Eric Olson All Around The House, Inc

General Contractor CCB# 203051 Certified Home Inspector OCHI # 1508 255 N Arney Rd Suite 230 Woodburn, OR 97071

Phone: 503

- 851

- 7234

October 9 , 2015

U. S. Department of Transportation Docket Management System 1200 Ne w Jersey Ave., SE Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151 Following the format of FAA Exemption No. 11138

- Regulatory Docket No. FAA

– 2014

– 0481 I have included:

1) Supplemental Response for Petition 2) 3D Robotics Solo Manual User Manual

Pursuant to Section 333 of the FAA Modernization and Re form Act of 2012 and 14 C.F.R. Part 11, I, Eric Olson

, a professional photographer, videographer, Licensed, Bonded and Insured General Contractor and Certified Home Inspector, I am preparing this exemption request myself, would like to apply for an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and

video of homes an d points of interest for Real Estate Clients and for General Home Inspection purposes

. I have a BA in I ndustrial/Scientific Photography from the Brooks Institute of Photogra p hy . I graduated in 1995. I am licensed in the State of Oregon as a

General Contrac tor and Certified Home Inspector. I have experience in flying hobby quads for recreat ional purposes during the past 4 years without incident. I would l ike to purchase a 3DRobotics Solo quad

- copter ( E quipped with four rotors that are driven by electric motors powered by batteries, the UAS has a maximum airspeed of 48 knots) and add to my inventory equipped with a GoPro 4 HERO Black camera with

intent for Ho me Inspection and ae rial videography/cinematography to enhance personal safety while inspecting areas of real estate that can not be easily accessed or are a part of a roofing system. By adding a UAS, it will greatly diminish the need for me to inspect a roofing system by climbing up on a ladder and walking around for a visual inspection ; following an exemption and approval by the FAA.

My exemption request would permit operation of light weight, unmanned (piloted by

remote control with a live video monito r feed ) in predetermined areas away from general public, airports, heliports and vehicular traffic, under 300 ft. and after carefullyreviewing, inspecting and examining the area of aerial observation. This would allow for community videos and within prope rty boundaries for individual homeowner real estate listing videos/photos. I will abide all FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules and will only operate in a safe environment that is strict ly controlled, are away from power lines, elevated lights, airports and actively populated areas; and I will conduct extensive preflight inspections and protocols, during which safety carries primary importance.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I am asking exemption from 14CFRpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) and (b) (Certifications required ),subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of P.L. 112

- 95 (Section 333).

14 C.F.R. 45.27(a): Location of marks; non fixed

- wing aircraft. 14 C .F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. I understand the need for markings and will mark my UAS in the largest possible lettering by placing the word “Experimental” or assigned number or name (based on a request or ruling by the FAA ) on its fuselage as required by §45.29(f) so that anyone assisting him as a spotter will see the markings. I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) Mainte nance inspections may be required and should be granted since they only apply to aircraft with an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection of my UAS before each flight as outlined in his operating documen ts.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in

command. Under §61.113 (a) and(b) private pilots are limited to non

- commercial operations, however I can achieve an equivalent level of safety as achieved by current regulatio ns because my UAS does not carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting skills. The risks of operating a

UAS are far less than the risk levels inherent in the commercial activities outlined in

14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations. Regarding UAS operational training, as stated previously I have four years’ experience flying hundreds of practice flights as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS’ performance under different temperature and weather conditions. I also practiced on a computer simulated flight software to maintain adequate skills and response reflex

time.14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action If granted an exemption I agree to additional safety procedures including, but not

limited

to:

1) Keeping my UAS within a radius distance of 1000 feet from the controller to both aid in direct line of sig ht visual observation. 2) Operate the UASfor3

- 7 minutes per flight; land my UAS according to the manufacturer’s recommended minimum level of battery power. 3) Operate my UAS only within visual line of sight (VLOS). 4) Use the UAS’ global positioning sys tem(GPS) flight safety feature; it hovers and then slowly lands if communication with the remote control. 5) Conduct all operations under my own personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 150 feet”). 6) I will operate and will actively analyze flight data and other sources of information to constantly update and enhance my safety protocols. 7) Contact respective airports if operations will be within 5 miles to adv ise them of estimated flight time, flight duration, elevation of flight and other pertinent

information. 8) Always obtain all necessary permissions prior to operation. 9) Have procedures in place to abort flights in the event of safety breaches or potent ial danger.

Personal safety is a great concern of mine. I am a husband and father to 6 children and I feel the addition of a UAV will greatly diminish the possibility of severe injury or

death. Also I will be able to add Aerial videography for geographical awareness of real estate marketing

. Aerial inspections have been around for a long time through helicopt ers, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption would allow me to provide this service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to the public given its

small siz e and lack of combustible fuel when compared to larger manned aircraft. The agents I am working for see this as a necessity to market many of their listings. I want to meet the needs of my clients with the confidence that I am under the protection of the FAA guidelines.

Sincerely,

Eric Olson
All Around The House, Inc Licensed, Bonded and Insured Certified Home Inspector

General Contractor

OCHI# 1508

CCB# 203051