Techon, Inc

56801 Hartley Dr. W

ShelbyTwp, MI 48316

eric@techoninc.com

248-770-9808

February 20, 2016

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012(the reform act) and CFR Part 11, Techon, Inc, owner and operator of 

Small Unmanned Aircraft Systems (UASs), requests to be exempted from 

the Federal Aviation Regulations (FAR) listed below so that Techon, Inc.

may operate UASs commercially in airspace regulated by the FAA., as 

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. 

Techon, Inc (a service and manufacturing company providing services to 

Oakland County, MI and other local businesses and governments) is 

owned by Eric G. Anderson, with a Michigan Drivers license. All operations 

will be performed with the public’s safety and right to privacy safeguarded 

at all times. 

As described below, the requested exception would permit the operation of 

light weight (less than 55 lbs. total takeoff weight) UASs under controlled 

conditions for commercial use thereby enhancing safety and fulfilling the 

Secretary of Transportation’s ( the FAA Administrator’s) responsibility to

”establish requirements for safe operation of such aircraft systems in 

national airspace systems.” Section 333(c), of the Reform Act. 

The quadcopter UAS that Techon, Inc plans to use is a DJI Phantom 3

Professional aglwhich is a rotorcraft weighing less than 4 lbs. including 

payload. It operates at a speed less than 30 knots and has the capability to 

hover and move in the vertical and horizontal plane simultaneously. It has
an auto return to launch point when battery power is under 25%. The UAS 

will operate within the line of sight within a protected flight area as 

described below and at 200 feet above ground level (AGL) or less with an 

observer located close at hand as to make voice communication possible. 

These operations will not create a hazard to users of the nation airspace, 

public nor the environment. 

Techon, Inc respectfully requests the grant of an exception to the following 

specific sections of the Title 14 Code of Federal regulations allowing it to 

operate lightweight UASs for commercial use, 

14 CFR 21, subpart H, 14 CFR 45.23 (b), 14 CFR 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)&(b), 91.417(a) & (b)

Techon, Inc, submits this application in accordance with the Reform Act,

112 P.L. 95 331-334, seeking relief from any currently applicable FAA 

regulations (FAR’S) operating to prevent Techon, Inc, future commercial 

use of small UASs to operate in the national airspace system as described 

below. The reform Act section 332 provides for such integration of civil 

unmanned aircraft into our national airspace system as it is in the public’s 

interest to do so. Techon, Inc’s UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration 

of the UAS is expressly contemplated by the Reform Act. Techon, Inc, 

would like to operate its lightweight UAS prior to the time period by which 

the Reform Act requires the FAA to promulgate rules governing such 

aircraft. 

The Reform Act directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in national 

airspace before completion of the rule making required under Section 332 

of the reform Act. In making this determination, the Secretary of 

Transportation is required to determine which UASs do create a hazard to 

users of the national airspace system or the public or pose a threat to 

national security in light of the following: 

The UAS size, speed, weight and operational capability 

Operation of the UAS in close proximity to airports and populated 

areas 

Operation of the UAS within visual line of sight of the operator 

Reform Act 333(a). If the secretary determines that such vehicles “may 

operate safely in National Airspace System, the secretary shall establish 

requirements for the safe operation in national airspace. 
The UAS will operate only within the line of sight of the operator within a 

protected flight area and at 200 feet AGL or less. These will not present a 

hazard to the national airspace nor the public. 

The very small nature of this UAS combined with the safe guards 

presented below, will allow for the safe operation greater than that 

envisioned by Congress for the FAA to establish and by exemption allow 

commercial operations of this UAS to commence immediately. Also due to 

the size of UAS and the areas and altitudes it will operate approval of this 

exception presents no national security issues and absolutely minimal 

safety concerns which have been mitigated through our rigorous risk 

management process. Given the clear direction given in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as 

amended, the strong equivalent level of enhanced safety, reduced 

emissions utilizing a UAS verses traditional aircraft as well as the 

economic impact of greatly reducing the cost of aerial photography thereby 

benefiting the greater public’s interest. Accordingly, the applicant requests 

that the FAA grant the requested exemption without delay. 

The following will be considered as the binding limitation on operations of 

Techon, Inc. Flights will only occur in the daylight hours, Flights will be 

operated in the line of sight of the operator(PIC) and 

Observer,(VSO) Flights will be terminated at any time weather and wind 

deteriorate to “unsafe for flight” by manufacturers recommendations, 

Specifically, our UAS will weigh less that 4 lbs., Flights will be operated at 

200 feet AGL or less. Crew will be at a minimum an operator(PIC) who is a 

minimum of 17 years old, and an observer and/or camera operator(VSO), 

Operator and crew will remain in contact during the flight operation, The 

UASs operator will perform a check of the flight area and make certain of 

the safety of all persons in the area, Consent will be obtained from all 

persons within the video capabilities of the units to further reduce the 

chance of violating anyone’s privacy. All required FAA clearances, will be 

obtained and distances from airports strictly observed. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane 

under day-VFR conditions unless there is enough fuel to fly to the first 

point of intended landing and to fly after that for at least 30 minutes. The 

UAS is smart battery powered and continually transmits battery charge 

information back to the ground station to be evaluated by the PIC who will 

return the UAS back to the ground station prior to the battery showing 25% 

remaining capacity. We feel that this combined with the fact that the UAS 
will have a maximum range of 1000 feet from the ground station provides 

an equivalent level of safety. Additionally, the UAS will have the capability 

to return automatically to the operator in a safe manner with the auto return 

function checked and working. Flights will only operate in VFR conditions. 

Flight team will communicate by voice and the use of two-way radio if the 

area is too big to hear voice from all team members. The UAS will be used 

to video for bridge, highway inspection, roof inspection and real estate 

sales. When operating over or near water the UASs will be equipped with 

flotation devices so that recovery can be made as to prevent lithium battery 

exposure to the water table. 

14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 

91.203(a)(1) Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary certificates in relation to FAR 

91.203(a)(1). The size, weight and defined area of operations for Techon, 

Inc, UASs flights permits exception from Part 21 because they meet an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The 

FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 USC 4470(f) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UASs 

from airworthiness certificates in consideration of weight, size, speed, 

maneuverability and proximity to areas such as airports and dense 

populations. Techon, Inc, meets or exceeds each of these elements.

As of March 23, 2015 the FAA has stated that it will automatically grant a 

“blanket” COA for flights at or under 200 AGL to any UASs operator with a 

section 333 exemption. 

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and 

registrations. These are inapplicable for the same reasons stated above. 

The equivalent level of safety will be achieved by maintaining such 

certifications and registrations at Techon, Inc, operations center. 

14CFR91.7 (a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by FAR’s this regulation is inapplicable. 14 CFR 

91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 

14 CFR 91.9(b)(2) requires an aircraft flight manual in the aircraft. As there 

are no pilots or passengers, and given the size of the UASs this regulation 

is inapplicable. An equivalent level of safety will be achieved by 

maintaining such certifications and registrations at Techon, Inc, operations 

center. The FAA has previously issued exemptions to this regulation in 
Exemptions No’s 607,8737, 8738, 9299, 9299A, 9565, 9565B, 10167,

10167A, 10602, 10700 and 32827. 

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for 

operation of civil aircraft. It allows helicopters to be operated at lower 

altitudes in certain conditions. Techon, Inc, will only operate its UAS at or 

below 200 feet above ground level (AGL). They will be operated on a well 

defined area of responsibility (AOR) that has been carefully reviewed for 

hazards and minimizes the presence of any persons not essential for these 

operations. Flights will only be over private property that the owner has 

consented and all persons within this video area also give consent for this 

filming. Compared to flight operations of conventional and traditional 

aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 

AGL with flammable fuel UASs operations present a far smaller risk to the 

public. 

Approval of these 333 Exemptions allowing commercial operations of small 

UASs in the service of aerial photography will greatly enhance safety by 

reducing the overall risk associated with traditional aircraft. Traditional 

aerial photography requires large aircraft with flammable fuel to fly in close 

proximity of populated areas and people in general. With the use of small 

UASs of 55 lbs. or less, battery operated and fling below 200 feet AGL the 

risk of injury of people on the ground or the crew has been reduced or 

almost erased. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 

C.F.R. 91.417(a) & (b) Maintenance, Preventive Maintenance, and 

Alterations.

We propose that the PIC perform maintenance and inspection and "be 

authorized to approve the aircraft for return to service." The PIC will 

inspect the aircraft prior to every flight to ensure it is in airworthy condition. 

A maintenance check will also be performed at intervals instructed by the 

manufacturer, DJI. Any general maintenance and repair or replacement of 

components will be completed by the PIC following the manufacturer's 

recommendations and documented in accordance with 91.417. In any case 

where the UAS cannot be returned to service by the PIC, or is suspected to 

be unsafe, the UAS will not be operated until returned to all manufacturer 

specifications. We feel that due to the simplicity, size, robustness and 

construction of the aircraft, the PIC can assure an equivalent level of 

safety. 
Granting Techon, Inc, the above exemption will allow for the expansion of 

UAS systems into the future for the safe conduct of free enterprise and the 

enjoyment of the masses. 

Techon, Inc, respectfully requests the FAA grant its exception without 

delay. The FAA has the authority to issue the exemption sought by 

Techon, Inc, pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as 

amended (the ACT). 

If any of procedures, policies, or content of this request do not meet the 

requirements of an exemption, it is Techon, Inc’s intention to adjust its 

policies in accordance to the FAA's requirements outlined in the granted 

exemption. 

Sincerely 

Eric Anderson

President

Techon, Inc

56801 Hartley Dr. W

ShelbyTwp, MI 48316

eric@techoninc.com

248-770-9808