# YOVEM LLC.
2255 GERMANN RD APT 2027 CHANDLER, ARIZONA, 85286
U.S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Avenue SE Washington, DC 20590
Re: Exemption Request Section 333 of the FAA Reform act & Part 11 of the Federal Aviation Regulations from 14 C.F.R.45.23(b); 14 CFR Part 21; 14 CFR 61.113(a) & (b); 91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 91.409; 91.417 (a) & (b)
**To Whom It May Concern:**

RE: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R Part 11, Yovem LL C is a new and developing filming and photography compan y and operator of a small (UAS) equipped for photos and videos, hereb y applies for an exe mption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operations of its UASs, so long as such operations are conducted within and under the conditions outlined herein or as may be established b y the FAA and required b y Section 33 3. **Purpose of the pro posed flight will be to provide:** 

 P hotos and videos of real estate listi ng offered for rental and sale.  P hotos and videos used to promote tourism in the areas resulted in potential tax receipts for Local, States and US Government.  Photos promoting land for sale

.  Golf Course Photo graphy

.  Cinematograph y .  Monitor Crops

.  Survey s .  Pipeline inspections

.  Property

Inspections

. Nature Photograph y.

 Photos and videos taken with UASs will be promoted on company’s websites (yovem.com), Facebook , Instagram and twitter.
**The name and address of the Applicant is:** YOVEM LLC. Attn: Richard Tulloch PH: 623.205.0712 Email: myyovem@gmail.com Address: 2255 W Germann Rd APT 2027, Chandler Arizona, 85286
**Public Interest and National Security** Yovem LL C i ntends to service the needs of aerial filming and photograph y for the purposes of movie making, advertising and marketing in a variety of industries. Traditional methods of aerial filming and photograph y are handled by full sized, fixed and rotor wing aircraft which are no longer competitive when compared to the low acquisition and operating costs of small unmanned aircraft s ys tems. These cost savings can be transferred to the advertiser then ultimately to the consumer to promote competitiveness in the market place. Full sized aircraft have a greater environmental impact. They are significantly

louder to operate than small, fully electric unmanned aircraft s ys tems and carry a much larger carbon “ footprint" ad ding to the growing concern of the emissions of greenhouse gases. Being all electric is beneficial in that it is significantl y quieter and less likely to disrupt the peace of the surrounding flight operations area. Full sized aircraft carry

flammable fuels and flight crew and/or passengers. There is a great deal of danger imposed to the flight crew and/or passengers and to those on the ground in the event of an emergency

with regard to full size aircraft. This danger is considerabl y less in comparison with the UAS due to its small siz e, maximum forward speed and lac k of flammable fuels. Because Yovem LL C w ill have a public presence for commercial UAS aerial filming and photograph y, we will be available and willing to assist in disaster relief. There is no threat to National Security due to the Transportation Security Administration security screen ing of certificated airmen. The PI C is U.S. Citizen with zero criminal back ground and zero FAA violations and is greatly

concerned in ensuring the public maintain s their right to privacy . We believe that because of advancing technologies, small unmanned aircraft sy stems are much less expensive to acquire, easier to operate, and less demanding to maintain when compared to full size aircraft. UAS aerial services, suc h as filming, surveying, inspection and surveillance will undoubtedly

promote public interest. **Note :**  The PI C is also an Army combat veteran who served overseas during Operation Iraqi Freedom for twelve months and spent a total of eight years in the United States military . Also theDJIPhantom 3 is sophisticated equipment with a built in program that does not even allow the

drone to operate within 15 miles of the white house are other high security areas. **Pilot In Command (PIC)** Name: Richard Tulloch FAA Certificate #: 3429390 FAA Certifications/Ratings:

 Airline Transport Pilot (Multi Engine)  Single Engine Commercial Pilot Privileges  Certified Flight Instructor a. Single Engine Land b. Multi Engine Land (MEI) c. Instrument (CFII)  PI C holds over 2000 hours total time
**General Operating Flight Crew Requirements**  Only the PIC shall be required to maintain a valid Pilot's L icense (Private, Commercial or ATP) issued by

the FAA as prescribed by 14 CFR Part 61. The PI C shall maintain his or her Flight Review currency requirements as per 14 CFR part 61.56 and 3rd, 2nd, or 1 st Class Medical Certificate as prescribed b y 14 CFR Part 67.  Prior to any

UAS flight, the PI C shall be trained in all aspects of flight operations. Training will include, but is not limited to; Pers onal Computer Flight Simulation that is similar to the flight characteristics and control of the UAS to be used; actual flight training with the UAS to be used in a designated flight area.  Prior to any

commercial flight operations, the PI C shall have accru ed at least 25 hours of documented flight time with the UAS being operated b y Yovem LLC. The PI C and VO shall train together during this time to practice and become familiar all aspects of the operations. The VO is not required to be present at all 25 hour s of flight training; however, it is the responsibility of the PIC to determine if the VO has a thorough understanding of how to conduct flight operations safel y.  Prior to any

commercial flight operations, demonstration of complete control of the UAS sha ll be maintained. P roficiency flights shall include all normal flight maneuvers such as takeoff; a figure "8" coordinated turn flight pattern; and landing s . UAS flight crewmembers are required to demonstrate the ability to speak and understand

the English Language to the proficiency level required by

I CAO Annex 1. This is accomplished b y means of formal and informal interviewing during the hiring process.  Neither the PIC or VO shall participate in any flight operations, whether it be proficiency flights or revenue generating flights, if the blood alcohol concentration (BAC) level is 0.04% or higher, within 8 hours of having consumed any alcohol, while under the influence of alcohol, while under the influence of illegal, prescribed or over the counter drugs that would impair the ability to safel y operate the UAS as prescribed in 14 CFR Part 91.17. It is the responsibility of the PIC and VO to police each self and each other.  The UAS flight crewmembers shall not participate in any phone calls, phone conversat ions or operation of a two

- way radio during flight operations. All proposed flight paths and flight operations will be discussed by Yovem LL C and the customer prior to an y flights in order to avoid unnecessary distractions. Only concise communications are allowed between authorized flight operations area personnel and the UAS flight crewmembers. Every effort shall be made to prevent non

- essential personnel from interfering with the PI C and VO in any way during flight operations.  All applicable licenses, ce rtificates, permits, authorizations, waivers, exemption letters, flight and maintenance logbooks, personal identificatio ns, and this Operations Manuals shall be made available to any law enforcing, State or National Gover nment Entity

at any) Record keepin g  Training qualifications and record keeping are maintained and tracked for the pilot in command and visual observer. The PIC is responsible for the management of all training, maintenance and flight records. Records shall include the following, as appropriate to the crew position; copies of certificates and ratings, copy of current Medical Certificate and flight training logs.  Maintenance will only be conducted b y an authorized DJIrepresented who is certified by DJIto maintain a DJ I phantom 3. Rec ords will include date, time, specific detail of work done and name and or badge number of personal who conducted the maintenance. Maintenance records will be kept for 7 ye ars. Operational and Maintenance records may be made available for inspection by the Federal Aviation Administration

. **The UAS & Flight** The UAS is a 3 lbs battery operated quadcopter (four motors, four blades) call the DJ I Phantom 3 Professional, which consist of:  4k UHD video recording with fully stabilized 3

- axis gimbal; Vision Positioni ng s ys tem allows stable flight. Li ghtbridge digital streaming allows live viewing of 720p video (full resolution video is

simultaneously

recorded on the internal microSD card).  Flight battery

and rechargeable remote controller.  DJIPilot a

pp for I OS and Android allows live viewing and complete camera control.  The Phantom 3 Professional carries a full y stabilized 3

- axis 4k UHD video camera for smooth, crisp videos and still photos.  To allow you to see what the drone sees, DJ I has engineered a new generatio n of their Li ghtbridge technology

that allows 720p HD digital streaming of live video directly from the drone.  In cludes GPS navigation with auto takeoffs and auto landings, intelligent high power flight battery , a built

- in safety database of no fl y zones, and a powerful mobile app for yo ur iOS or Android device.  GPS Assisted flight

- Allows quadcopter to hover when no command are being sent

- This is a nice feature in case the PI C needs to "regroup" during flight.  Non
- GPS Modes

- If GPS signals are lost, aircraft goes into a mode that monitors and hold altitude and provides control assistance to help keep aircraft stable and under total control of the PI C.  LED Status Lights on Aircraft, along with warning s ys tem equipped on the pilot app which allows the PI C to alway s have full situation awareness on his aircraft. **Note:** DJ I has locked the Phantom from being able to even start the motor if you live within a 15 mile radius of the White House. This encompasses not only D.C. but much of Prince George's County , Arli ngton, Fairfax, Silver Spring, Falls Church and Montgomery County

. (The DJ I Phantom 3 manuals will be attached to this packet) The UAS also have two bright gold bands in front of the quadcopter, these are used for orientation and location of aircraft fro m line of site. MAX. Ascent Speed: 5m/s MAX. Descent Speed: 3m/s MAX. Flight Altitude 6000m MAX. Flight time approximately 23 minutes GPS: GPS/GL ONASSThe powerful Remote Controller allows you to pilot and maneuver the Phantom 3 Professional at

distances over 6,000 feet away , while putting selected camera controls. Built into the Remote control is a rechargeable LIPo battery and DJ I Li ghtbridge, which when paired with a compatible mobile device gives live HD view from the Phantom Camera. Operating Frequency : 2.400 GHz

- 2.483 GHz Max. Transmission Distance: 2 km Operating Temperature Range: 0c

- 40c Transmit Power: FCC: 20 dbm; CE : 16 dbm Charger: Voltage 17.4V; Rated Power 100W The UAS will be operated by a Pilot in Command (PI C) with the following restrictions:  All operations will occur in Class G airspace at no more than 400' AGL. The vast majority of flight s will be well below this limit at an average of 200' AGL to accomplish the best photographs and videos.  Any required permits will be obtained from local and state government before flights.  The Aircraft will not operate directly above human beings at any time or within 150 feet of human beings.  Maximum flight time will be 18 minutes. Battery allows 23 minutes of flight time. Batteries are inspe cted and alway s full y charged before use.  The Aircraft will not operate within 5 miles of an airport/heliport without prior approval from said airport/heliport.  All operations will be during the day time and in ideal weather conditions of less than 15 mph w inds and clear skies.  Aircraft will remain in visual line of site at all times not to exceed 1/4 miles from PI C.  Visual observer will serve as additional eyes on the aircraft and be within voice reach to communicate with PI C  Aircraft will not fly

in the ar ea of any

full scale aircraft and if a full scale aircraft comes into airspace during the aircraft's flight, it will be landed immediatel y to allow right of way to full scale aircraft.  At any

time Aircraft is being flown, signs will be posted in least thr ee (3) locations, warning of UAS operations are being conducted and to stay at 200' away

at all times of landing and takeoff areas.  UAS will never be used as an invasion of privacy and only be used for purposes listed above.  The UAS will never be flown near, in or over stadiums; or over large gathering of persons.  The equipment is not inexpensive and Itake general public and aviation safety seriously

. I have developed pre

- flight plans, and maintenance plan to make sure the aircraft is alway s in safe fl ying condition.**REASONS FOR EXEMPTIONS**

Exemption Request Section 333 of the FAA Reform Act & Part 11 of the Federal Aviation Regulations from: **14 C.F.R**  **. Part s**  **21, 45.29, 45.23:** The aircraft has no area to display numbers or letters that are at least 2” in size. To my Kn owledge there are no registration sy stems for UAS. We will place in the largest letters
“ YOVEM LLC” on the top of the aircraft. **14 C.F.R**  **. 91.7:** To my knowledge there are no aircraft airworthiness certificates for UAS. We will before each flight run through the enclosed pre

- flight checklist to ensure airworthiness. **14 C.F.R**  **91.9(b):** There is no cockpit to include said manual. Operating manual will be kept with PI C. **14 C.F.R. 91.103:** Sin ce there will not be a FAA approved quad copter manual to be provided we will need to be exempt. We will again follow our enclosed pre

- flight checklist to ensure safety and airworthin ess. **14 C.F.R. 91.109:** UAS are controlled b y transmitter and do not have the cap ability for dual controls. It is our understanding there have been other aircraft approved without dual controls. **14 C.F.R. 119:** Since flights will never be above 400’ AGL and usually around 200’ AGL, we requested an exemption as the altitude cited in 14 CFR 91.119 would cause us to exceed said 400’ AGL. **14 C.F.R.91.121:** UAS does not have a traditional altimeter. The DJI Phantom 3 Professional uses sophisticated technology

which enable s precise GPS coordinates that gives real time positioning including altitudes and speeds all displayed on an Iphone or Ipad. **14 C.F.R. 91.51:** The UAS does not use traditional fuel but battery power. The battery

provides for up to 23 minutes of flight. Battery power levels will be monitored using an apple application which gives the PI C the capability

to enable the return home feature telling the UAS to return home and land. No flight will last longer than 18 minutes as an extra safety net. All batteries are o nly

used if freshl y charged, all batteries are visuall y inspected and volt tested before each flight.**14 C.F.R. 91.203:**

There is no cockpit to include said certificate or registration documents. Any certificates, exemptions or registration documents will be with the PI C on the ground level. **14 C. F.**  **R. 91.405, 91.407, 91.409, 91. 47:**  As there are no airworthiness inspections available therefore we request an exemption. Again we will perform pre

- flight checklists to ensure safety. If our pre

- flight checkl ist does not pass, we will abort flight. An y items of concern will promptly be repaired using similar components and records will be kept through maintenance records. We are prepared to modify or amend any

part of this petition for exemption to meet or exc eed concerns of safety ; we do look forward to working with the FAA to provide a great service to our community

and profession in a safe manner.
Sincerel y, Richard Tulloch President Y OVEM LLC.**Pre -**  **Flight Checklist**

o Make sure you are using genuine parts and that all parts are in m int condition

o Ensure the remote controller, intelligent Flight Battery , and mobile device are full y charge

o Ensure that there is no foreign object stuck to the camera lens, the micro

- SD card has been inserted into the camera , and gimbal can rotate freely before powering it on.

o En sure the propellers are securel y mounted onto the motors, and the motor s can start and function normal

. o Make sure propellers are not chipped or damaged

o Check all electrical wiring for security

o Follow the on screen instructions to calibrate the compass

o Ensure the DJ I pilot app and aircraft firmware have been upgraded to the last version

o Make sure yo ur flight area is outside the No

- Fl y Zones and flight conditions are suitable for flying the Aircraf

t
o Make sure wind velocity is less than 15 MPH

o Before starting DJ I Phantom make sure you are in an open area clear of trees, power lines or any obstacles.

o Make sure you located at least 5 Miles from an airport unless received a uthorization from an authorized pe rsonnel.

o Make sure an y b y standby personal are at least 150 feet from DJ I Phantom at all times when in operation.

o Set up cones notify

people of DJ I operations in three distinct locations**Post flight**

o Turn Off UAS

o Disconnect batter from UAS

o Set Radio control transmitter power switch to off

o Perform general visual inspection of UAS

**Loss of Communication**

o In the event of loss of communication with the UAS utilized the return home feature.