HonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 1 of 6 

## HonestDrones LLC

C/O Steven Murray

3224

– C N College Rd

Suite 230 Wilmington NC 28405

650

- 241

- 9444
steve@ skylevin.com



### U.S. Dep artment of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3)(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.121, 91.203, 91.151

Dear Sir or Madam :

Pursuant to Secti on 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, HonestDrones LLC.

, represented by Member Steven Murray , a licensed ATP

Multi/Commercial SEL Pilot, hereby appl ies for an exemption from the Code of Federal Regulations (C.F.R) , Federal Aviation Regulations (FARs) identified, to allow commercial operation of lightwei ght Unmanned Aircraft Systems ( UAS) for aerial imaging and video. This exemption is made based on information outlined in this petition, to allow commercial operati on of a UAS aircraft listed below, so long as operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration (FAA) as required by 333.

Aircraft of operation

3D Robotics Aero, 3D Rob otics Aero

‐ M, 3D Robotics Iris, 3DRobotics Solo, 3DRobotics Spektre, 3DRobotics X8+, AEE AP10, AEE F50, AeroVironment Puma, AirRobot AR 180, AirRobot AR200, Altavian Nova F6500, Altavian Nova R8400, AR Drone 2.0, Blade 350 QX,

C9D

‐ BD Butterfly Dragon, C

‐ As tral Bramor gEO, DJI Inspire, DJI Spreading Wings S1000, DJI S800, DJI Spreading Wings S900, E

‐ flight Apprentice, Flyzone Sensei, Cinestar 8, Hubsan Spyhawk, MLB Company Super Bat, Parrot Bebop Drone, PrecisionHawk Hawkeye Mk

‐ III,

PrecisionHawk Lancaster M K3 , Roboflight RF70, Sensefly Ebee, TBM ISR 2.6, TBM ISR 3.0

, Trigger Composites Pteryx, Penguin B UAV, Xfold Cinema HeavyLifter MultiRoter, Xfold Dragon, Xfold SPY, Xfold Travel, and Yuneec TyphoonFreefly Cinestar 6, DJI Phantom 1, DJI

Phantom 2 , Phantom 3, DJI Phantom 4. These aircraft were previously granted in Exemption Number 11493 with the exception of DJI Phantom 4 which will effectively operate similarly to the Phantom 3 in weight and safety.

1 . Types of Operations

T he requested exemption would permit the operation of small, unmanned multirotor

aircraft under controlled conditions to provide the following services to the community;HonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 2 of 6

Real Estate sales advertising Aerial Survey

Aerial Photo/video

Promotional advertising mate rial Inspections

Construction Observation Bridge /Road/Utility Inspections Utility Corridor Vegetation Management Building Inspection Surveys Disaster Response
Aerial observation of structures, land, water, wildlife, vehicles

Closed Set Filming is also requested. The required MPTOM has been submitted in private.

This exemption would permit operation of a n ultra

- light weight, unmanned (piloted by remote control) in predetermined areas away from the general public, airports, heliports,

and vehicul ar traffic. Operations would be conducted within federal guidelines, by a FAA

Licensed Private Pilot with the assistance of a n Observer. Operations would be conducted after carefully reviewing, inspecting, and examining the area of aerial operation to e n sure the safety of persons and property.



### 2

. REQUESTED RELIEF

HonestDrones LLC. Is also 

### requesting a grant of exemption of the following sections of Title 14 of the Code of Federal Regulations:

 14 CFR 21;

 14 CFR 91, et seq;

 14 CFR 45.23 (b);

 14 CFR 61.113 (a) & (b);

 14 CFR 407 (a)(1);

 14 CFR 409 (a)(2);

 14 CFR 417 (a) & (b).

HonestDrones LLC. is 

### also requesting an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations for the following:

 14 CFR 45.23 (b);

 14 CFR Part 21;

 14 CFR 61.113 (a) & (b);

 91.7 (a);

 91.9 (b) (2);

 91.103 (b);

 91.119;

 91.121;

 91.151 (a);HonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 3 of 6 

###  91.203 (a) & (b);

 91.405 (a);

 91.407 (a) (1);

 91409 (a) (2);

 91.417 (a) & (b).

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 91.7 (a)

14 CFR § 91.203 Given the size, weight, speed, and limited operating area

associated with the UAS aircraft to be utilized, I am asking exemption from 14 CFR P art 21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required),

su bject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14 CFR P art 11 and Section 333 of the Reform Act.

The Federal Aviation Act U.S.C. 44701 (f) and 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 analys is of these criteria demonstrated that the UAS operated without an airworthiness certificate, in the restricted environment and under 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

. I request an exemption from 14 CFR 91.7 (a) Civil Aircraft Airworthiness.

14 C.F.R. 45. 23 ( b ): Marking of the Aircraft

Furthermore HonestDrones LLC. request s an exempti on from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two

- inch lettering is difficult to place on such a small

aircraft with dimensions smaller than th e minimal lettering requirement.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed. The word “Experimental” could be placed on the UAS to comply with 45.29 (f) in a size suitable for the available space. The UAS is e quipped with LED lights to aid in visibility.

14 CFR 61.113 (a) & (b): Private pilot privileges an d limitations: Pilot in command

Under §61.113 (a) and(b) private pilots are limited to non

- commercial operations,

however HonestDrones LLC. can achieve an equivalent level of safety as achieved by current regulations because my UAS does not carry any pilots or passengers. I , the owner

of HonestDrones LLC., have a Commercial Pilot/ATP License and will ensure all operations are conducted by a pers on with at a minim um a Private Pilots Certificate and meets the medical requirements for a sport pilot license.

14 CFR 91.9 (b) (2) : Civil Aircraft Flight Manual in the Air craftHonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 4 of 6 An exemption to the part will be needed since there is nowhere to place a c opy of a flight manual on board the UAS.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

This requires each PIC to take certain actions before flight to insure safety of flight. There is no approved flight manual, however the PIC will take actions prior to flight by reviewing the weather, flight battery requirements, and e nsuring there is a s afe location to land and depart so as not to cause undue hazard to people or property on the ground. The

manufactures manual w ill be used prior to flight to e nsure safety.

14 CFR 91.119: Minimum Safe Altitudes

Due to the limitation that operations be co nducted at or below 400 feet AGL, an exemption will be necessary to meet 91.119. The typical UAS flight will be operated as

follows:

1 ) Operate the UAS for less than 60 minutes per flight, land my UAS according to the

manufacturer’s recommended minimum level of battery power.

2 ) Operate my UAS only within visual line of sight (VLOS). 3) Always obtain all necessary permissions prior to operation.

4 ) P rocedures in place to abort flights in the event of safety breaches or potential danger.

14 CFR 91.121 : Altimeter Setting

The UAS is not equipped with an altimeter setting device. GPS will be used on board the UAS to determine altitude by reference to the ground (AGL).

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

An exemption from 91.151 will be necessary as the normal flight time will only be 10

- 4 5 minutes. The UAS is fueled by battery power and a long duration flight is not possible. Also since all flights will be conducted Line of Sight (LOS), this requirement is not appli cable.

14 CFR 91.405 ( a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections

These regulations require the owner/operator to have the aircraft inspected as prescribed in subpart E of this part. An equivalent level of safety will be maint ained because of the small size and limitations of this UAS. Maintenance will be accomplished by the operator pursuant to the owners manual. The operator will ensure that the UAS is in proper working order prior to each flight, perform necessary mainten ance, and keep a log of maintenance. The operator is the person most familiar with the UASs operation and is best suited to maintain in an airworthy condition to provide equivalent level of safety.

3

. Commercial and Public BenefitsHonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 5 of 6 G ranting this exemption will by provide a safe (by way of a n unmanned system) and efficient means to meet technical problems solvable by elevated data collection instruments. Our typical customer base is small to medium size business and individuals who would be unable to acquire this service by manned aircraft due to it being cost prohibited. By moving these functions to UAS based aircraft not only can more people benefit from this service but

it will r educe aircraft noise, pollu tion, reduce airport congestion.

In addition, it will reduce the amount of people and property exposed to the hazards

of a manned aircraft flying at low altitude with the potential for catastrophic results. There

are no combus tibles on

- board the UAS, thus eliminating the risk of explosion and fire due to

a crash. The operation of t his UAS will minimize ecological damage and promote economic growth by providing information to companies in the area that would otherwise be

unavai lable. Additionally

, this system would eliminate a distraction to air traffic control lers

who must monitor an aircraft that usually wants' to take pictures in the "wrong place at the wrong time" thus reducing workload on ATC.

The use of UAS, would allow these services to be provided and thus benefit bot h the community and aviation by:

1. Providing a lower cost to the individual needing these services.

2. Zero emissions from the UAS.

3. Reduced noise over an aircraft. 4. Reduced hazard to people o r property on the ground.

The use of a UAV will provide a level of safety at least equal to existing rules and will only be operated in a safe environment that is strictly controlled. Operations will only be

conducted after a careful review of the area and weather conditions. Safety is the number one priority.

4

. SUMMARY

Granting this exemption is a " win win " situation for individual s in need of this service. The community benefits from reduced pollution and noise. The economy benefits by creating jobs for small businesses. The consumer benefits from reducing the cost of this

service. The FAA benefits by regulating the use of UASs so that safety and accountability

can be maintained and monitored.

Approval of exemptions allowing commerci al operations of UASs in the media will enhance safety by reducing risk associated with conventional aircraft operations. The operation of UASs weighting less than 55lbs by a certified pilot will enhance safety to the community increase awareness of prope rly flow n UASs, eliminate the risk of collision with aircraft operating in the airspace and around airports and provide jobs.

Steven Murray 

## HonestDrones LLC

3224

– C N College RdHonestDrones LLC Request for Exemption for Commercial UAS Operation March 09, 2016

steve@ skylevin.com

Page 6 of 6 Suite 230 Wilmington NC 28405

650

- 241

- 9444