September 25, 2015

Exemption No. 12985

Regulatory Docket No. FAA−2015−0886

Mr. Steve Stockton

Drone Your Home, LLC

17428 Pershing Street

Livonia, MI 48152

Dear Mr. Stockton:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on April 1, 2015 and August 28, 2015, you petitioned the 

Federal Aviation Administration (FAA) on behalf of Drone Your Home, LLC (hereinafter 

petitioner or operator) for an exemption. The petitioner requested to operate an unmanned 

aircraft system (UAS) to conduct aerial photography for industrial, real estate, and 

agriculture.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional, and DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 
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provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Drone Your Home, LLC is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Drone Your Home, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+, Phantom 3 Professional, and Inspire 1when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 
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the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the enclosed COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

boundaries of the operational area as defined by the applicable COA must 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 Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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FAA

Exemption Rulemaking

Section 333

Of The

FAA Reform Act and Part 11

Steve Stockton

Drone Your Home, LLC

17428 Pershing Street 

Livonia, MI 48152
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Attention: US Department of Transportation Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 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); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a)

(2); 91.417 (a) & (b)

Dear UAS Integration at Federal Aviation Administration,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and

14 CFR Part 11, Drone Your Home, LLC, Inc., a research developer and operator of Small Unmanned 

Aircraft

Systems (“UASs”) equipped to conduct aerial photography for industrial, Real State, agriculture, motion

picture, and Television industry for scripted closed set filming, hereby applies for an exemption from the

listed

Federal Aviation Regulations (“FARs”) to allow commercial operation of its UASs (Fixed-wing &

Multi-Rotor), so long as such operations are conducted within and under the conditions outlined herein

or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2)

predetermined 3) controlled as to access and 4) would provide safety enhancements to the already safe

operations in the industrial, film, and television production community presently using conventional and

unmanned aircraft. Approval of this exemption would thereby enhance safety and fulfill the FAA

Administrator’s responsibilities to “...establish requirements for the safe operation of such aircraft

systems in the national airspace system.” Section 333 (c) of the Reform Act. The conditions proposed by

the applicant are drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8 Issue a Certificate of Waiver for

industrial, agriculture, Real State, motion picture, and Television industry.
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The name and address of the applicant is:

Drone Your Home, LLC

Attn: Steve Stockton

Phone: 248-802-4000

Email: Steve@droneyourhome.us

Address: 17428 Pershing St, Livonia, MI 48152

Locations for Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 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); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a)

(2); 91.417 (a) & (b) are:

1. Drone Your Home, LLC Livonia, MI

Regulations from which the exemption is requested:

14 CFR Part 21

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 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)
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Privacy

All flights will occur over private and controlled access property with the property owner’s prior consent

and knowledge. Image capture of people will rarely take place, but in the event they are, they will have

consented prior to being filmed or otherwise have agreed to be in the area where data collection will

take place.

Airborne (Day & Night)

With regard to airborne Drone Your Home, LLC adheres to all FAA regulations. Further DRONE YOUR 

HOME airborne teams operate under the principals of: Safety First, Quality Assurance, Accountability, 

Reporting, and Training. When approved by the FAA it is DRONE YOUR HOME mandate to treat all UAS 

operations the exact same as that of conventional aircraft.

Approval of exemptions allowing commercial operations of UASs in the industrial, agriculture, Real

State, motion picture, and Television industry will enhance safety by reducing risk. Conventional

operations, using jet or piston powered aircraft, operate at extremely low altitudes just feet from the

subject being in extreme proximity to people and structures; and present the risks associated with

vehicles that weigh in the neighborhood of 4,000lbs., carrying large amounts of Jet A or other fuel (193

gallons for jet helicopter shown below). Such aircraft must fly to and from location. In contrast, a UAS

weighing fewer than 10lbs and powered by batteries eliminates virtually all of the risk given the

substantial reduced mass and lack of combustible fuel carried on board.

The UAS is typically transported to the location via auto or cargo van in a medium sized case and is never

flown to set. The UAS will carry no passengers or crew and, therefore, will not expose them to the risks

associated with manned aircraft flights.

The operation of small UASs, weighting less than 10lbs., conducted in the strict conditions outlined

above, will provide an equivalent level of safety supporting the grant of the exemptions requested

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile

environment and, as a result, are far safer than ground than conventional operations conducted with

turbine helicopters operating in close proximity to the ground and people.
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The primary used of interest for Drone Your Home, LLC utilizing UASs are as fallow:

Visual inspections, Photo and Video of:

(1) Photography 

(2) Agriculture Land Mapping

(3) Real State

(4) Telecommunications Towers

(5) Power lines

(6) Structural Integrity

(7) Motion Picture

(8) Television Industry

(9) Search and Rescue

It is estimated that the use of UAS aircraft will reduce hazardous tower climbs Poles Wells etc, Aside

from reducing the number of physical climbs, the utilization of UAS will dramatically lower the use of

cranes and lifts, which also pose dangerous conditions for build and repair personnel. In a number of

instances, inspectors just need to get “eyes on” the tower top assemblies to look for specific

deficiencies. With regard to power lines when climbers are sent in the power must be deferred. The use

of UAS may allow these industries to fill in the data gaps where traditional aircraft are currently

restricted.

It is anticipated that the airborne image capture process will be accomplished in both day and night

environments. Currently, conventional aircraft are flown in highly populated and/or urban areas, with

turbine powered helicopters. The grant of this exemption request will provide improved safety in both

day and night operations. To capture the highest quality of resolution the majority of airborne data

collections will take place during the 10:00am – 6:00pm window.

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section

333 (a) through (c) of the Reform Act. This directs the FAA to consider whether certain unmanned

aircraft systems may operate safely in the national airspace system (NAS) before completion of the

rulemaking required under Section 332 of the Reform Act. In making this determination, the FAA is

required to determine which types of UASs do not create a hazard to users of the NAS or the public or

pose a threat to national security in light of the following:
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. The UAS’s size, weight, speed, and operational capability:

. Operation of the UAS in close proximity to airports and populated areas; and

. Operation of the UAS within Visual Line of Sight (VLOS) of the Operator (PIC) and Observers.

Reform Act §333 (a). Lastly, if the FAA determines that such vehicles “may operate safely in the national

airspace system, the FAA shall establish requirements for the safe operation of such aircraft in the

national airspace system.” Id. §333 (c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority by its terms includes exempting civil aircraft, as the term is defined under

§40101 of the Act, the mat includes UASs, from the requirement that all civil aircraft must have a

current airworthiness certificate. The Administrator may grant an exemption from a requirement of a

regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title

if the Administrator finds the exemption in the public interest.

49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

Applicant interprets this provision to place of the duty on the Administrator to not only process

applications for exemptions under section 333, but for the Administrator to craft conditions herein for

the safe operation of the UAS, if it should be determined that the conditions set forth herein do not

fulfill the statutory requirements for approval.
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Drone Your Home, LLC UASs are multi-rotorcraft, weighing 10 or fewer lbs. including

sensor payload. They operate their multi-rotorcraft, under normal conditions at a speed of no more than

35 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously.

They operate their fixed-wing aircraft, under normal conditions at a speed of no more than 35 knots and

primarily have the flight characteristics of traditional airplanes. They will manually operate only in VLOS

and will operate only within the sterile area described in the Confidential: Flight Operations Manual

(FOM) attached as Exhibit 1 (hereinafter “the Manual”).3 Adherence to the Manual will insure that the

UAS will “not create a hazard to the national airspace system or the public.

Given the small size and weight of the UAS involved and the restricted sterile environment within which

they will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in

which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant

UAS will operate, approval of the application presents no national security issue. Given the clear

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as

amended; the strong equivalent level of safety, surrounding the proposed operations, and significant

public benefit, including enhanced safety, reduction in environmental impacts, including reduced

emissions associated with allowing UASs for inspection and survey operations, the grant of the

requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the

FAA grant the requested exemption without delay.

The Flight Operation Manual is presented as an applicant confidential document under 14

CFR 11.35 (b) as the entire manual contains proprietary methods and information that the applicant has

not and will not share with others. The manual reflects learned experiences, methods, operating

conditions, and procedures that are not available to the public and are protected from release under the

Freedom of Information Act 5 USC 552 et.seq. Reform Act Section 333 (b)

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY
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The applicant proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at least

an equivalent or even higher level of safety to operations under the current regulatory structure

because the proposed operations represent a safety enhancement to the already safe Videography and

Photography operations conducted with conventional aircraft. These limitations and condition to which

Drone Your Home, LLC agrees to be bound when conducting commercial operations under an FAA 

issued

exemption include:

1: The UAS will weigh less than 10 lbs Constructed by high reputation companies, single,

Multicopter base on application.

2. Flights will be operated manually within visual line of sight (VLOS) of the Operator (PIC) and

Observers

3. Maximum total flight time for each operational flight will depend on battery charge, the average

flight will be 30 +/- minutes. Flights will be terminated at 25% battery power reserve should that

occur prior to the 30 +/- minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet

above an elevated platform from which airborne data collection is planned.

5. Minimum two (2) man crew for each UAS operation will consist of the Operator (PIC) and

Observers. In some cases the third aircrew member will serve as the Camera / Sensor Operator.

6. The UAS pilot (PIC) will have a COA prior to conducting any operations, the COA will be

submitted in conjunction with this petition of exemption 333.

7: The UAS will only operate within a confined “Sterile Area”.

8. Drone Your Home, LLC will develop a procedures to document and maintain a record of the UAS

maintenance, preventative maintenance, alteration records, and status of
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replacement/overhaul component parts.

9. A pre-flight briefing will be conducted in regard to the planned UAS operation prior to each

day’s production activities. It will be mandatory that all personnel who will be performing duties

within the boundaries of the safety perimeter be present for this briefing.

10. Spotter (Observer) and Pilot will at all times be able to communicate by voice, radio, and/or

text.

11. Written and/or oral permission from the relevant property holders will be obtained.

12. All required permission s and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

13. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to

a pre-determined location within the Security Perimeter and land.

14. The UAS will have the capability to abort a flight in case of unpredicted obstacles emergencies.

15. The UAS Will 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.

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §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 requirements 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 authorize the FAA to

exempt aircraft from the requirement capability, and proximity to airports and populated areas of the

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the restricted environment and under the conditions proposed will be at

least as safe, or safer, than a conventional aircraft (fixed-wing or multi-rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.
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The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a Pilot nor Observers,

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area

as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly

controlled and monitored by both the Operator, pursuant to safety requirements, and under the

requirements and in compliance with local public safety requirements, to provide security for the area

of operation as is now done with conventional tools. The FAA will have advance notice of all operations.

These safety enhancements, which already apply to civil aircraft operated in connection with

Videography and Photography production, provide a greater degree of safety to the public and property

owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R.

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible

threat to national security posed by the UAS, due to its size, speed of operation, location of operation,

lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

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
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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 Operator (PIC) and Observers 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.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations -Pilot in Command (PIC)

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will not

carry a Pilot or Observers, the proposed operations can achieve the equivalent level of safety of current

operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a

commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the

Operator (PIC) and Observers, the UAS is remotely controlled with no living thing on board. The area of

operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth

in the Manual. The level of safety provided by the requirements included in the Manual exceeds that

provided by single individual holding a commercial pilot’s certificate operating a conventional aircraft.

The risks associated with commercial operations contemplated by Part 61 when drafted, that allowing

operations of the UAS as requested with a private pilot as the PIC exceeds the present level of safety

achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the

requirements contained in the Manual for maintenance and use of safety check lists and a preflight

inspection, all maintenance and alterations will be properly documented in the aircraft records prior to

each flight, an equivalent level of safety will be provided.
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14 CFR §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 which an Airplane or Multi-rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved Airplane or Multi-rotorcraft Flight Manual,

approved manual material, markings, and placards, or any combination thereof.

The 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 board, but because there is no room or capacity to carry

such an item on the aircraft.

The equivalent level of safety will be maintained by keeping the flight manual at the ground control

point where the pilot flying the UAS will have immediate access to it. The FAA has issued the following

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299,

9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety

of flight. As FAA approved multi-rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. An equivalent level of safety will be provided in the Manual. The PIC will take

all actions including reviewing weather, flight battery requirements, landing and takeoff distances and

aircraft performance data before initiation of flight.

14 CFR §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. UASs and

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is
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accomplished through the use of a control box that communicates with the aircraft via radio

communications. The FAA has approved exemptions for flight training without fully functional dual

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos.

5778K & 9862A. The equivalent level of safety provided by the fact that aircraft.

14 CFR §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the

FAA. As this exemption is for a UAS that is a fixed-wing or multi-rotorcraft requests authority to operate

at altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which filming

inspections is planned, an exemption may be needed to allow such operations. As set forth herein,

except for the limited conditions stated in the Manual, the UAS will never operate at higher than 400 ft.

AGL. It will however be operated in restricted area with security perimeter, where buildings and people

will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as

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 operations as set forth in the Manual.

Compared to flight operations with aircraft or multi-rotorcraft weighing far more than the maximum 55

lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less

than those presently presented with conventional aircraft operating at or below 500 ft. AGL in this

industry. In addition, the low-altitude operations of the UAS will ensure separation between these small

UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings
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This regulation 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 UAS may not have a barometric altimeter, but instead a GPS altitude

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator,

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the

GPS altitude indicator before flight.

14 CFR §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 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 battery powering the UAS provides approximately 40 minutes of powered flight. To meet the 30

minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10

minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its

proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR

conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions.

See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners

or official representatives who have signed waivers will be allowed, with less than 30 minutes of

reserved fuel, does not engender the type of risks that Section 91.151 (a) was intended to alleviate given

the size and speed of the small UAS. Additionally, limiting UAS flights to 10 minutes would greatly

reduce the utility for which the exemption will be granted.
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Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or

25% of battery power whichever happens first. This restriction would be more than adequate return the

UAS to its planned landing zone from anywhere in its limited operating area.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification 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 (b) 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 passengers or crew.

The UAS fully loaded weighs no more than 10 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

UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the Pilot flying the UAS will have immediate access to them, to the extent they are applicable to

the UAS.

14 CFR §91.405 (a); 407 (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 © 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 as referenced in the Manufactures Manual. An equivalent

level of safety will be achieved because these small UASs are very limited in size and will carry a small

payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the

UAS can land immediately and will be operating from no higher than 400 ft. AGL. As provided in the

Manual, the operator will ensure that the UAS is in working order prior to initiating flight, perform

required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the
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person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition

to provide the equivalent level of safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2);

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1);

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in

industrial area and industrial operations.

Summary

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed,

operating capabilities, proximity to airports and populated areas and operation within visual line of sight

and national security – provide more than adequate justification for the grant of the requested

exemptions allowing commercial operation of applicant’s UAS in the industrial, Videography and

Photography production industry pursuant to the Manual appended hereto. DRONE YOUR HOME is 

eagerly standing by to support the FAA and UAS community in its quest to establish proper regulations 

and protocols for the safe introduction of unmanned aircraft into the national airspace.

Sincerely,

Steve Stockton

Owner

Drone Your Home, LLC

248-802-4000

Steve@droneyourhome.us