### • 14 C.F.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. §61.113 (a) & (b) limitprivate pilots to non-commercial operations. Because the sUAS will not carry a pilot orpassengers, the proposed operations canachieve the equivalent level ofsafety of current operations by requiring a ground crewmemberto have a private pilot's license rather than a commercial pilot's license to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons onboard. The area of operation is controlled andrestricted, and all flights are planned and coordinated in advance. The risks associated withthe operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations as requested with a Jrivate pilot in the ground crew exceeds the present level ofsafety achieved by 14 C.F.R. §61.1 13 (a) & (b). The equivalent level ofsafety provided by the fact, that neither a pilotnorpassengers will be carried inthe aircraft by the size and speed ofthe aircraft. Enhancing this safety is the technology inherent inthe remote controls utilizing digital communications which is paired to the sUAS making it nearly impossible to unintentionally or intentionally have the control communications interrupted.

14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulationrequires that no personmay operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemptionbe granted, no FAAregulatory standard will exist for determining airworthiness. Giventhe size ofthe aircraft and the requirements containedinthe Manual for maintenance and use ofsafety check lists priorto each flight, a subset ofwhich are provided inenclosed Supplemental material, an equivalent level ofsafety will be provided.

14 C.P.R. §91.9 (b) (2): CivilAircraft FlightManual intheAircraft. §91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) Forwhich anAirplane orRotorcraft Flight Manual is notrequired by §21.5 ofthis chapter, unless there is available inthe aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof. The sUAS, given its size and configurationhas no ability to carry a physical flight manual onthe aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAAhas issued the following exemptions to this regulation: ExemptionNos. 8607,8737,8738,9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. §91.103: Preflight action this regulation requires each PIC to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance databefore initiation offlight. Further, we have proprietary manuals created with the help ofsUAS experts, the manufacturer, the regional sUAS vendor and policy holding

### • insurer and continue to work withthese organizations to ensure best safe practices are adhered to.

14 C.::t;>.R. §91.109: Flight instruction §91.103 provides that no personmay operate a civil aircraft

. (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do nothave fully functional dual controls. Flight control is accomplished through the use ofa control box that communicates withthe aircraft viaradio communications. The FAAhas approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. See ExemptionNos.5778K & 9862A. 

# ' 14 C.F.R. §91.119: Minimum safe altitudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimums prescribed, providedthe person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the behavior ofa helicopter and the exemptionrequests authority to operate at altitudes up to 400 AGL, an exemptionmay be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400AGL orbeyond unaided visual line ofsight, whichever is closer. It will howeverbe operated in a restricted area with security officials tasked with ensuring public safety, and where buildings and people will not be exposedto operations without their preobtained consent and training. The equivalent level ofsafety will be achieved given the size, weight, speed ofthe sUAS as well

as the location where it is operated. No flight operation will be taken without the permission of the property owner inthe case ofprivate property orlocal officials I the case ofpublic property
orprivateproperty with public interests. Because ofthe advance notice to the property owner and participants inthe remote sensing activity, all affected individuals will be aware ofthe planned flight operations. Comparedto flight operations with aircraft orrotorcraft weighting far

more than the maximum 55lb ofDave Lopez sUAS proposedherein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations of the sUAS will ensure separationbetweenthese small- UAS operations and the operations of conventional aircraftthat must comply with §91.119.

14 C.F.R. §91. 121 Altimeter Settings §91.121 requires eachperson operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, confirming the altitude of the launch site shown onthe GPS altitude indicatorbefore flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection ofheight.

### • 14 C.F.R. §91. 121 Altimeter Settings §91.121 requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the sUAS may n_ot have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, confirming the altitude of the launch site shown onthe GPS altitude indicatorbefore flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurate detection ofheight.

14 C.F.R. §9 1.151 (a): Fuel Requirements for Flight inVFR Conditions §91.151 (a) prohibits an individual from beginning "a flight in an airplane underVFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for atleast 30

. minutes; or (2) Atnight, to fly after that for at least 45 minutes:' The battery powering the sUAS provides approximately 15 minutes ofpowered flight inhover mode withoutpayload. Dave Lopez sUAS will notbe able to meetthe 30 minute reserve requirement in 14 CPR §91.151. Operatingthe small UAS, in a tightly controlled areawhere only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of

reserve power, does not engenderthe type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Dave Lopez believes that an equivalent level of safety can be achieved by limiting flights to » 10 minutes or 25% ofbattery powerwhichever happens first. This restriction would be more than adequate to return the sUAS toils planned landing zone from anywhere in its limited operating area. Similar exemptions have beengranted to other operations, including Exemptions 2689F, 5745, 10673.

14 C.P.R. §91.203-(a) & (b): Carrying CivilAircraft Certification and Registrationthe regulation provides inpertinentpart: (a) Except as provided in §91.715, no personmay operate a civil aircraft unless it has within it the following: (1) an appropriate and current airworthiness certificate

... (b) No personmay operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis 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 sUAS fully loaded weighs no more than 55lb and is operated without an onboard pilot. As such, there is no ability orplace to carry certification andregistration documents orto display them onthe sUAS. An equivalent level ofsafety will be achieved by keeping these documents at the ground control pointwhere the pilot flying the sUAS will have immediate access to them to the extentthey are applicable to the sUAS. The FAAhas issued numerous exemptions to this regulation. A representative sample ofother exceptions includes ExemptionNos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.P.R. §91.405 (a); 407 (a) (1); 409 (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 ofthispart and shall betweenrequired inspections, except as provided inII paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart 43 ofthis chapter

...;' and others shall inspect ormaintainthe aircraft in compliance with Part 43. Giventhat these section andPart 43 apply only to aircraft with an airworthiness certificate, these sections will n9t apply to the applicant. Maintenance will be accomplished by the operatorpursuantto the

. flight manual. An equivalent level ofsafety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only inrestricted areas for limited periods oftime. Ifmechanical issues arise the sUAS can land immediately and will be operating from no higherthan 400 feetAGL. The operator will ensure thatthe sUAS is in working order priorto initiating flight, performrequired maintenance, and keep a log ofany maintenance performed. Moreover, the operator is the personmost familiar withthe aircraft and best suitedto maintain the aircraft in an airw rthy conditionto provide the equivalent level ofsafety. An exemption granted to Dave Lopez would permitits operation oflightweight, unmanned, remotely controlled, sUASs in a tightly controlled environmentwith limited airspace. Dave Lopez utilizes local business' safety officers in specifically determined areas (designed flight zone) to mitigate injury andproperty damage while fulfilling clients' goals. Technical enhancements to current safety controls will allowDave Lopez to operate exceeding current safety specifications, and stay ahead of, ormeet, new ones being implemented by the FAAand Department ofTransportation. Further, Dave Lopez conducts its operations in compliance with protocols described herein or as otherwise established by the FAA.

Summarv

Dave Lopez seeks anexemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. 

### § 91.9 (b) (2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R.§ 91.409 (a) (2); and, 14 C.P.R.§§ 91.417 (a) & (b) to operate Dn Phantom 3 sUAS for commercial photograph and video to provide High-end video production, graphic media and sUAS aerial services. This authorization will be usedto provide support services to news organizations, real estate agencies photography, film andmovie production, and inspection companies in a safe environment and infull compliance with federal guidelines. Ifan exemption is grantedto Dave Lopez he will have a unique opportunity offer educationto change the present and an innovative approach to the future. Along with this, brings a chance to share information that will educate and elevate the State ofHawaii and neighboring states across the seato become

more respectful andresponsible operators, hobby enthusiasts and future professional entrepreneurs ofUAS. By granting Mr. Dave Lopez's request for exemptionwill also enhance safety and reduce currentrisk levels as Dave Lopez will operate at lower altitudes and in controlled airspace.

### , In closing, Dave Lopezhas strong ties to his community and the ability to keep its citizens informed about the product and its potential services. This offers a unique role to affectpositive change

... ifexemption is granted. By his relationship with UAS's and the continued sharing of**cuttin~** edge techniques and extraordinary safeguards inplace, the likelihood ofdeath or serious bodily injury are significantly reduced. Drone Services Hawaii LLC Exemption#12675 helped educate and developed Petitionfor exemption for Dave Lopezthe end document user. This step was initiated afterAlaskaUAS interest group annual meeting 2015. This action is a newway forward to ensure a higher level of Safety. Sharing data across exemptionholders will be the way to move forward in solving sUAS integration into the NAS.

Dave Lopez respectfully requests that the FAA grants its exemptionrequest without delay. The FAAhas the authority to issue the exemption soughtby Dave Lopez pursuantto the Federal AviationAct, 85 P.L. 726 (1958), as amended (the "Act").

Sincerely,

Dave Lopez, CEO

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