## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

1 Misher	Hollifield
Airman	Certif icate	#3777375
245	Green	Leaf	Rd
Burnsville	NC.	28714

December	15 th ,	2015

Re:	Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation	Regulations	from:	14 CFR	21	subpart	H;	14 CFR	45.23(b);	14	CFR	61.113(a)	and	(b);	14	CFR	91.7(a);	14	CFR	91.9(b)(2);	14	CFR	91.103;	14	CFR	91.105;	14 CFR	91.109;	14	CFR	91.119(c);	14	CFR	91.121;	14	CFR	91.151(a);	14	CFR	91.203	(a)	and	(b);	14	CFR	91.405	(a);	14	CFR	91.407	(a )	(1) 14	CFR	91.409	(a) (1)	and	(2);	14	CFR	91.417(a)	and	(b)

Dear	Sir	or	Ma’am:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	“Reform	Act”)	and	14	CFR	Part	11,	I	Misher Hollifield,	owner	and	operator	of	small	Unmanned	Aircraft	Systems	(sUAS) ,	hereby	apply	for	an	exemption	from	the	listed	Federal Aviation	Regulations	(“FARs”)	to	allow	commercial	operation	of	sUAS,	so	long	as	such	operations	are	conducted	within	and	unde r the	conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	req uired	by	Section	333.

Commercial	operation	of s UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	sensors,	would	operate	in	the following	manner:

• Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	estate,	architectu re,	land	surveying, engineering	and	other	related	professional	activities.

• Aerial	video	and/or	photography	for	public	and/or	private	use	including	television,	pu blic	events,	cinematography	and newsgathering

.

• Aerial	inspection/photography	of	residential/c ommercial	structures	under	contract	with	the	owners	or	local	government authority.

• Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	including	but	not	limited	to	electrical	power lines,	wind	turbines	and	cell	towers.

• Aerial	v ideo/photography	or	providing	live	video	feed	to	assist	with	search	and	rescue	operations	in	cases	of	an	emergency or	natural	disaster	only	when	the	local	authorities	or	government	has	requested	it	by	contract	or	donation.

• The	ability	to	offer	training	to persons	individually	or	belonging	to	both	private	and/or	public	organizations	that	have interests	in	the	use	and	application	of	a s UAS	for	the	purpose	of	the	safe	operation	of	a s UAS	to	enhance	the	safety	of the	National	Airspace	System	(NAS)	as	well	as	f or	the	protection	of	the	persons	and	property.

As	described	fully	below,	the	requested	exemption	would	permit	the	operation	of	a	sUAS	under	controlled	conditions	in	the	NAS that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	will	provide	safety enhancements	to	the	already	safe	operations	in the	industry	presently	using	conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	safety	and	fulfill	the Secretary	of	Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	“....est ablish	requirements	for	the	safe	operation	of such	aircraft	systems	in	the	national	airspace	system.”

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

2 The	name	and	address	of	the	applicant	is:
Mr.	Misher	John	Hollifield
Airman	Certificate	#3777375 Misher32@gmail.com
245	Green	Leaf	Rd
Burnsville	NC.	2871 4

AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

The	operational	limitations	proposed	will	provide	for	an	equivalent	o r	higher	level	of	safety	to	persons	and/or	property	due	to	the elimination	of	slow,	low,	and	high	angle

- of

- attack	flight operations	using	con ventional	aircraft.

These	limitations	and	conditions,	to	which	the	applicant	agrees	to	adhere	to	when	conducting	commercial	operations	under	the FAA	issued	exemption	as	set	forth	in	the	Flight	Operations	Manual	(FOM),	include:

• The s UAS	will	weigh	less	th an	55	lbs.

• The s UAS	will	have	a	maximum	op erating	speed	of	no	more	than	100 mph.

• Flights	will	be	operated	within visual line	of	sight (VLOS) of	the	Pilot	in	Command	(PIC)	and/or	Visual	Observer	(VO).

• Maximum	flight	time	for	each	operational	flight	will	be 20	minutes.	Flights	will	be	terminated	at	25%	battery	power	reserve or	20	minutes	of	flight	time	whichever	occurs	first.

• Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	Above	Ground	Level	(AGL) or not	more	than	200	feet	above an	elevated	p latform	from	which	filming	is	planned.

• Minimum	crew	for	each	operation will	consist	of	the s UAS	Pilot	and the	Visual	Observer	(VO )

.

• The s UAS	pilot (Misher	J Hollifield) will	be	the	desig nated	Pilot	in	Command	(PIC), is	a	FAA	certified	pilot	(Certificate

#3 777375) ,	and	will	comply	with	recent	registration	and	marking	required	by	§48.15	where	all	small	unmanned	aircraft must	display	a	unique	identifier	and	register	their	aircraft	prior	to	operation	of	the	sUAS.

• The	Pilot	In	Command	(PIC) shall,	before	beginni ng	a	flight,	familiarize himself	and	crew with	all	available	information concerning planned s UAS	opera tions	prior	to	each	day’s	flight

. This	information	will	include	weather	reports	and forecasts,	flight	hazards,	safety	information,	estimated	flight	time, emergency	contacts,	and	a	planned	order	of operations.

• All	flights	will	occur	under	Visual	Flight	Rules (VFR) and	will	remain	clear	of	clouds

.

• If	operations	will	be	within	a	5	mile	radius	of	the	geographic	center/Airport	Reference	Point	(ARP)	of	a	tower	co ntrolled	or uncontrolled	airport

, the	respective	airports	will	be	contacted	advising	them	of	the	estimated	flight	time,	flight	duration, elevation	of	flight	and	other	pertinent	information.

• The	operator	will	obtain	verbal/written	consent	of	all	persons	inv olved	with	the	planned	operation	and	ensure	that	only consenting	persons	will	be	allowed	within	100	feet	of	the	flight	operation,	and	the	radius	may	be	reduced	to	30	feet based	upon	an	equivalent	level	of	safety	determination,	as	r equired	under	the	FOM.	O p erations	at	closer	range	may	be approved with advanced	permission	of	the local	Flight	Standards	District	Office	( FSDO ).

• The	PIC	and	VO	will	have	been	trained	in	operation	of s UAS	and	receive	up

- to

- date	information	for	the	particular s UAS	to be	operated.

• T h e	PIC	and	VO	will	be	able to	communicate	by	voice	and/or	radio	at	all	times.

• Written	and/or	verbal	permission	and	permits	will	be	obtained ,	as	applicable, from	territorial,	state,	county	or	city jurisdictions,	including	law	enforcement,	fire	or	other	appro priate	governmental	agencies.

• If	the s UAS	loses	communications	with	the	remote	controller	or	loses	GPS	signal,	the s UAS	will	have	the	capability	to	return
to	a	pre

- determined	location	within	a	designated	location	and	land	autonomously.

• The s UAS	will	have	t he	capability	to	abort	a	flight	in	case	o f	unpredicted	obstacles,	meteorological	conditions ,	or emergencies.

I	Misher	John	Hollifield,	will	operate	a DJI	Phantom	3,	with	a	total	weight	of	approximately	1280g	or	2lbs	13	oz.	The	dimensions

are	40.36cm	x	40 .36cm	x	19.05cm	or	16inch	x	16inch	x	7.5inch. The	maximum	airspeed	will	not	exceed 16m/s	or	35mph	with	a cruising	speed	of	11m/s	or	25mph.	The	DJI	Phantom	3	has	the	ability	to	hover	and	move	along	a	vertical	and	horizontal	plane simultaneously.	The	DJI	Pha ntom	3	has	four	motors,	Motor	Model	DJI	351 0,	powered	by	a	4480mAh	4s Lithium	Polymer	battery.

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

3 There	are	four	propellers,	Propeller	Model	DJI	1345,	in	use.	The	DJI	Phantom	3	will	be	controlled	with	the	C3	remote	controll er with	an	operating	frequency	of	2. 400GHz

– 2.483GHz.	The	live	video	feed	will	have	an	operating	frequency	of	2.4GHz	ISM	with maximum	range	of	1.2	miles.	The	applicant	will	operate	the sUAS	within	visual line	of	sight (VLOS) within	a	closed	off	and predetermined	area	owned	and/operated	by	t he	property	representative.



## DJI	Phantom	3

GENERAL	FEATURES

· Ready	to	fly

· 3

- axis	camera	stabilization

· Precision	flight	and	stable	hovering

· GPS/GLONASS	positioning	&	auto	return	home

· Onscreen	real

- time	flight	parameters

· High	Definition	Camera

· Camera	tilt	control

· Film	straight	down

· Supports	Adobe DNG	RAW

· Adobe	lens	profile	support

· Camera	parameter	settings

· Album	synchronization

· FAA	no

- fly	zones	locked	out	via	installed	software

TRANSMITTER

· Operating	Frequency:2.400	GHz

– 2.483	GHz

· Communication	Distance ( open	area ) :	CE:	2000m;	FCC:	20 00m

· Receiver	Sensitivity ( 1%PER ) :

- 101dBm	+/

- 2dBm

· Transmitter	Power:	CE:	16dBm;	FCC:	20dBm

· Working	Voltage:	1.2A	@	7.4V

· Battery:	6000	mAh	LiPo	2s

CAMERA

· Operating	Environment	Temperature : 0 °C

- 40 °C

· FOV:	94°/	85°

· Sensor	size:	1/2.3"

· HD	Recor ding

DJI	VISION	APP

· System	Requirement	of	Mobile	Device:	iOS	version	6.0	or	above/	Android	system	version	4.0	or	above

The	proposed	operations	will	adhere	to	the	Reform	Act’s	safety	requirements	due	to	the small	size	of	the sUAS	combined	with the

stru ctured	environment	and	planning	provided	by	the	PIC .	The	approval	of	this	application	presents	no	national	security	issues. Using	sUAS	for	the proposed	operat ions	increases safe ty	tremendously	for	all	persons,	vessels,	vehicles,	or	structures	as	compared to	traditional	General	Aviation	(GA)	aircraft;	which	frequently	are	required	to	operate	at	altitudes	that	no	do	not	allow,	if a	power unit	fails,	an	emergency	landing	without	undue	hazard	to	persons	or	property	on	the	surface. A	higher	level	of	safety

, com bined with	lower	noise	and	zero	harmful	emissions	deem	it	fit	that	this	exemption	is	in	the	interest	of	the	public

, and	should	be granted. Accordingly	the	applicant	requests	that	the	FAA	grant	the	requested	exemption	with	minimum	delay.

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

4 Regula tions	from	which	the	exemption	is	requested:

14	CFR	Part	21	subpart	H 14	CFR	45.23	(b) 14	CFR	61.113	(a)	&	(b) 14	CFR	91.7	(a) 14	CFR	91.9	(b)	(2)

14	CFR	91.103

14	CFR	91.105

14	CFR	91.109 14	CFR	91.119	(c)

14	CFR	91.121 14	CFR	91.151	(a) 14	CFR	91.203	(a )	&	(b) 14	CFR	91.405	(a) 14	CFR	91.407	(a)	(1) 14	CFR	91.409	(a)	(2) 14	CFR	91.417	(a)	&	(b)

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	requiremen ts	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	authoriz e the	FAA	to	exempt	aircraft	from	the	requirement	for	an	airworthiness	certif icate,	upon	consideration	of	the	size,	weight,	speed, operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular s UAS.	In	all	cases,	an	analysis	of	these
criteria	demonstrates	that	the s UAS	operated	without	an	airworthiness	cer tificate,	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	wit h	an airworthiness	certificate	without	the	restrictions	and	conditions	propos ed.

The s UAS	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	and	designated	area.	Unlike	other	civil	air craft, operations	under	this	exemption	will	be	tightly	controlled	and	monitored	by	both	the	operator	and	under	the	requirements	and in compliance	with	local	public	safety	requirements.	These	safety	enhancements	provide	a	greater	degree	of	safety	to	the	pub lic	and property	owners	than	conventional	operations	conducted	with	airworthiness	certificates	issued	under	14	C.F.R.	Part	21,	Subpar t H.	Lastly,	application	of	these	same	criteria	demonstrates	that	there	is	no	credible	threat	to	national	security	posed	by the s UAS, due	to	its	size,	speed	of	operation,	location	of	operation,	lack	of	explosive	materials	or	flammable	liquid	fuels,	and	inabil ity	to carry	a	substantial	external	load.

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

The	regulation	requires:	Wh en	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

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

5 inches	high,	the	words	"limited,"	"restricted,"	"light

- sport,"	"experimental,"	or	"provisional,"	as	applicable.

Even	though	the s UAS	will	have	no	air worthiness	certificate,	an	exemption	will	be	needed	as	the s 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 s UAS,	two

- inch	lettering	will	be	impossible.	The	word	“Exper imental”	will	be	placed	on	the	fuselage	in compliance	with	§45.29	(f).

The	equivalent	level	of	safety	will	be	provided	by	having	the s UAS	marked	on	its	fuselage	as	required	by	§45.29	(f)	where	the	pilot, observer	and	others	working	with	the s UAS	will	see the	identification	of	the s UAS	as	“Experimental.”

The	sUAS	will	comply	with	recent	registration	and	marking	required	by	§ 48.200 where	a ll	small	unmanned	aircraft	must	display	a unique	identifier.

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

Pursuant	to	14	CFR	61.113	(a)	&	(b),	no	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	of	an	airc raft that	is	carrying	passengers	or	property	for	compensation	or	hire.

An	equivalent	level	o f	safety	can	be	achieved	by	current	Regulations	because	the	applicant’s s UAS	do	not	carry	any	pilots	or passengers	nor	property.	The	risks	attendant	to	the	operation	of s UAS	is	far	less	than	the	risk	levels	inherent	in	the	commercial
activities	outlined	in 14	CFR	61.	The	operation	and	limitations	set	forth	in	the	FOM	will	equate	to	the	safe	operation	of	the s UAS.

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	airworth y	condition.	As	there	will	be	no airworthiness	certificate	issued	for	the	aircraft,	should	this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	fo r determining	airworthiness.

Given	the	size	of	the	aircraft	for	maintenance	and	use	of	safety che cklists prior	to	each	flight,	an	equivalent	level	of	safety	will	be provided.

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	whic h	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	Rot orcraft Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any	combination	ther eof.	The s UAS,	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	bo ard,	but because	there	is	no	room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivale nt	level	of	safety	will	be	maintained	by keeping	the	flight	manual	at	the	ground	control	point	where	the	pilot	flying	the s UAS	will	have	immediate

access	to	it.

14	C.F.R.	§	91.103:	Preflight	Action.

This	regulation	requires	each	pilot	in	command	to	tak e	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	as stated	in the	manufacturer	FOM	in	the	pre

- flight	i nspection	section,	including	but	not	limited	to	reviewing	weather,	flight	battery

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

6 requirements,	landing	and	takeoff	distances	and	aircraft	performance	data	before	initiation	of	flight.

14	C.F.R.	§91.105:	Flight	crew	members	at	stations

Exemption	may	be required,	the	PIC	may	not	leave	his	station	nor	shall	VO	leave	station	.	In	event	that PIC	or	VO	become

i ncapacitated, s UAS	is	to	automatically	return	to	designated	landing	area,	as outlined	in	FOM

.

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. s UAS	and	remotely	piloted	aircraft,	by	their	design	do	not	have fully	fu nctional	dual	controls.	Flight	control	is	accomplished	through	the	use	of	a radio	transmitter that	communic ates	with	the aircraft	via	Radio	Frequency	(RF) communications.	The	FAA	has	approved	exemptions	for	flight	training	without	fully	functional
dual	con trols	for	a	number	of	aircraft	and	for	flight	instruction	in	experimental	aircraft.	The	equivalent	level	of	safety	provided	b y the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in	the	aircraft	and	by	the	size	and	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	operat ed	at	less than	the	minimums	prescribed,	provided	the	person	operating	the	helicopter	complie s	with	any	route	or	altitudes	prescribed	for helicopters	by	the	FAA.	As	this	exemption	is	for	a s UAS	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,	the s UAS	will	never	operate	at	higher	than	400	AGL	with	the	exception	that
in	circumstances	where	the s UAS	is	used	to	survey	or	photograph	a	structure	whose	heig ht	exceeds	400	feet	AGL,	the s UAS	will not	be	operated	more	than	200	feet	above	the	highest	point	on	the	structure.	It	will	however	be	operated	in	a	restricted	area with security	perimeter,	where	buildings	and	people	will	not	be	exposed	to	operations	witho ut	their	pre

- obtained	consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the s 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	ope rations. Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	more	than	the	ma ximum	55lbs.	proposed	herein	and	the lack	of	flammable	fuel,	any	risk	associated	with	these	operations	is	far	less	than	those	presently	presented	with	conventiona l aircraft	operating	at	or	below	500	AGL.	In	addition,	the	low

- altitude	operations	of	the s UAS will	ensure	separation	between	these

s 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	cruisin g	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 s UAS	may	not have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exem ption	may	be	needed.	An	equivalent	level	of	safety	will be	achieved	by	the	operator,	pursuant	to	the	safety	check	list	and	live	flight	data	monitoring,	confirming	the	altitude	of	th e	launch site	shown	on	the	GPS	altitude	indicator	before	flight.

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	w ind and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to the	first	point	of	intended	landing,	and,	assuming	normal	cruising

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

7 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 s UAS	provides	approximately	25 minutes	of	powered	flight.	To	meet	the	30	minute	reserve	requirement in	14	CFR	§91.151, s UAS	flights	would	be	limited	to	approximately	10	minutes	in	length.	Given	the	limitations	on	the s UAS’s proposed	flight	area	and	the	location	of	its	proposed	operatio ns	within	a	predetermined	area,	a	longer	time	frame	for	flight	in daylight	or	twilight	VFR	conditions	is	reasonable.

Applicant	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope	of	prior	exemptions.	Operating	the s UAS,	in	a tightly	c ontrolled	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	t o alleviate	given the	size	and	speed	of	the	small s UAS.	Additionally,	limiting s UAS	flights	to	10	minutes	would	greatly	reduce	the utility	for	which	the	exemption	will	be	granted.	Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	lim iting flights	to	2 0	minutes	or	25%	of	battery	power

— whichever	happens	first.	This	restriction	would	be	more	than	adequate	to	return
the s UAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.

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

(1)	An	appropriate	and	current	airworthiness	certificate.	.	.

.

(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

passe ngers	or	crew.

The s 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 s UAS.

An	equivalent	level	of	safe ty	will	be	achieved	by	keeping	these	documents	at	the	ground	control	point	where the	pilot	flying	the s UAS	will	have	immediate	access	to	them;	to	the	extent	they	are	applicable	to	the s UAS.

The	sUAS	will	comply	with	recent	registration	and	marking	require d	by	§48.15	where	a ll	small	unmanned	aircraft	m ust	display	a unique	identifier	and register	their	aircraft	prior	to	operation	of	the	sUAS.

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.	An equivalent	level	of	safety	will	be	achieved	because	the s UAS	is	very	limited	in	size	and	will	carry	a	small	payload	and	operate	only
in	restricted	areas	for	a	lim ited	period	of	time.	If	mechanical	issues	arise	the s UAS	can	land	immediately	and	will	be	usually operating	from	no	higher	than	400	feet	AGL.	The	operator	will	ensure	that	the s UAS	is	in	working	order	prior	to	initiating	flight, perform	required	maintenanc e,	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.

An	equivalent	level	of	safet y	will	be	achieved	because	maintenance	and	inspections	will	be	performed	in	accordance	with	the

## Misher	Hollifield Petition	for	Exemption	Filed	under	Section	333

8 s UAS	Manufacturer's	User	Manual.	As	provided	in	the	FOM,	the	operator	will	ensure	that	the s UAS	is	in	working	order	prior	to initiating	flight	and	perform	required	maintenance	needed.

Additional	Information

The primary	pilot

, Misher	Hollifield

, has been	involved	in	the	piloting	of	remote	con trolled	aircraft	for	more	than	10 years. The applicant hold s	a Private	Pilot	certificate,	and has a	firm	understanding	of	risk	mitigation.	The	applicant also	has	an	in

- depth understanding	of	the	capabilities	and	safety	concerns	involved	in	using	this	technology	as	an	asset	to	the	community.	Satisfa c tion of	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012	provide	more	than	adequate	justification	for	the	grant	of	the requested	exemptions	allowing	the	commercial	operation	of	the s UAS.

Sincerely,

Misher	John	Hollifield