Techon, Inc 56801 Hartley Dr. W ShelbyTwp, MI 48316 eric@techoninc.com
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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 Regul ations (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
Sect ion 333.

Techon, Inc (a service and manufacturing company providing services to
Oa kland County, MI and other local businesses and governments) is owned by Eric G. Anderson , with a Michig a n 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 controlle d
conditions for commercial use thereby enhancing s afety 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 th at Techon, Inc plans to use is a DJI Phantom 3
Professional agl which is a rotorcraft weighing less than 4 lbs. including payload. It operate s at a speed less than 3 0 k nots and has the capability to hover and move in the vertical and horizontal plane simult aneously. It hasan 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 meet s the definition o f “small
unmanned aircraft” as defined in Section 331 and t herefor e 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 Sect ion 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 fol lowing:

The UAS size, speed, weight and operational capa bility Operation of the UAS in close proximity to airports and popul ated

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 Sy stem, 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 o perations of this UAS to commence immediate ly. 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
emiss ions utilizing a UAS verse s 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 fo llowing 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 recommendation s,

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 remai n 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 r educe 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 ba ck 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 UASwill have a maximum range of 1000 feet from th e ground station provides an equivalent level of safety. Additionally, t he 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 n ear 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 Airwort hiness 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 equiva lent 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 F AA 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 inappl icable 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 thi s regulation inExemptions 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 helicopter s to be operated at lower
altitudes in certain conditions. Techon, Inc

, will only operate its UAS at or
below 200 fee t above grou nd level ( AG L ) . They will be operated on a we ll
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 traditio nal 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 o f 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 genera l. 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 1 4 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 whe re 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 PI C 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 And erson President Techon, Inc 56801 Hartley Dr. W ShelbyTwp, MI 48316 eric@techoninc.com
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