Mr. Tadakatsu Honda

United!Conveniences!LLC!

2000 Alaeloa St. 

Honolulu, HI 96821

Oct 25th, 2015

U. S. Department of Transportation Docket

Management System

1200 New Jersey Ave., SE

Washington DC 20590

Re: FOR A SUMMARY GRANT EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, 

SUBPART H AND SECTIONS , 45.23(b), 61.23(a) & (c), 61.101(e)(4) & (5), 61.113(a), 

61.315(a), 91.7(a), 91.9(b)(2), 91.103, 91.119(a,b,c), 91.121, 91.203 (a) & (b), 91.151(a)(1), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF ALL DJI PHANTOM 2 AND PHANTOM 3 MODELS, DJI 

S1000, DJI S900, AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT 

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

1. SUMMARY 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, United Conveniences LLC, an operator of Unmanned Aircraft Systems 

(“UASs”) for aerial data collection, hereby applies for an exemption from the

Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs.

United! Conveniences LLC! request,! as! described! in! greater detail below, the requested 

exemption would permit the operation of a sUAS at or below 400 feet AGL, under controlled 

conditions in airspace that (1) is limited; (2) is predetermined; (3) is controlled as to access; and 

(4) provides safe operations. No operations will be conducted over restricted airspace or over 

congested areas. Approval of this exemption would enhance safety, promote industry growth and 

fair competition through increased affordability of aerial photography and videography, and 

would fulfill the Secretary of Transportation’s responsibilities to establish requirements for the 

safe operation of such aircraft systems in the NAS pursuant to Section 333 of FMRA.
2. INTRODUCTION

The name and address of the applicant is:

United Conveniences LLC 

Mr. Tadakatsu Honda

2000 Alaeloa st

Honolulu, HI 96821

alohath@gmail.com

808-589-7634 

United Conveniences LLC objective is to collect aerial data by conducting aerial photography 

and videography in order to provide high quality digital imaging and video content to its clients, 

and to promote the safe use of sUAS’s. More specifically, the purpose of this exemption would 

be to allow United Conveniences LLC to provide commercial aerial video and photography 

operations in the following areas: Aerial photography and videography for the touring industry, 

Aerial photography and videography for Advertisement industry, Aerial photography and 

videography of residential/commercial buildings for the real estate industry, Aerial photography 

and videography for industrial/construction sites, Aerial photography and videography for the 

agricultural and farming industry, and flight demonstrations to new users. Increase public 

knowledge of sUAS and promote safe sUAS operations

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to 

consider whether certain unmanned aircraft systems may operate safely in the national airspace 

system (NAS) before completion of the rulemaking required under Section 332 of the Reform 

Act. In making this determination, the Secretary is required to determine which types of UASs 

do not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following:

The UAS’s size, weight, speed, and operational capability;

Operation of the UAS in close proximity to airports and populated areas; and

Operation of the UAS within visual line of sight of the operator.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate.
UASs operated by United Conveniences LLC weigh less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal). They operate at speeds of no more than 50 knots, can 

hover, and can simultaneously move vertically and horizontally. United Conveniences LLC will 

only operate its UASs in line of sight and will operate only within the sterile area. Such 

operations will insure that the UAS will “not create a hazard to users of the national airspace 

system or the public.”

United Conveniences LLC seeks an exemption to operate the DJI Phantom 2, DJI 

Phantom 2 Vision+, and all Phantom 3 models, The DJI S1000, S900 and DJI Inspire 1 model 

UAS for compensation or hire within the NAS.

Each UAS operated by United Conveniences LLC will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

3. BASIS FOR PETITION 

Given the small size of United Conveniences LLC ’UASs and the restricted sterile 

environment within which they will operate, United Conveniences LLC UAS operations adhere 

to the Reform Act’s safety requirements. Additionally, due to the size of the UASs and the 

limited areas in which they will operate, approval of this application presents no national security 

issues. Each of United Conveniences LLC sUASs, including payload, is far below the 55 pound 

sUAS classification requirement, and one is also below the 4.4 pound requirement developed by 

the proposed 14 C.F.R. Part 107 that creates the “microUAS” subclass of sUAS. Based on the 

substantial level of safety surrounding the proposed operations, and the significant public benefit 

(enhanced safety), reduction in environmental impacts (reduced emissions and noise), the grant 

of the requested exemption is in the public interest. Accordingly, United Conveniences LLC 

respectfully requests that the FAA grant the requested exemption without delay.

Aircraft and equivalent level of safety

The applicant proposes that the exemption requested apply to civil aircraft that have the 

characteristics and that operate with the limitations listed. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe aerial 

photography and aerial filming for movie and television filming operations conducted with 

conventional aircraft.

These limitations and conditions to which United Conveniences LLC agrees to be bound 

when conducting commercial operations under an FAA issued exemption include:
The sUAS will weigh less than 55 lbs.

Flights will be operated within line of sight of a pilot and/or observer.

Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

Flights will be operated at an altitude of no more than 400 feet AGL

Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer.

sUAS pilot will be an FAA licensed airman with at least a private pilot’s certificate and 

third class medical. The observer will hold at least a third class medical.

sUAS Pilot assume all duties and responsibilities as Pilot in Command (PIC).

The UAS will only operate within a confined “Sterile Area”. Security will be performed 

by the operator and designated security personnel.

A briefing will be conducted in regard to the planned sUAS operations prior to each 

day’s production activities. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for this 

briefing.

The operator will obtain the consent of all persons involved in the mission and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, and 

this radius may be reduced to 30 feet based upon an equivalent level of safety 

determination. With the advanced permission of the relevant FSDO, operations at closer 

range can be approved.

The operator will submit a written Plan of Activities to the FSDO three days before the 

proposed shoot.

Pilot and observer will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated.

ALL crew members will at all times be able to communicate by ONLY voice 

communications as to ensure all crew members maintain a visual contact with the UAS at 

ALL TIME.

Written and/or oral permission from the relevant property holders will be obtained.

All required permissions and permits will be obtained from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

If the sUAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land.

The sUAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.
The Plan of Activities

The Plan of Activities must include the following:

Dates and times for all flights;

Name and phone number of the person responsible for the photography / filming 

event;

Name and phone number of the person responsible for the aircraft;

Make, model and serial number and/or registration number of all UAS t to be 

used;

Name and certificate number, if applicable, of all crewmembers to be utilized in the 

event including copies of FAA Medical Certificates and endorsements;

A statement that the Waiver Holder has obtained permission from property 

owners and/or local governmental officials to conduct the event;

Signature of Waiver Holder or representative;

A description of the flight activity including maps or diagrams of any area, city, 

town, county, and/or State over which filming will be conducted and the 

minimum altitudes essential to accomplish the operation.

Briefing

United Conveniences LLC will conduct a verbal and written briefing for the members 

involved, including emergency, if applicable, and security personnel. This briefing will be 

conducted prior to each day’s UAS activities and will include the following items.

Authorization UAS flight operations, Plan of Activities, special provisions and any 

additional provisions issued by the Flight Standards District Office having jurisdiction 

over the photo / filming area.

Radio communications.

Takeoff procedures.

Aviation activities to be conducted during the event.

Approach and landing procedures.

Alternate landing zone in the event of emergency or security breach

Recall procedures.

Emergency procedures.

Possible risk to personnel that are involved.

Control of non-participating persons.
Location of boundaries or deadlines, man-made or natural, readily visible to the 

participants.

Local governmental limitations, restrictions, or any special circumstances, such as noise 

sensitive areas, time of day restrictions or changes in operating procedures.

Security

The exclusion from the flight operations area of unauthorized persons, vehicles or aircraft 

will be enforced by designated event personnel, private security officers or sworn law 

enforcement officers at the direction of United Conveniences LLC.

United Conveniences LLC or a designated representative will halt flight operations in the 

event unauthorized persons, vehicles or aircraft enter the flight operations area.

A predetermined abort signal will be used to halt flight operations should a breach of 

perimeter security occur, or for any other reason in the interest of safety.

Alternate UAS landing sites will be made available prior to the start of the event.

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

3. EXTENT OF RELIEF AND REASONS SEEKS RELIEF 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size 

and limited operating area associated with the aircraft to be utilized by the Applicant, 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. 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 sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot 

nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the operator, pursuant to the

Manual’s requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with motion picture and television 

production, 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.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

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.
Even though the UAS will have no airworthiness certificate, an exemption may 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 sUAS, two-inch lettering will be impossible. 

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 sUAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS 

will see the identification of the UAS as “Experimental.” The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

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

UAS 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 a private 

pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a 

conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with 

no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance as set forth in the Manual. The level of safety provided 

exceeds that provided by a single individual holding a commercial pilot’s certificate operating a 

conventional aircraft. The risks associated with the operation of the sUAS are so diminished 

from the level of risk associated with commercial operations contemplated by Part 61 when 

drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC exceeds 

the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manufacturer's Operating 

Manual for maintenance and use of safety check lists prior to each flight, an equivalent level of 

safety and operating criteria can be found at the following links: 

Requested exemption Aircraft Operating User’s Manuals 

http://www.dji.com/product/phantom-3/download,!

http://www.dji.com/product/phantom-2/download

http://www.dji.com/product/inspire-1/download http://www.dji.com/product/spreading-wingss900/download http://www.dji.com/product/spreading-wings-s1000-plus/download
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

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.

The sUAS, given its size and configuration has no ability or place to carry such a flight 

manual on the aircraft, not only because there is no pilot on board, but because there is no room 

or capacity to carry such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. The FAA 

has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for 

the aircraft an exemption will be needed. The PIC will take all actions including reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft performance data 

before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that 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.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety can be 
achieved as neither a pilot nor passengers will be carried in the aircraft in addition to the small 

size and low speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority 

to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from 

which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, except for the limited conditions stated in the Manual, the UAS will never operate at 

higher than 400 AGL. It will however be operated in a restricted area with security perimeter, 

where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS 

as well as the location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at or 

below 500 AGL in the movie industry. In addition, the low-altitude operations of the sUAS will 

ensure separation between these small-UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 Altimeter Settings

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 Check list, by receiving 

altitude information via a digitally encoded telemetric data feed, which downlinks from the 

aircraft to a ground-based on-screen display. This altitude information will be generated by 

equipment installed on board the aircraft, using GPS triangulation, or digitally encoded 

barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero 

altitude initiation point will be established and confirmed for accuracy by the pilot.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “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; or (2) At night, to fly after that for at least 45 

minutes.”

The battery powering the sUAS provides approximately 40 minutes of powered flight. To 

meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight or night VFR conditions is reasonable.

United Conveniences LLC believes that an exemption from 14 CFR §91.151(a) falls 

within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin 

Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly controlled area where only people and property owners or official representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender 

the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the 

small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for 

which the exemption will be granted.

United Conveniences LLC believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction 

would be more than adequate to return the sUAS to its planned landing zone from anywhere in 

its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 

5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

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

it has within it the following:

An appropriate and current airworthiness certificate. . . .
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.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents or to 

display them on the sUAS.

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

control point where the pilot flying the sUAS will have immediate access to them; to the extent 

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be accomplished by 

the operator pursuant to the flight manual and operating handbook. As the manufacturer does not 

provide specific maintenance instructions, maintenance will be “on condition” for all aircraft and 

each aircraft will have a maintenance log.

An equivalent level of safety will be achieved because these small UASs are very limited 

in size and will carry a small payload and operate only in restricted areas for limited periods of 

time. If mechanical issues arise the UAS can land immediately and will be operating from no 

higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and 

best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. If the operator encounters a maintenance issue which cannot be addressed, the UAS will 

be returned to the manufacturer or a qualified repair facility where such repairs or maintenance 

can be performed.
Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned 

vehicle (55lbs or less) in aerial photography and aerial filming operations and flight 

demonstrations for training purposes..

Approval of exemptions allowing commercial operations of sUASs in the aerial photo 

and film industry will enhance safety by reducing risk. Conventional film operations, using jet or 

piston power aircraft, operate at extremely low altitudes just feet from the subject being filmed 

and in extreme proximity to people and structures; and present the risks associated with vehicles 

that weigh in the neighborhood of 4,000lbs., carrying large amounts of jet A or other fuel. Such 

aircraft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs. 

and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The sUAS is carried to the film set and not flown. The sUAS 

will carry no passengers or crew and, therefore, will not expose them to the risks associated with 

manned aircraft flights.

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the 

exemptions requested herein, including exempting the applicant from the requirements of Part 21 

and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to 

the ground, and in a sterile environment and, as a result, are far safer than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and 

people.

Privacy

All flights will occur over private or controlled access property with the property owner’s 

prior consent and knowledge. Filming will be of people who have also consented to being filmed 

or otherwise have agreed to be in the area where filming will take place.

4. SUMMARY 

United Conveniences LLC exemption request should be granted due to the fact that the business 

will increase competition in the marketplace, serve to benefit the public good in a safe and not 

interfere with other safe and effective operations in the National Airspace. Similar exemptions 

have been granted and have been given previously to other operators who are operating the same 

sUASs, e.g. Exemptions Nos. 11062, 11109, 11112, 11213, 11641, 11639, 11240, 11654,11656, 
11658, 11659, 11660, 11663, 11664, 11655, 11669, 11670, 11672, 11639, 11641, 11642, 11644, 

11626.

If you have any questions or need any additional information, please contact 

the undersigned at

Dated: 25-OCT 2015 

Sincerely,

/s/ Tadakatsu Honda 

Mr. Tadakatsu Honda

United!Conveniences!LLC!

2000 Alaeloa St. 

Honolulu, HI 96821