D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 1 

# FAA

Exemption Rulemaking

Section 333

Of The

FAA Reform Act and Part 11

Steve Stockton

Drone Your Home, LLC

17428 Pershing Street

Livonia, MI 48152D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 2

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 de veloper 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 t he

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 b y 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, Vo lume 3, Chapter 8 Issue a Certificate of Waiver for

industrial, agriculture, Real State, motion picture, and Television industry.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 3

The name and address of the applicant is:

Drone Your Home, LLC

Attn: Steve Stockton

Phone: 248

- 802

- 4000

Email: Steve@droneyourhome.us

A ddress: 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)

1 4 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)D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 4

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

c onsented 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 th e 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 op erations 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 aircra ft must fly to and from location. In contrast, a UAS

weighing fewer than 10 lbs 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, weighti ng less than 10 lbs., 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 comm ercial

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.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 5

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 lo wer 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 whe n 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 bot h 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 makin g 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:D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 6

. 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 operat e 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 Adm inistrator 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.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 7

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 t han 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

th ey 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 authori ty 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 ass ociated 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 Operatio n 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 SAFETYD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 8

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 r egulatory 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 Ho me, LLC agrees to be bound w hen 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 sig ht (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 pri or 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 ofD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 9

replacement/overhaul component p arts.

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 prese nt for this briefing.

10 . Spotter (Observer) and Pilot will at all times be able to communic ate 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 th e 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 Par t 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 th at 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 cert ificate without the restrictions and conditions proposed.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 10

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 t o 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, a nd 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 “ prov isional, ” 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 beD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 11

placed. Given the size of the sU AV, 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 O perator (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, th e 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 l evel of safety will be provided.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 12

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 r equired 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 configurati on 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 keep ing 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 1060 2, 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 func tioning dual controls. UASs and

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control isD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 13

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 aircra ft.

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 co mplies 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 platf orm 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 opera ted 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 wh ere 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 SettingsD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 14

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 nigh t 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.D r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 15

Applicant believes that an equivalent level of safety can be achi eved 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): Carryin g 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 c abin or cockpit entrance so that it is legible to passengers or crew.

The UAS ful ly 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 d isplay 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

pa ragraph © 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 airworthine ss 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 b ecause 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 theD r o n e Y o u r H o m e , L L C 1 7 4 2 8 P e r s h i n g S t . L i v o n i a , M I 4 8 1 5 2 Page 16

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 i s 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 applica nt ’ 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 intro duction of unmanned aircraft into the national airspace.

Sincerely,

Steve Stockton

Owner

Drone Your Home, LLC

248

- 802

- 4000

Steve@droneyourhome.us