon that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, ortail the marks required by §45.23. Because this is neithera passenger rotorcraft norcontains acabin, book, or tail in the traditional sense, displaying any type of registration marking cannot be accomplished. Therefore, the next best location will be used to place the UAS aircraft registration number, this will be determined bythe operatorto ensure balance, mechanical motion, and radio/GPS signal Reception is not hindered. As guidance, atypical ideal location may be the booms forthe motor arms oron the landing gearassembly. 14 CFR 45.29: Size of Marks There will be insufficient space to display aircraft registration numbers on this type of UAS and make itvisible as required by this section. Asmallerdecal orsticker label with non-standard alphanumeric markings will be affixed to the UAS in some location in orderto identifythe craft. 14 CFR 61.113{a) and {b): Private Pilot Privileges and Limitations: Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because the UAS will notcarry a pilot or passengers, the proposed operations can achieve the equivalent level of safety ofcurrent operations by requiring the Pilot in Command (PIC) operating the aircraftto have a private pilot's license ratherthan acommercial pilot's license to operate a UAS. Unlike a conventional manned aircraft, a UAS is remotely controlled by aground-based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level ofsafety exceeds that provided by asingle individual holding acommercial pilot's certificate operating aconventional aircraft. The risks associated with the use ofa UAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part61 allowing UAS use by asport pilot as the PIC exceeds the present level ofsafety sought by 14 CFR 61.113 (a) and (b). 14 CFR 91.9: {b){2) The need to have an aircraft manual onboard does not apply. UAS aircraft information manuals will be kept by the operator. 14 CFR 91.103: PreflightAction Section 91.103 requires each pilot to preflight an aircraft before flight to insure the safety of flight. As FAA approved rotorcraftflight manuals will not be used, an exemption is requested. However, an equivalent level ofsafetywill be provided. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoffdistances, and aircraft performance data before commencement offlight. 14 CFR 91.109: Flight instruction: Simulated instrumentflight and certain flighttests At times, itwill be necessary to certify and/or recertify other UAS operators in an instructional setting. There will be no persons onboard the UAS. A.ls.o,**~n** the**g~ound,** only a single UAS transceivercontrollerwill be monitored bythe person grvrng rnstructlon to the current UAS PIC receiving instruction and piloting the UAS craft.

Page314 CFR 91.119(c): Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 provides, in pertinent part, that: "exceptwhen necessary fortakeoffor landing, no person may operate an aircraft belowthe following altitudes: (c) Overotherthan congested areas. An altitude of500 feet above the surface, exceptover open water orsparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feetto any person, vessel, vehicle, orstructure." Because Houston Home Inspections, PLLC requests authority to operate at altitudes no higher than 400 AGL, and not more than 200 above an elevated platform from which filming is planned, an exemption is needed to allow such operations. It may, however, be operated in a restricted area within asecurity perimeter, where buildings and peoplewill not be exposed to operations without their pre-obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed ofthe UAS as well as the location where it is operated. No flight will be taken without the permission of property owners or local officials. Because ofthe advance notice to the property owners and participants in the filming activity, all affected individuals will be informed ofthe planned flight operations. Compared to flight operations for manned aircraft and the lackofflammable fuel, any risk associated with the proposed UAS operations is far less than conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separation between a UAS and conventional aircraft. 14 CFR 91.121: Altimeter Settings Section 91.121 requires each person operating an aircraftto maintain cruising altitude by reference to an altimeterthat is set"

...to the elevation ofthe departure airport oran appropriate altimetersetting available before departure." As a UAS may not have a barometric altimeter, but instead aGPS altitude data, an exemption is needed. An equivalent level ofsafetywill be achieved by the operator, pursuantto the Pre- Flight inspection and Safety Check list, confirming the altitude ofthe launch site shown on the GPS altitude indicator before flight. 14 CFR. 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151(a) prohibits an individual from beginning "a flight in an airplane underVFR 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 afterthatforat least 30 minutes

...." The typical battery powering the Houston Home Inspections, PLLC's UASs provides less than 30 minutes ofpowered flight. To meetthe 30-minute reserve requirement in 14 CFR §91.151, UAS flight would not be possible. Given the limitations on the UAS's proposed flight area and its proposed operations within a predetermined location, a longertime frame forflight in daylight VFR conditions is reasonable. Furthermore, operating the UASs in atightly controlled area where only people, property owners, orofficial representatives will be allowed, less than 30 minutes of reserve fuel does not engenderthe type of riskthat §91.151(a) was intended to address. Houston Home Inspections, PLLC believes that safety can be achieved by limiting flights to 30 minutes or25% of battery power, whichever occurs first. This restriction would be more than adequate to return the UAS to its pre-determined landing zone from anywhere in its limited operating area.

Page414 CFR 91.203 (a) and (b). and 91.715 Airworthiness Certificates Section 91.203(a) prohibits, in pertinent parts, 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 ofthe Aircraft Registration Application as provided for in§47.31(c). Section 91.203(b) prescribes, in pertinent parts, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under§ 91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew. A UAS has no certificate nordoes it have acockpit door. Houston Home Inspections, PLLC is requesting an exemption from 91.203 (a) and (b), and also 91.715 14 CFR 91.205 (b): Powered civil aircraftwith standard category U.S. airworthiness certificates: Instrument and equipment requirements Section 91.205 pertains to cockpit instrumentsfor manned aircraft occupied by at leastone pilot. This is not applicable to UAS. However, to ensure an equivalent level ofsafety and information, transmitted telemetrywill be sent to the PIC and displayed on avideo screen indicating various parameters including, but not limited to, GPS altitude, GPS signal, battery power remaining, time in flight, UAS ground speed, etc.

14 CFR 91.215: ATC transponder and altitude reporting equipment and use The UAS craft will have insufficient useful load and power supply to operate atransponder. Furthermore, operations offered by the blanket COA will occur belowATC radarcoverage. To ensure an equivalent level ofsafety, when operations existwithin 3 miles ofa public airport, the operatorwill notifythe local airport orATC facility to advise them ofthe operation. Ifoperations exist in an area not covered by the blanket COA, then aspecific COAforthat operation will be obtained bythe local FSDO and specific case-by-case coordination with ATC will be made for the UAS flight.

14 CFR 91.405 (a); 407 (a) (1): 409 (a) (2); 417(a) & (b): Maintenance Inspections These regulations require that an aircraft operator or owner shall"havethat aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter

...," and others shall inspect or maintain the aircraft in compliance with Part43 Given thatthese sections and Part43 apply onlyto aircraftwith an airworthiness certificate, these sections will notapply to Houston Home Inspections, PLLC operations. Maintenancewill be accomplished bythe operator. An equivalent level ofsafety will be achieved because the UASs are limited in size, will carry asmall payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise, the UAS can land immediately and will be operating from no higherthan 400 feet AGL. The operatorwill ensure that the UAS is in working order priorto flight, perform any required maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the person mostfamiliarwith the UAS and best suited to maintain it in an airworthy condition. Summary

Page 5Houston Home Inspections, PLLC will adhere to all outlined safety precautions. The unit itself weighs fewerthan 55 pounds and powered by batteries that eliminates virtually all ofthat risk given the small size and lack offuel. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 (size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight and national security) provide more than adequatejustification to grant Houston Home Inspections, PLLC's requested exemption, allowing for Houston Home Inspections, PLLC's UAS operations.

Ifyou have any questions or need any additional information, please contact the undersigned by phone at 713-408-1129 orvia email at shawn@houstoninspections.com

Sincerely,

Robert S. Emerick Primary Partner Houston Home Inspections, PLLC

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