January 21, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue SE Washington DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA -2014-0481 in the 

matter of the petition of DOUGLAS TRUDEAU

2)FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter 

of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter 

of the petition of FLYING CAM INC 

Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting a Petition for 

Exemption under section 333 of the FAA Modernization and Reform Act 

of 2012, Quicksilver Consulting LLP. DBA National Property 

Inspections Conroe, referred to as NPI-Conroe, request exemption 

from the following sections of Title 14, Code of Federal Regulations §§

Part 21; 45.23(b); 61.113(a); 61.113(b); 91.119; 91.121; 91.151; 91.405(a)(1); 

91.409(a)(1); 91.409(a)(2); 91.417(a) and (b)
Extend of relief requested:

To permit commercial operation of Small Unmanned Aircraft Systems (sUASs) for 

operations conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333.

Said exemption will permit the operation of sUASs under controlled conditions in 

limited, predetermined and controlled airspace. Upon granting of this proposed 

exemption request, NPI-Conroe will conduct commercial operations of sUASs 

meeting or exceeding all operational and safety requirements per section 333.

Public Benefit:

1. Project and construction management/progress, inspections and 

monitoring. Aerial surveying and inspections can increase work site efficiency and 

safety, improve volumetric estimations, and reduce the risk of falls and injuries. In 

most cases the use of helicopters and small aircraft will be reduced, which will 

improve safety and reduce the environmental impact.

2. Real estate and marketing will benefit from the use of sUAS aerial 

videography/photography that will lead to increased commerce and enhanced 

personal photography. Providing a view that cannot be displayed through ground 

videography/photography, enhancing listings and future marketing.

3. Crop surveying with sUAS will possibly lead to decreased use of 

pesticides/fertilizers, potential conservation of water, and increased crop yields 

with decreased costs.

4. Search and rescue operations with sUASs will assist local officials with a tool 

that is capable of being deployed faster than and safer than a conventional 

helicopter or small aircraft with a lower risk of personal injury in the case of an 

unforeseen accident.

5. Educational and research projects will benefit from the use of sUAS that 

provide more information in a more cost effective and efficient manner than 

other available options
About Petitioner:

Quicksilver Consulting, LLP DBA National Property Inspections - Conroe

3 Camden Oaks Lane

Montgomery, Texas 77356

Phone: 936 230-3440

Email: Garner@NPI-Conroe.com

NPI-Conroe is a small business serving the needs of the southeastern Texas 

region. NPI-Conroe intends to use sUASs to greatly benefit a variety of projects 

that may include, but not be limited to aerial surveying, construction 

management/progress, property inspections, agricultural projects, aerial 

videography/photography, real estate needs, possible search and rescue, etc.

Reasons why this exemption will not adversely effect safety or how this 

exemption will provide a level of safety at least equal to the existing rule

When compared to small aircraft and helicopters, the following reasons show the 

enhanced level of safety proposed when using sUASs:

 1. The sUASs weigh less than eight (8) pounds

 2. Flights will take place within the visual line of sight of the pilot

 3. Flight times are estimated to be 25 minutes with the PIC monitoring 

battery percentage returning to the ground station with 20% battery 

power remaining

 4. Safety briefings will be conducted with personnel involved with sUASs

 5. Crew consists of sUAS pilot and Visual Observer

 6. The public and bystanders will remain outside the 25 foot radius of the PIC

 
 7. Operation will not be performed in a five (5) nautical mile radius of an 

airport without consent from the airport management.

 8. Flights will take place at an elevation range of 50'-400' and to not 

exceed 400'. 

 9. The sUAS will weigh less than 55 pounds including payload including 

camera, gimbal, etc.

 10. The sUAS will operate at speeds less than 50 knots, hover and 

simultaneously move vertically and horizontally

 11. The sUAS will be capable of returning to and landing at a pre-determined 

location in the event that the communication is lost from the control or satellite 

during flight

NPI-Conroe will adhere to the following regulations including:

 1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. 

Airworthiness Certificates

 2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks

 3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command 

and 61.133 Commercial pilot privileges and limitations

 4. 14 C.F.R. 91.119 Minimum safe altitudes: general

 5. 14 C.F.R. 91.121 Altimeter settings 

 6. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions

 7. 14 C.F.R. 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a)and(b); As 

approved in Exemption 11138 (DOUGLAS TRUDEAU), BHI proposes to inspect and 

ensure that the sUASs is in a condition for safe flight in accordance with the 

operating documents.
Equipment:

 DJI Phantom 3 Advanced

Conclusion:

Satisfaction of the criteria provided in Section333of the Reform act of 2012- size, 

weight, speed, operation capabilities, safety features, and operation within visual 

line of sight- provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of NPI-Conroe’s sUASs to 

conduct aerial services to its clients.

Please feel free to contact our office with any questions or concerns regarding 

this application.

Sincerely,

Garner Gremillion

National Property Inspections - Conroe