1/26/2016 U.S. Department ofTransportation, Docket Operations Ground Floor, Rrn. W12-140 1200 New Jersey Ave, SE Washington, DC 20590 Rudolph 0. Schlosser 2905 Harrison St. Glenview IL 60025
T: 847-571-7967 rudy@aceinthehorne.net

Regarding: FAAExemption Rulemaking Section 333 ofthe FAAReform Act and Part 11- 14 C.F.R. § 45.23(b); 14 C.F.R. Part21; 14 C.F.R. 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a) & (b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b)
Dear Sir or Madam:
Ace in the Horne Inspection Services, is requesting exemption from the Federal Aviation Regulations ("PARs") listed below and pursuantto the FAA Modernization and Reform Act of2012 and the procedures contained within 14 C.P.R. 11. in orderto commercially operate a small ultra lightunmanned aircraft system ("UAS"), specifically the following UAS platforms will be used:
DJI Phantom III Pro

Attachment 1lists the technical specifications for each ofthe previously listed UAS(s).
The PilotIn Command (PIC) will hold either an airline transport, commercial,private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia,Puerto Rico, a territory, a possession, orthe Federal government. Ace in the Home Inspection Services,would like to expand its operations, and wishes to add the followng photography/videography services.

• Real Estate • Horne Inspections Specifically, it wishes to provide aerial imaging to its customers in need ofaerial photography/videography. With the advancement ofInternettechnology and consumer adoption ofshopping for properties online,the demand for high-resolution aerial graphics and video is unprecedented. In addition, it wishes to be able topetform property (primarily roof) inspections via UAS. All UAS pertinent safety and risk management measures as specified in the FAA's Risk Management Handbook shall be complied with.
A grant ofthe exemption request,by the FAA, would permit operation ofultra lightweight and unmanned UAS to operate in predetermined areas away from the general public, airports, heliports and vehiculartraffic, primarily over individual properties/communities for the purpose ofrecording real-estate listings (photo/video).
In summary and in accordance with this request ofexemptionrequest as authorized and outlined by the FAA under Section 333(c) ofthe Reform Act specifiedfor use ofUAS'for "Real Estate" purposes,Ace in the Home Inspection Services will adhere to all FAA regulations at all times and shall conduct all flight operations in strict compliance and safety protocols as mandated and required by regulations and best practices. Respectfully, we request the grant ofexemption to operate ultra light weight, remote controlled UAS's for commercial purposes as described in this request and as allowable by law. This grant ofexemption will allow the company to offer such services to private and govemement entities who have little to no experience piloting UAS's buthave a need to get images that are only possiblefrom a UAS in orderto compete within an ever demanding technology driven market. Ace inthe Home Inspection Services submits that this application has been prepared by Rudolph 0. Schlosser (owner ofAce in the Home Inspection Services) and not an attorney using his personal knowledge ofexisting FARs as well as utilizing excerpts from other similar applications and assistance from Mile High Drone Services. Consequently, ifRudolph 0. Schlosser has unintentionally omitted any relative FARs,Ace in the Home Inspection Services,humbly request an opportunity to submitto those accidental omissions. The essence ofthis application is to declare that,Ace in the Home Inspection Services meets and exceeds the FAA's expected competencyfor piloting the listed UASs for commercial purposes and thatthe UAS that we specified earlier meets and exceeds the safety requirements as setforth by the Secretary ofTransportation thereby prompting the requestfor COAunder Section 333.


### 1. ContactInformation: Ace in the Home Inspection Services Attn: Rudolph 0. Schlosser 2905 Harrison St. Glenview IL 60025 847-571-7967 rudy@aceinthehome.net


### 2. The Specific section(s) of 

### 14 C.F.R. seeking anexemptionfrom are: 14 CFR 21; 14 C.P.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.P.R. 91,et seq.; 14 CFR407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).


### 3. The extent andreason ofrelief:
Ace inthe Home Inspection Services, is seeking relieffrom existing FARs that currently prohibit the use ofUASs from operating commerciallyfor the purpose ofaerial photography/videography in accordance with the FAAModernization and Reform Act of2012 112 P.L. 95 § 331-334. The Reform Act Subtitle B: UnmannedAircraft Systems- (Sec. 332) "Requires the Secretary to develop a plan to accelerate safely the integration by September 30,2015,ofcivil unmanned aircraft systems (UASes, or drones) into the national airspace system." The company humbly requests that it be allowed to commercially operate the listed UASs during the time periodthe FAA is further establishing rules andregulations governing the operations of such craft.
The Secretary ofTransportation has been asked by Congress to, among otherthings, consider whether certain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe rulemaking required under Section 332 ofthe ReformAct. In making this determination, the Secretary is required to determine which types ofUASs do not create a hazard to users ofthe National Airspace System orthe public orpose a threat to national security in light ofthe following:
The UAS's size, weight, speed, and operational capability; Operation ofthe UAS in close proximity to airports and populated areas; and Operation ofthe UAS within visual line of sight (VLOS) ofthe Pilot andVO Accordingly, all flights will be conducted by a PIC and aVO in accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements for UASs" and with the following restrictions: All aircraft will be made with a UA Gross weight ofless than 55 pounds All flights will occur only during daylight hours. All flights will occur at orbelow 400feetAGL 5 nautical miles from an airport having an operational control tower; or 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a published instrument flight procedure or an operation tower; or 2 NM from a heliport with a published instrument flight procedure. For safety, no flight with winds over 10 mph. Flight only in GPS mode that allows UAS to hoverin place when radio controls are released. All operations to be conducted in GPS mode only.


### 4. Howthe requestwill benefitthe public as a whole: Aerial photography is becoming a critical component ofthe way a company does business. Aerial photography viaUAS allows people to get a vantage point that neverused to be possible or economically feasible. It is much too dangerous and expensive to hire a manned aircraftto take many aerial images thereby making the UAS option more cost effective and safer. There simply is not enough UAS Pilots to coverthe demand for these images, which is leading to unlicensed UAS operators which ultimately results in untrained and unqualified operators. 

### 5. Reasons whythe exemption would not adversely affect safety; orhow the exemption would provide a levelfor safety atleastequaltotheexisting rule:
An exemption would not adversely affect safety because this application applies only to aircraft characteristics and applications within FAA specified limitations. These limitations providefor atleast an equivalent safety standard. However,the experience ofa certificated rated pilot allows him/herto utilize his/her experience in UAS operations thereby exceeding safety and improving airspace operations by allowing aerial imaging clients to choose an pilot that knows how to pilot an aircraft safely and within regulated limits. In addition, by providing unmanned services to the marketplace, there will be less ofa demand for manned operations, which will providefor safer and quieter residential aerial photography. In addition, inspecting roofs via UAS will reduce the risk ofpersonal injury because people who no longerhave to walk on roofs which is inherently dangerous.
As previously stated, all flights will be conducted by a PIC and aVO in accordance with FAAPolicy N 8900.227 Section 14 "Operational Requirements for UASs" and withthe following restrictions:All aircraft will be made with a UA Gross weight ofless than 55 pounds All flights will occur only during daylight hours. All flights will occur at orbelow 400feet AGL 5 nautical miles from an airport having an operational control tower; or 3 NMfrom an airport with a published instrumentflight procedure, butnot an operational tower; or 2 NMfrom an airport without a published instrumentflight procedure or an operationtower; or 2 NM from a heliport with a published instrumentflight procedure. Extensive, pre-flight briefings are required between the PIC and the VO. A flight plan is required priorto each flight. All aircraft operations mustbe conducted within manufacturerrecommended specifications. All site permissions must be obtained priorto flight.
6. A summarythe FAAmaypublish inthe FederalRegister: 14 C.F.R. 21 and 14 C.P.R. 91: Airworthiness Certificates,Manuals and The Like.
14 C.P.R. 21, SubpartH,entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(l).The size, weight and enclosed operational area ofthe listed UASs permitexemptionfrom Part 21 because the listed UASs meets (and exceeds) an equivalent level of safety pursuantto Section 333 ofthe Reform Act. The FAAis authorized to exempt aircraftfrom the airworthiness certificate requirementunder both the Act (49 U.S.C. § 44701 (f)) and Section 333 ofthe Reform Act. Both pieces oflegislation permit the FAA to exemptUAS's from the airworthiness certificate requirementin consideration ofthe weight, size, speed,maneuverability and proximity to areas such as airports and dense populations. The current and projected UAS's meet orexceed each ofthe elements.
14 C.P.R. 91.7(a) prohibits the operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.
14 C.P.R.§ 91.9 (b) (2) requires an aircraft flight manual inthe aircraft. As there are no on board pilots orpassengers, and given the size ofthe UAS's,this Regulation is inapplicable. An equivalentlevel of safety will be achievedby maintaining such manuals onlocation with the Pilot. TheFAAhas previously issued exemptions to this regulation inExemption Nos. 8607, 8737, 8738,9299,9299A, 9565,9565B, 10167, 10167A, 10602, 10700 and 32827.
14 C.P.R.§ 91.121 regarding altimeter settings is inapplicable insofar as all UAS utilizes electronic global positioning systems with a barometric sensor. 14 C.P.R.§ 9l.203 (a) and (b) provides for the carrying ofcivil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalentlevel ofsafety will be achieved by maintaining any such required certifications and registrations with the Pilot.
14 C.P.R.§ 45.23: Marking ofThe Aircraft. Applicable Codes ofFederal Regulation require aircraft to be marked according to certain specifications. The listed UASs are, by definition, unmanned. They therefore do not have a cabin, cockpit orpilot station on which to mark certain words orphrases. Further, two-inch lettering is difficult to place on such small aircraft with dimensions smallerthat minimal lettering requirement. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167Aand 10700.
14 C.P.R.§ 61.113: Private PilotPrivileges and Limitations: PIC.Pursuant to 14 C.P.R.§§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. The PIC can achieve an equivalent level of safety as achieved by current Regulations because the listed UASs do not carry any pilots orpassengers. Further,the PIC possess an FAApilot certificate, which helps his remote control piloting skills and factors in his experience in assessing any flight risks. The risks attended to the operation ofthe listed UASs are farless thanthe risk levels inherentin the commercial activities outlined in 14 C.P.R.§ 61, et seq. Thus, allowing the PIC to operate the listed UASs and meet and exceed current safety levels in relation to 14 C.P.R. §61.113 (a) & (b).
14 C.P.R. 91.119: Minimum Safe Altitudes.
14 C.P.R.§ 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. The listed UASs will never operate at an altitude greaterthan 400ftAGL. The PIC wiiJ also operate the listed UASs in safe areas awayfrom public and traffic, providing a level of safety at least equivalentto or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed ofthe listed UASs, an equivalent orhigher level of safety will be achieved.
14 C.P.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The above-cited Regulations require, amongst otherthings, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter.

.. "
These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to the listed UASs. However, as a safety precaution the UAS which will be used will be inspected before and after each flight.

In Summary:
Ace inthe Home Inspection Services,respectfully requestthatthe FAA grant the exemption request and further volunteer any information gathered during flights in the eventthe FAAis interested in live field data. Ace in the Home Inspection Services, agrees and attests to adhere to any further limitations the FAA imposes, now orin the future. Satisfaction ofthe current criteriaprovided in Section 333 ofthe Reform Act of2012- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line ofsight andnational security- provide more than adequatejustificationfor the grant ofthe requested exemptions allowing commercial operation ofthe listed UASs for commercial purposes. Ace in the Home Inspection Services looksforward to supportthe FAA and UAS community in its quest to establish properregulations and protocolsfor the safe introduction ofunmanned aircraft into the national airspace. Sincerely,

Rudolph 0. Schlosser Ace in the Home Inspection Services 2905 Harrison St. Glenview IL60025Attachment 1
DJI Phantom III Pro (http://www.dji.com/product/phantom-3/spec)

Weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590 mm Max Ascent Speed: 5 m/s Max Descent Speed: 3 m/s Hover Accuracy

• Vertical: +/- 0.1 m (when Vision Positioning is ac-tive) or +1- 0.5 m • Horizontal: +1- 1.5 m Max Speed: 16 m/s (ATTI mode, no wind) Max Altitude Above SeaLevel: 6000 m Operating Temperature: O(C) to 40(C) GPS Mode: GPS/GLONASS