January 23, 2016 Bullitt Auto Detail & Vinyl Wraps Page: 1

Bullitt Auto Detail & Vinyl Wraps

168 Manchester Trail

Clayton, NC 27527

919-368-7487

Mr. Kenneth W. Mahlschnee

bullittautodetail@gmail.com

January, 23, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of

2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Bullitt Auto Detail & Vinyl Wraps, pursuant to Section 333 of the FAA Modernization and Reform Act

of 2012 (Reform Act), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, requests an

exemption from the Federal Aviation Regulations (FARs) listed below and discussed in Appendix A

to allow Bullitt Auto Detail & Vinyl Wraps to conduct commercial operations with small Unmanned

Aircraft System (sUAS) to provide aerial film making, photography, and videography primarily for 

privately owned customized vehicles. Also availability for surveying, data acquisition, site, structural 

and patrolling inspections for pipeline, energy, utility, construction, real estate, precision agriculture 

and other industries, search and rescue, remote sensing, community awareness, education, training 

and research operations when called upon.

Performing these services with a sUAS is in the public interest for several reasons, which are

detailed further herein and include: (1) dramatically reducing safety risks inherent in manned 

operations, both in the air and on the ground; (2) inspecting locations where humans are not able 

visit without incurring substantial risk; (3) enhancing capabilities to utilize the sUAS to assist first

responders on safety or environmental incidents; (4) and improving access to and control of 

various sites and operations.

The use of the sUAS for these services will reduce the need to either operate manned aircraft in a

difficult environment and reduce the environmental impact of conventional aircraft operations or add 

to the safety when other non-aircraft related methods prove hazardous or risky. In addition, the

small, lightweight, and easily controllable operating characteristics of the sUASs’ provide for safe

operations over site locations.
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Exemptions Requested

Bullitt Auto Detail & Vinyl Wraps requests exemptions from the following regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 91.7(a);

14 C.F.R. 91.119(c);

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) and (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(1) and (2);

14 C.F.R. 91.417(a) and (b).

Operating Conditions

Bullitt Auto Detail & Vinyl Wraps requests an exemption subject to the conditions listed in

Appendix B, which are substantially similar to the operating conditions required for the FAA’s

previous grants of exemptions under Section 333.

In accordance with the conditions approved in previous exemption grants, Bullitt Auto Detail & Vinyl

Wraps is requesting authority to operate the sUAS within visual line of sight and below 400 feet 

AGL except as provided by FAA Air Traffic Control via COA.

Operator Requirements

As a condition to the grant of the exemptions, Bullitt Auto Detail & Vinyl Wraps will require that the

PIC be solely operated by the owner/operator Kenneth Mahlschnee. Kenneth Mahlschnee has over 

200 flight cycles logged and only will fly during daylight hours, as required by the FAA.
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Public Interest

Bullitt Auto Detail & Vinyl Wraps respectfully submits that its use of the sUAS in lieu of manned

operations, which are currently conducted with conventional fixed and rotary winged aircraft,

offers increased safety benefit and will achieve an enhanced level of safety, as mandated under

Section 333(c) of the Reform Act. Approval of this application also will benefit the public interest

by allowing better, safer, and more cost efficient information gathering for various industries.

Conventional aerial survey and inspection operations using manned aircraft involve very heavy

aerial vehicles that must transit to the operational location and carry significant quantities of

combustible fuels and a multi-person crew in piloting and observation roles. 

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 and 49 U.S.C. § 44701(f), the equivalent and enhanced level of safety of the 

proposed operations, the significant public benefit, and cost savings to be realized as a result of the

use of sUAS for aerial inspection and survey services. Moreover, the FAA has already granted 

similar exemptions for sUAS used to conduct high-resolution aerial imaging and surveying 

operations. 

Privacy Concerns

The proposed operations will take place only in authorized areas that are owned or leased, by

the owner of record. No privacy issues are raised by this application.

Sincerely,

Kenneth Mahlschnee

Bullitt Auto Detail & Vinyl Wraps
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APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Bullitt Auto Detail & Vinyl Wraps requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the sUAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for

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

weight of the aircraft, the operating conditions, design safety features, and the proposed conditions

and limitations, it is unnecessary to go through the certificate of airworthiness process under Part 21 

Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333. Section 333 and 49 U.S.C. § 44701(f) 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 sUAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer,

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The sUAS

weighs less than 10 pounds fully loaded. It will not carry a pilot, passenger or flammable fuel. The

sUAS operates exclusively within a controlled area pre-disclosed and in compliance with conditions

set forth herein. Unlike other civil aircraft, operations under this exemption will be tightly controlled

and monitored by the PIC and observer(s), pursuant to the conditions set forth in Appendix B, the

Operator’s Manual, and local public safety requirements. The FAA will have advance notice of all

operations through the filing of NOTAMs. The lack of flammable fuel and the fact that the aircraft is

carried to the location and not flown there all establish the equivalent level of safety. The sUAS

provides at least an equivalent level of safety to that of such operations being conducted with

conventional aircraft that would be orders-of-magnitude larger and would be carrying passengers,

cargo, and flammable fuel.

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

The regulation requires that 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 sUAV, 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 sUAV marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the sUAV 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. 
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14 C.F.R. § 91.7(a): Minimum Safe Altitudes

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy

condition. No FAA standard exists for determining an aircraft’s airworthiness when an

airworthiness certificate is not issued. As the FAA has done with previous exemption grants,

airworthiness will be ensured and an equivalent level of safety will be achieved by compliance

with the operating documents prior to every flight.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above

the surface, except over open water or sparsely populated areas. In those cases, the aircraft may 

not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Because some of

the aerial inspection and survey work must be accomplished at altitudes less than 500 feet AGL and

nonparticipating employees may be working within 500 feet of the sUAS, an exemption from

Section 91.119(c) is needed.

The equivalent level of safety will be achieved because the sUAS, given its size, weight, speed, and

materials, does not pose a serious risk. Compared to aerial inspection operations conducted with

aircraft or rotorcraft weighing far more than 10 pounds and carrying flammable fuel, any risk

associated with these operations will be far less than those currently allowed with conventional

aircraft operating at or below 500 feet AGL. Exemption Nos. 11156, 11158, 11159.

14 C.F.R. § 91.121: Altimeter Setting

Section 91.121 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 is required. An equivalent level of safety will be achieved by the

operator, pursuant to the Operator’s Manual, confirming the altitude of the launch site shown on the

GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation 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 sUAS

batteries provide approximately 50 minutes of powered flight. Without an exemption from 14

C.F.R. § 91.151, the sUAS’s flights would be limited to approximately 10 minutes in length

because the PIC would require the last 30 minutes to satisfy section 91.151(a). Given the

limitations on its proposed operations, a longer time frame for flight in VFR conditions is reasonable.

Bullitt Auto Detail & Vinyl Wraps believes that an exemption from 14 C.F.R. § 91.151(a) provides an

equivalent level of safety and is consistent with prior exemptions. Operating the sUAS, without 30

minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was meant

to prevent given the size and speed at which the sUAS operates. In the unlikely event that the 

sUAS’ battery runs low, it would simply follow the pre-programmed command to land at a 
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designated location, usually the departure point. Given its weight and construction material, the risks

are less than contemplated by the current regulation.

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b): Maintenance

Inspections

Section 91.405(a) requires 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.”

Section 91.407 similarly makes reference to requirements in Part 43. Section 91.409(a)(2)

requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a)

requires the owner or operator to keep records showing certain maintenance work that has been

accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval

of the aircraft for return to service. A qualified person prior to each flight and at predefined intervals 

as part of the maintenance schedule will perform pre-flight checks.

The pre-flight checklist includes but may not be limited to:

1. Visual inspection of the airframe;

2. Visual inspections of propeller;

3. Verify GPS acquisition;

4. Plan and upload mission;

5. Video and payload check;

6. Controls check;

7. Gyro/control surfaces check;

8. Throttle check

9. Altimeter check;

10. Check sensors; and

11. Verify failsafe’s are set correctly.

An equivalent level of safety will be achieved because the sUAS will carry no external payload, will

operate only in restricted predetermined areas, and is not a complex mechanical device. In addition,

the operator will ensure that the sUAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is

the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy

condition and to ensure an equivalent level of safety.
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APPENDIX B

Bullitt Auto Detail & Vinyl Wraps Operation Limitations

1. Operations authorized by the grant of exemption are limited to the sUAS that weigh less

than 55 lbs.

2. The sUAS will not be operated at a speed exceeding 87 knots (100 miles per hour) based on 

either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the sUAS be operated at airspeeds greater than the maximum 

sUAS operating airspeed recommended by the aircraft manufacturer. 

3. The sUAS will not be operated at an altitude more than 400 feet above the highest 

predominant terrain except as may be provided by FAA Air Traffic Control (ATC) via COA.

The highest predominant terrain is the defined as terrain within 1 mile of the launch point

and within the visual line of sight of the PIC. All altitudes reported to ATC shall be in feet

AGL.

4. The sUAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective

lenses, as specified on the PIC’s FAA-issued airman medical certificate.

5. All operations must use a visual observer (VO). The VO and PIC must be able to

communicate verbally at all times. The PIC must be designated before the flight. The PIC

must ensure that the VO can perform the functions prescribed in the operating documents.

6. The operating documents and this grant of exemption must be accessible during sUAS 

operations and made available to the Administrator upon request. If a conflict exists 

between the conditions and limitations in the exemption and the procedures outlined in the

operating documents, the conditions and limitations in the exemption take precedence and

must be followed. Otherwise, Bullitt Auto Detail & Vinyl Wraps must follow the procedures

as outlined in its operating documents. 

7. Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for safe

flight. The PIC shall not operate the aircraft if the inspection reveals a condition that affects

the safe operation of the sUAS until the necessary maintenance has been performed and

the sUAS is found to be in a condition for safe flight. The Ground Control Station, if

utilized, must be included in the preflight inspection. All maintenance and alternations must

be properly documented in the aircraft records.

8. Any that has undergone maintenance or alterations that affect the sUAS operation or flight

characteristics (e.g., replacement of a flight critical component) must undergo a functional

test flight in accordance with the Operator’s Manual. The PIC who conducts the functional

test flight must make an entry in the aircraft records of the flight. The requirements and

procedures for a functional test flight and aircraft record entry shall be included in the

Operator’s Manual.

9. The pre-flight inspection must account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating

documents.
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10. The operator must follow sUAS manufacturers component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

11. Bullitt Auto Detail & Vinyl Wraps must carry out its maintenance, inspections, and record

keeping requirements, in accordance with the operating documents..

12. The sUAS operated under this exemption must comply with all manufacturer Safety

Bulletins or Airworthiness Directives if applicable.

13. Bullitt Auto Detail & Vinyl Wraps may not permit any PIC to operate the sUAS, other than 

stated, Kenneth Mahlschnee.

14. Operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual flight rules (VFR) conditions. Flights under

special visual flight rules (SVFR) or instrument flight rules (IFR) conditions are not authorized.

15. The sUAS may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA published aeronautical chart unless a letter of agreement with

that airport’s management is obtained. The letter of agreement with the airport management

must be made available to the Administrator upon request.

16. The sUAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

17. If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter and land or be recovered in accordance

with the Operator’s Manual.

18. The PIC must abort the flight in the event of unpredicted obstacles, other aircraft incursions

or emergencies in accordance with the Operator’s Manual.

19. sUAS operations must be completed within 50 minutes flight time.

20. All aircraft operated in accordance with the requested exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number)

markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as 

practicable.

21. The radio frequency spectrum used for operation and control of the sUAS must comply

with Federal Communication (FCC) or other appropriate government oversight agency

requirements.

22. The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the PIC

at the Ground Control Station of the sUAS any time the aircraft is operating. These

documents shall be made available to the Administrator or any law enforcement official upon 

request.

23. The sUAS must remain clear and yield the right of way to all other manned operations and

activities at all times.

24. The sUAS may not be operated over congested or densely populated areas.
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25. Flight operations must be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, structures, and public access roads unless if operated near vessels,

vehicles or structures where the owner / controller of such vessels, vehicles or structures

has granted permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present an undue hazard.

26. Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons as

defined in the operating documents are permitted if those operations do not present an

undue hazard to those persons per § 91.119(a) as determined by the PIC.

27. All operations must be conducted over private or controlled access property unless an 

exception is granted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA shall be reported to

the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB.

APPENDIX C

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION

sUAS Operating Overview: The sUAS utilized are either a fixed or rotary-wing aircraft constructed

of foam or rugged polycarbonate materials. The aircraft are easy to assemble or come preassembled. The sUAS can be operated manually or in fully autonomous flight modes. Creating preplanned flight paths in autonomous mode is as simple as clicking on reference points on a georeferenced maps. Pre-mission waypoints, landing zones, and flight area dimensions can be entered 

during preflight planning ensuring the sUAS operates only within specified boundaries and predetermined flight parameters.

The DJI Phantom 3 (Professional) is a fixed wing drone.

The Phantom is a battery-powered drone allowing flight times up to 23

minutes. Diagonally it measures approximately 590mm (23.25 inches) 

including rotor blades. Takeoff weight is 1280 grams.

Many advanced safety features makes these drones on of the safest choices for commercial 

operations. Safety features include geo-fencing, position hold and self-leveling, return home, 

emergency landing and stop.

Operator’s Manual – The respective UAS Operator’s Manual, provided by the respective 

manufacturer, will be followed at all times and available during all appropriate flight operations.
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Takeoff and Landing style/type – The sUAS is ground or hand launched and can be tube launched 

with additional equipment. The sUAS lands by returning to a pre-determined rally point. Once it

reaches a pre-selected altitude, it heads toward the landing waypoint, descending until it lands and / 

or skids to a stop.

Navigation System – Specific maps can be downloaded to the display screen (such as VFR air 

sectional and geographic maps), which are overlaid with GPS positional data. Waypoints can be

created before and during flight operations creating specific locations and sequences for the aircraft

in use.

Defined “Keep Out” Areas – The navigation software allows for preplanning Keep Out Areas, also 

know as geo-fencing, that allow the operator to designate airspace he or she does not want the

sUAS to enter. If defined flight paths pass through an area designated as keep-out, the individual 

waypoints and waypoint connection segments turn red as a warning. Additionally, if a mission is

uploaded and intersects with a keep out area, a warning is presented to the user. Also, if an aircraft

in flight is navigated into a designated keep out area, an audible warning is sounded.

Maintenance – The sUAS require very little maintenance, and operators may perform most required

maintenance in the field with the field repair kit.

Command and Control Systems - The sUAS Ground Control Station (GCS) allows the operator

simultaneous control over aircraft and payloads. The display screen provides all essential flight data

to the operator. Telemetry data is transmitted to the command station at least once per second.

Displayed on GCS:

● Current position

● Registered home position

● Any autopilot flight plans

● Registered emergency landing zone

● Aircraft attitude

● Altitude

● Airspeed

● Groundspeed

● Compass reading/heading

● Estimated wind heading

● Communication strength

● Range from home

● Bearing from home

● Duration of current mission

● Rate of climb

● Mode of the aircraft

● Battery level

Emergency Procedures and System Failures

Loss of Link – The sUAS does not need constant signal from the GCS to continue flying.

Communications outages are detected by the system and are reported to the PIC. During the

communication outage, the sUAS continues on its pre-determined flight path until a failsafe is

triggered. Once a failsafe is triggered, the sUAS will perform in accordance with the failsafe

conditions uploaded before launch. This is accomplished without input from the operator.