### Premier Drone Solutions, LLC

Via certified mail : 7014 2870 0001 3021 4534 March 1 , 2016 Carl Young Premier D rone Solutions , LLC 2205 Tuscany Drive Corinth , Texas 76210 214-236-9591 Carl2521@aol
. com Dale Williams Program Analyst Airmen & Airspace Rules Division Federal Aviation Administration 800 Independence Avenue , SW Washington , D
. C
. 20591 Re : FAA-2015-6060- Request for Exempt ion Dear Mr
. W illi ams : I have received and thank you for your letter dated February 23 , 2016 regarding the add itional information needed in order to further consider the above reference d request for exemption under Section 333
. Please note that I am unable to submit this information online using the " Comment " option on the Regulations.gov website , as the Comment option reflects that the comment period for my submission is in closed status , and the option to add a comment is no longer available. Therefore , I am providing this to you in written form and am asking for your assistance in having this information reviewed and a determination made on my request at the earl iest possible convenience
. Thank you very much for your time and assistance
. If there are questions or if additional information is needed please do not hesitate to contact me . Sincerely ,**..,**



# .**~J ·,-**  Carl M
. Young Jr
. Prem i er Drone Solutions , LLC



### Premier Drone So lution s, LLC

### Nam e and Address of Pet ition er: M r . Carl Yo u ng Premier Drone Solutions , LLC 2205 Tuscany Drive Co rinth , TX 76210 

### Docket # FAA-20 1 5-6060 RE: Request for add itional information , letter dated February 23 , 2016 Request for Exemption , Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulat ions 14 C F R 

### §§ 61
.23(a) and (c) , 6 1 .101(e)(4) and (5) , 61
. 113(a) , 61.3 1 5(a) , Part 21 , 91
.7(a) , 91
. 119(c) , 91.121 , 91.151(a)(1), 91.405(a) , 91.407(a)(l) 

### & (a)(2) , 91.409(a)(l) a nd (2), 91.417(a) and (b) Premier Drone So l utions, LLC, the petitioner, requests exemptions in order to legally ope rate an Unmanned Aircraft System (UAS) , as defined under Secti on 333 Subtitl e B (6 ), and speci f ically the DJ I Phantom 3 and/or DJI I nspire 1 , as well as other similar FAA approved , and registered small UAS in the National A i rspace System
. A ll flights of the UAS will be flown , in line of s i ght during daylight hours , at l ess than 175' above ground leve l (AG L) and we ll clear of the flight path of any manned aircraft
. The UAS also uses a smartphone or si m ila r dev ice to enh a nce controls by showing c urrent AG L and v i sua l location of the UAS to the sub j ect and its surround i ngs . T he petiti oner w ishes to be granted the exemption for use of the UAS for commercial data collect ion i nc l ud i ng , but not li m ited to , v i deography and photography of: 1
. Residential and Commercial Rea l E state for marketi ng or analys i s 2
. Construction ( Resident ial and Commercial ), provid i ng a visua l review of the construction process to be used for marketing or analys i s 3. Property Survey , providing a visua l review of the property for marketing or analysis. 4. Property I nspection , providing a vi s ua l rev iew of existing conditions for ma rketing or a n alysis. 5 . Landscaping , providing visual d ocu m entation of ' before and after' improveme nt for ma rketing or analysis
. Using a sma ll UAS substantially re d uces the risk to pub l ic safety in comparison to a manned fixed wing aircraft or roto rc raft. Weig h ing less than 10 pounds , the UASs deployed by P rem ier D rone Solutions are incapable of causing the level of damage or injury that could pote nti a lly be caused by a full - size , manned aircraft. I n add ition , the ecologic and noise impact is negligible as compared to a trad itional manned aircraft
. F urthermore , this valuable servi ce is substantia lly more cost-effect ive than us i ng fixed wing aircraft or rotorcraft , thus providing a means for small bus i nesses to capture p revi ously cost-prohibit ive , but a ll too important , data
. Request for Exempti on , Secti on 333 of the FAA Reform Act pertaining to Federa l Avi ation Regulat ions : 

### 14 CFR Pa rt 21 Certification Procedures For Products and Parts 

### • REASON FOR EXEMPTION It h as been dete rmine d th at similar UAS ' s do not require an airworthiness certificate as granted in E xemption N o . 11623 , 11650 , 11664 , and 11734
.14 CFR 61 .23 Medical Certificate Requirement • REASON FOR EXEMPTION It has been determined that th is requirement is not applicable for these stated purposes , and exemptions have been granted at least twice in exemption #'s 14977 and 14970. 14 CFR 61.101(e)4 Recreational Pilots may not act as pilot in command of an aircraft for compensation or hire. • REASON FOR EXEMPTION It has been determined a recreational license may be used for compensation or hire under these circumstances. See Exemption No.s 14977 and 14970. 14 CFR 61.113(a) and (b) Private pilot privileges and li mitations: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that i s carrying passengers or property for compensation or hire ; nor may that person , for compensation or hire , act as PIC of an aircraft. (b) A private pilot may , for compensation or hire , act as PIC of an a i rcraft in connection with any business or employment if- ( 1 ) The flight is only incidental to that business or employment ; and (2) The aircraft does not carry passengers or property for compensat i on or hire
. • REASON FOR EXEMPTION All flights of the UAS , conducted by the PIC pursuant to the grant of this Petition : (1) will be incidental to Premier Drone Solutions 's business ; and (2) will not carry passengers or property for compensation or hire
. 14 CFR 61.315(a) Sport pilots may not act as pilot in command of an ai rcraft for compensation or hire. • REASON FOR EXEMPTION It has been determined a sport pilot certificate may be used for compensation or hire under these c i rcumstances . See Exemption No
.s 14977 and 14970
. 14 CFR 91.7(a) Civ i l Aircraft Airworthiness : (a) No person may operate a civil aircraft unless it is in an a i rworthy condition
. • REASON FOR EXEMPTION It has been determined that similar UAS ' s do not requ i re an airworthiness certificate , however the petitioner will ensure airworthiness through the combined use of the manufacturer's operations manual and preflight checks
.

# . .

14 CFR 9 1 .119 (c) Mi n imum Safe Alti tu des : (c) Over other than congested areas . 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. • REASO N FOR EXEMPTIO N T he UAS will be flown no higher than 200 ' AG L in line of sight over developed and deve loping resident i al a reas that may be cons idered congested areas . T hat w i ll not always be the case when providing a ' Property Survey' flight because they cou l d be conducted over empty l ots or acreages w ith no structures . T h is w i ll m i n i m iz e the amount of bystanders present or in the surrounding area. I n the case of flying over or near existing private property while provi d i ng photography for ' Resident i al and Commercia l Marketing ',**Co stru~tio** **n** P rocess ', ' Property I n spection ' , and ' Property Landscap i ng ' landowners w i ll be n otif ied i n person by the petitione r , or by a card left behind by t he petitioner, of a n occurring UAS flight. T he petitioner also proposes to d isplay a caut ion sign on site while a UAS flight is ongoing. T he petitioner will review with the landowners the associated risks to people and property . Due to the small s ize of the UAS the associated risk to persons , vessels , vehicles , and structures is not comparab le to manned aircraft
. 14 CFR 91.121 Alt i meter Settings
. • REASON FOR EX EMPTIO N T he UAS does not have a barometric al t imeter
. It does have a G P S that will calculate altitude
. The petiti oner w i ll li m it fl ights to a maxi mum altitude of 175 feet AGL as granted in Exempt ion No
. 11623, 11650 , 11664, and 11734
. 14 CFR 91. 1 51 F uel requirements for flight in VFR condit ions • REASON FOR EXEMPTION The UAS provides low battery warnings to indicate when the P il ot in Command should return the UAS to the launch point. The UAS will be ian ded upon the 1st low battery alert
. T he petitioner will not initiate a flight unless (considering wind and forecast weather cond itions) there is enough power to fly at normal cruis i ng speed to the intended landing point. All flights will be done during the day and at an appropriate time as to not be a nu i sance to others
. 14 CFR 91.405(a) Mai ntenance requ i red : E ach owner or operator of an aircraft : (a) Shall have that aircraft i nspected as prescribed in Subpart E of this part and shall between required i nspecti ons , except as provided in paragraph (c) of th i s section , have discrepancies repaired as prescribed in part 43 of t h i s chapter. • REASON FOR EX EMPTION

# ..

The pet itioner shall inspect the aircraft p rior to every flight. The petitioner plans to follow manufacturer's recommended preflight checklist. 14 C FR 91 .407(a)(1) Operati on after mai ntenance , preventive ma i ntenance , rebuilding , or alteration : (a) No person may ope rate any aircraft that has undergone maintenance, preventive maintenance , rebuilding , o r alteration un less(1 )It has been approved for retu rn to service by a person a uth orized under 43
. 7 of th i s chapter • REASON FOR EXEMPTION The petitioner who has the responsibility for the operation and safety of the UAS w i ll follow the manufacturer's suggestions for maintenance and repair , i ncluding the use of suggested rep l acem ent parts. 1 4 CFR 91 .409(a)( 1) & (2) I nspections : (a) Except as provided in paragraph (c) of this section , no person may operate an aircraft unless , w ithin t he preceding 12 ca lendar months , it has had (1 ) An annua l i nspectio n i n accordance with part 43 of this chapter and has been approved for return to service by a person a uthorized by 43
. 7 of this chapter; or (2) An i nspection for the issuance of an airworth i ness cert ifi cate in accordance w ith part 21 of this chapter
. No i nspection performed under paragraph (b) of this section may be substituted for any inspection required by th i s paragraph unless it is performed by a person authorized to perfo rm annua l i nspections and is ente red as an "annual" inspecti on in the required maintenance records
. • REASON FOR EXEMPTION The petitioner w i ll follow manufacturer' s suggesti ons to ensure that the UAS i s in a cond ition for safe fl i ght. 14 CFR 91.417(a) & (b) Maintenance Records : (a) Except fo r work performed in accordance with 91.411 and 91.413 , each registered owner or operator sha ll keep the fo ll owing records (l)(i)(ii)(iii) (2)(i)(ii)(iii)(iv)(v) (vi ) for the periods speci fied i n paragraph ( b) of th is secti on : ( 1 )(2)( 3) • REASON FOR EXEMPTION The petiti oner will keep a record of all repai rs and mod ifications
. The petitioner will also use manufacturer approved parts for repa i rs and modifications. SUMMARY P remier D rone Solutions , LL C , the petition e r , requests for exemption Section 333 of the FAA Reform Act pertaining to F ede ral Aviation Regulations 14 C FR 

### §§ 61
.23(a) and (c) , 61
. 101 (e)(4) and ( 5) , 61
. 113 (a) , 61
. 315 (a) , Part 21 , 91
.? (a) , 91
. 119 (c) , 91.121 , 91.151 (a)( 1} , 91
.405 (a } , 91.407(a)(l) & (a)(2) , 91.409(a)(l) and (2 }, 91.417(a) and (b) i n order to legally operate an Unmanned Aircraft System in the National Airspace System in order to collect data including , but not li m ited to , aeri al video a n d photography for rea l estate marketing , construct i on , survey , landscape and i nspection purposes . This submiss i on is substantially simila r to granted exemptions 14977 and 14970
.