) 

I 

The Simple Life LLC. 

535 S. Zerex Street Unit C-205 Fraser Co 80482 

Box 3364 Winter Park Co 80482 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

January 5, 2015 

; . ) 

Re: Petition ofThe Simple Life LLC (SL). for Exemption Pursuant to Sectiorl333 of the FAA 

.Modernization and Reform Act of 2012 

,/,:·;:·--·:-\ 

Dear Gentlemen: !/ ) ~ '\ ..... "'": .. /, /-;~:_.,.,, 

Pursuant to Secti~fi<333 'S)Ithe FAA Modernization and Reform Act of2012 ("FMRA") 

and 14 C.F.R. Part 11, Tli~.:~#p}~(Life LLC ("SL") hereby applies for an exemption from 

Federal Aviation Regulation~-{'-~EA.Rs',J) identified below, to allow commercial operations of ... t' ./'./ .•. 

small, unmanned aerial vehicles by; and t4t'ough small unmanned aerial systems ("sUAS"). 

y'/1/<'>\ " /'· 

This exemption is requested i~ subje~t}~'(.lnd in conformance with those operations and 

protocols outlined in this Petition, the enclosed SL' Flight Operations Manual ("Flight 

Operations Manual") 1

, the sUAS Operato~:.~·:H~ndl>O~~, which includes component parts 

manufacturers' operations and/or instructions.fl1ab:q~Js:(:'pperator's Handbook") and any other 

requirements established by the FAA pursuant to,~~e~~~~· 

I. Description of Petitioner , (/ f/>.~ /'·;,, '·/ /_../ .,) 

The Simple Life LLC is a Colorado corporation that t?:~viyi(sa-:wjde range of Real 

Estate, videography and Photography services. <'~:-<~~·'j/ / .. 

II. Statutory Authority z1.:/. '···~}· 

This petition for exemption is submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. Congress has directed the FAA "to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to consider whether certain 

unmanned aircraft systems may operate safely in the National Airspace ("NAS ") before 

completion of the formal UAS rulemaking, based on the following considerations: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

1 The Flight Operations Manual contains confidential, trade secret and proprietary information that the Petitioner has not and will not 

share with others. Petitioner submits the Flight Operations Manual and all information contained therein as proprietary and 

confidential information pursuant to 14 C.F.R. § 11.35(b). The Flight Operations Manual contains operating conditions and 

procedures that are not available to the public and are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et 

seq. 
U.S. Department of Transportation 

February 18, 2015 

Page 2 

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

If the Secretary determines that such vehicles "may operate safely in the National 

Airspace System, the Secretary shall establish requirements for the safe operation of such 

aircraft in the National Airspace System". 

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S. C.§ 44701(f) (permitting exemptions from§§ 

44701(a), (b) and§§ 44702-44716, et seq.). A party requesting an exemption must explain the 

reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely 

affect safety (or how it would provide a level of safety at least equal to the existing rules). See 

14 C.P.R. § 11.81 (p,etrtiqns for exemption). 

I, ) 

(./ 

III. Qualificat~«;)nsf~~ Approval Under Section 333 of the FMRA 

\·., ,/·/ /' 

The proposed opera1Jofis/~ii.this petition for exemption qualify for expedited approval /r / /• under Section 333 of the Reform;·Act:·Each of the statutory criteria and other relevant factors 

• fi .· 1// /;F< . are satls ted. ~/ /,<. ··<> 

(/ "<:> /) 

/'// ,./'., 

The proposed operations would p~~~'lhe:use of small and relatively inexpensive UAS 

under controlled conditions in airspace thaf is: (V) li}llited; (2) predetermined; (3) controlled as . ' ' ' / " 

to access; and that ( 4) provides an increasectlevel/6fsafety beyond that existing when fixed or / ' ' 

rotor wing aircraft are used to accomplish the s~e··P.JliJ?ose. ' ' / ·. ~·-. /·/. 

Petitioner's sUAS are rotorcraft and fixed-~ti~, ~Yrghir~g 45 or fewer pounds including 

payload. The rotorcraft operates, under normal conditioh'S·; at Jow.:speed and have the capability 

to hover, and move in the vertical and horizontal plane. T~e fix~.~Wing operates, under normal 

conditions, at low speed and moves in the horizontal plane. Petitione(s~U-ASs will operate in line 

of sight and will only operate within those areas described i~ ·tlie~~rtcl<;,s~d Flight Operations 

M 1 1

~. 0# / --·· 

.,.,::.., ...... <~--,_. 

Given the small size of the sUASs involved and the restricted environment within which 

they will operate, this petition exemption falls within the zone of safety i.e., an equivalent level 

of safety, in which Congress desired the FAA to permit commercial UAS operations by 

exemption pending completion of formal rulemaking. Also, due to the size of the sU ASs and 

the restricted area in which the sUASs will operate, approval of the application presents no 

national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained 

in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the grant of the requested exemptions is also in the 

public interest. 
U.S. Department of Transportation 

February 18, 2015 

Page 3 

Accordingly, Petitioner respectfully requests the FAA grant the requested 

exemption without delay. 

IV. Proposed Operations 

The enclosed Manuals describe, in detail, the policies and procedures for Petitioner's 

proposed sUAS operations. To assist the FAA in its safety assessment of Petitioner's proposed 

sU AS operations, below is a summary of operational limitations and conditions, which 

will 

ensure an equivalent or higher level of safety to operations conducted under current regulatory 

guidelines: /?~'· 

(l' )) 

1. Th~:§:lJ~~wi~lJ weigh less than 45 pounds. 

I{ X~ 

2. Flights ~ill::b'{dP,'brated within line of sight of the Operator. ,~?/I· ,./> 

<;i/ rl /;:/ .~~ 

3. Maximum total\:flignf~i¢e for each operational flight will be limited to the 

v /'•"i<'-. ~} 

amount of time tne sUAS&an be flown and still maintain a reserve battery /· 

power of no less than Y.>/~ 

4. Flights will be operated ~~~:u~alt~thd~ of no more than 500 feet above ground 

level ("AGL"). d"'·"~ '-'0 . 

~~-, ~ 5. Flights will be operated at a safe Yateta;l/9i~{~~e from, and not directly above, 

any inhabited structures, buildings, veijicles,"ye'sJels, or people not associated 

with t~e operation or who have not signe<J;;'·~a}~er in advance of the 

operation. <fYct~ .... ::-".e:;:::;. ".? 

¢ ~-J/ .·'> 

6. The sUAS Pilot with Pilot in Command responsibQ;fi~/ror the flight will be 

the designated Operator ("Operator"). ~ 

7. The sUAS will operate only within confined areas as described in the Flight 

Operations Manual. 

8. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day's missions. It will be mandatory that all personnel who will be 

performing duties within the boundaries of the safety perimeter be present for 

this briefing. 

9. The Operator will have been trained in operations of sUAS generally and 

received up-to-date information on the particular sUAS to be operated as 

required in the Flight Operation Manual. 
U.S. Department of Transportation 

February 18, 2015 

Page 4 

10. Written and/or oral permission from the relevant property holders will be 

obtained. 

11. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies. 

12. If the sUAS loses transmission signal, the sUAS will have the capability to 

return to a pre-determined location and land. 

13. Contingency plans will be in place to safely terminate flight if there is a loss 

of transmitter communications or a loss of GPS signal. 

14. Th~:BUJ\S will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. i \ __,, 

""·~', ·:_:--. ~~--- -~ 

V. Regulatio~~ Fr~~_)Yhich Exemption is Requested 

." ':::::-::</ /,/! 

The Federal Aviation Mt/~~Rt:e's~ly grants the FAA the authority to issue exemptions. 

This statutory authority, by its tetnis,,(~ci~des exempting civil aircraft, as the term is defined 

under § 40101 of the Act, including sUAS~,<from its safety regulations and minimum standards 

when the Administrator decides a request¢'d}~X'emption is in the public interest. (/~/ )'> 

Petitioner seeks an exemption from '~ey~r~l~inte:g_elated provisions of 14 C.F.R. Parts 21, 

45 and 91 for purposes of conducting inspectio~'using"sUASs. Listed below are (1) the 

specific sections of 14 C.F.R. for which exemptidp. i~ts~ught, and (2) the operating procedures 

and safeguards that Petitioner has established which~hi.~n:Sill:~, a level of safety better than or 

equal to the rules from which exemption is sought. (/ / ~;:>~ 

/_,/ /-:> 

A. 14 C.F .R. Part 21, Subpart H- Airworthl~ess~Cer,ti(icates and 14 C.F .R. 

§ 91.203(a)(1) <~~~\Jy/ p 

I,_, /./ 

Petitioner seeks an exemption from 14 C.F .R. Part 21, s'it~p~rt H, which establishes 

the procedural requirements for the issuance of airworthiness cerifficates as required by 

14 C.F.R. 

§ 91.203(a)(1). Given the size and limited operating area associated with the sUAS 

to be utilized by the Petitioner, 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 and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. 
U.S. Department of Transportation 

February 18, 2015 

Page 5 

In all cases, an analysis of these criteria demonstrates that the sUAS operated 

without an airworthiness certificate, in the restricted environment and under the 

conditions proposed, will be at least as safe as, or safer than, a conventional rotorcraft 

operating with an airworthiness certificate without restrictions and conditions of the 

proposed sU AS operations. 

Equivalent Level of Safety 

The sUAS to be operated hereunder, DJI Innovations S800 multi-rotor rotorcraft, 

weighs less than 35 pounds with payload, carries neither a pilot nor passenger, carries no 

explosive materials or flammable liquid fuels, and operates exclusively within a secured 

and sterile area. Unlike other civil aircraft, the proposed operations will be controlled and 

monitored by the Operator pursuant to the Flight Operations Manual's requirements. 

/: 

//' 

These safety enhancements, which already apply to civil aircraft operated in 

connection wfth:existl.ng'inspection operations, provide a greater degree of safety to the 

Petitioner's emplot~:_s, $%]Jers of the public, and property owners than conventional 

/- ! . ' 

operations conducted with ail)Votjhiness certificates issued under 14 C.P.R. Part 21, 

Subpart H. Lastly, applicat1ori .of these same criteria demonstrates that there is no credible 

threat to national security p"os~d'by t~~~sUAS, due to its size, speed of operation, lack of 

explosive materials or flammable Jiqmd/,fqels, and inability to carry a substantial external .( ,•' // \ 

load. " /,~ .' 

···-;\, /l/' ~,,~~~~~·· f~l , ' ·,·~<: ' 

B. 14 C.F .R. Part 27 Airworthine$'s'St~ndards: Normal Category Rotorcraft ·----~, './ /< 1 

14 C.P.R. Part 27 sets forth the procedlifalrequi~bp1ents for airworthiness 

certification of normal category rotorcraft. To the:,extent~the.,Petitioner's s U AS would 

otherwise require certification under Part 27, Petitiort~fsee~~an exemption from Part 

27's airworthiness standards for the same reasons identified in_.$.e exemption request <'/ ./'/~· /1 

from 14 C.P.R. Part 21, Subpart H. <(>-~<)'/ / :·~ I ~</.., ,.-" 

C. 14 CFR § 61.113: Private Pilot Privileges And Limt~tions ·-......\_~). 

Petitioner seeks an additional exemption from 14 CFR § 61.113, which restricts 

private pilot certificate holders from flying aircraft for compensation or hire, and which 

would also have the effect of requiring a second class medical certificate. 

Equivalent Level of Safety 

In Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA 

determined that a Operator with a private pilot certificate operating the Astraeus U AS 

would not adversely affect operations in the NAS or present a hazard to persons or 

property on the ground. Additionally, as previously determined by the Secretary of 

Transportation, the requirement to have an airman certificate ameliorates security 

concerns over civil UAS operations conducted in accordance with Section 333. The site 
U.S. Department of Transportation 

February 18, 2015 

Page 6 

surveys and structural inspections conducted by SL occur in areas where access to the 

public is strictly limited and controlled. Under virtually all circumstances, all of the only 

property or structures are owned and operated by the same entity. As a result, the 

operation has no substantial impact on any third persons not involved in the inspection. 

Because SL will operate in a sterile area, the sU AS will be flown based on 

visual line-of-sight at altitudes below 500' AGL. Accordingly, SL request that this 

exemption be granted. 

C.14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and 

Identification Requirements 

Petitioner seeks an exemption from the aircraft marking and identification 

requirements 9'6iita~!led in 14 C.F.R. § § 91.9(c), 45.23(b) and 45.27(a). 

,( .f 

14 C.F.:R:~:§· 9l::;9(c), Civil Aircraft Flight Manual, Marking and Placard 

requirements, pro~ides tllat:..._ 

\'-, // /··' '=~~" > / /:;• i 

No person may op~r,!~f4~~.-registered civil aircraft unless that aircraft is 

identified in accordance wi!h/~.a;ij4~\of this chapter. / ..,.... ..; 

<../ ''<> /) 

Equivalent Level of Safety o .. /"/ --~ ... ·0~·-- "'- f / ..... / /' ) .. ' <</ 1 

The equivalent level of safety Ior~~:(~~pttpps to the aircraft marking and 

identification requirements of§§ 91.9( c ),:45">2~.(b)~nd 45.27(a) will be provided by 

having the sUAS marked on its fuselage as':requtted by§ 45.29(£). '\'> /·/ .'I ,., 

The FAA has previously issued the fol~:~i4~;~)~ipns to the aircraft marking 

requirements of§ 45.23(b ): Exemption Nos. 10700, }Or67 apd 10167 A. 

/- ...,-, ~~- ' .. ~_..~::~i ' 

D. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Man(i~~tin JJ;le Aircraft ),~/ 

Petitioner seeks an exemption from the flight manual re~dj(~:nents of 14 C.F .R. § 

91.9(b)(2), which states: "";~'> 

(b) No person may operate a U.S.-registered civil aircraft-

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of 

this chapter, unless there is available in the aircraft a current approved airplane or 

Rotorcraft Flight Manual, approved manual material, markings and placards, or any 

combination thereof. 

Given its physical dimensions, configuration and load capacity, the sUAS has no 

ability to carry such a manual on the aircraft, not only because there is no pilot on board, 

but because there is simply no room or capacity to carry such an item on the aircraft. 
U.S. Department of Transportation 

February 18, 2015 

Page 7 

Equivalent Level of Safety 

The safety related purpose of this manual requirement can be equally satisfied by 

maintaining the sUAS flight manual at the ground control point where the Operator will 

have immediate access to it. Accordingly, Petitioner requests an exemption from 

91.9(b )(2)'s flight manual requirements, on the condition that the sUAS flight manual be 

available at the control point during each operation. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 

8607,8737,8738,9299,9299A,9565,9565B, 10167, 10167A, 10602,32827,and 

10700. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

/ ;;;=-::::::.~\ 

Petitiotxer sedks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil 

aircraft be in \iirw<?rtliy:cBndition to be operated. Inasmuch there will be no airworthiness 

certificate issued f9l the/§UAS, should this exemption be granted, no FAA regulatory 

standard will exist for:dete"rnlining airworthiness. /..~/' II /) . ·/ ; '/,r/ />· 

Equivalent Level o(.S~f~~y ~~) 

.,;/ '"~ ,;;. ' 

// /' 

The DJI Innovations S800 9-~S:a/~tel!~r safety record, demonstrating that the sUAS 

is airworthy. Further, given the size~{t'the/~~~S and the requirements contained in the 

Flight Operation Manual for maintertanee an~:rpf~-flight safety check lists, an equivalent 

level of safety will be provided. <("\, ~ 

~·t:'/'l/ # 

The FAA has issued the following exem;ti~~{~~SJegulation: Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167{,10167-:A, 10602, 32827, and 

10700. ,¥, ~~·50 

<...--'""'<':-1/ /) 

F. 14 C.F.R. § 91.103: Preflight Action Z/({// 

Petitioner seeks an exemption from 14 C.F.R. § 91.103, w'ilich requires a PIC to 

become familiar with specific information before each flight, including information 

contained in the FAA-approved flight manual on board the aircraft. While the Operator 

will be familiar with all information necessary to safely conduct the flight, an exemption 

is requested to the extent that an FAA -approved flight manual is required on board the 

aircraft. 

Equivalent Level of Safety 

An equivalent level of safety will be provided by following the Operator's 

Handbook. The Operator will take all required preflight actions - including reviewing 

weather, flight battery requirements, landing and takeoff distance, and aircraft 

performance data - before initiation of flight. The Operator's Handbook will be kept at 
U.S. Department of Transportation 

February 18, 2015 

Page 8 

the ground station with the operator at all times. 

G.14 C.F.R. § 91.109(a): Flight Instruction 

Petitioner seeks an exemption from 14 C.F.R. § 91.109(a), which provides that 

"[n]o person may 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 not have functional dual controls. Instead, 

flight control is accomplished through the use of a box that communicates with the 

aircraft via radio communications. 

Equivalent Level of Safety 

Given ~~Gsizf and speed of the sUAS, an equivalent level of safe training can still 

be performed~ without dual controls because no pilot or passengers are aboard the sUAS, 

and all person~:WiU;6e~~.afe distance away in the event that the sUAS experiences any 

difficulties during ;flight instruction. \--,-<~': ,/,. ) 

The FAA has ~~p~~~d/e£emptions for flight training without fully functional dual 

controls for a number of aitct~:f{~'a~for flight instruction in experimental aircraft. 

Exemptions include: Nos. 57~78K~ilnd-9862A. /.)///A 

H.14 C.F.R. § 91.119: Mi~-fi~~fe Altitudes '•,'- /'.' /· 

Petitioner requests an exempti~~-t4~~mwn safe altitude requirements of 

14 C.F .R. § 91.119. Section 91.119 prescnh,e.s tl}.{tpinimum safe altitudes under which 

aircraft may not operate, including 500 feet ab'6ve,1

thistl:rface and away from any person, 

vessel, vehicle, or structure in non-congested are~l,~{~Se7J)4~.F.R. § 91.119(c). Section 

91.119( d) allows f~r a helicopter to operate at less th'}h/th~se~ininimum altit~des when it 

can be operated "Without hazard to persons or property 9:9-:~8:;§/~face," prov1ded that -

.......- . .._,._, / /0 

"each person operating the helicopter complies with any route~,or/~Hfitudes specifically 

prescribed for helicopters by the FAA." >~ (( 

-,~ 

To provide the intended inspections, the sUAS is normally operated below 500 feet 

AGL. Additionally, due the nature of the proposed operations, the sUAS will maintain a 

safe lateral distance from inhabited structures, buildings, vehicles, and vessels, and from 

people not associated with the operation. 

Equivalent Level of Safety 

Compared to flight operations with rotorcraft weighing far more than the maximum 

3 5 pounds proposed herein, and given the lack of flammable fuel, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, and speed of the UAS, as 

well as the location where it is operated. As set forth in the Flight Operation Manual, the 
U.S. Department of Transportation 

February 18, 2015 

Page 9 

sU AS will be operated in a restricted and sterile area, where buildings and people will not 

be exposed to operations without their pre-obtained consent. Because of the advance 

notice to the property owners and participants, all affected individuals will be well aware 

of the planned flight operations as set forth in the Flight Operation Manual. 

Furthermore, by operating at such lower altitudes, the sUAS will not interfere with 

other aircraft that are subject to the minimum safe altitude regulations. Finally, the 

successful safety record of the DJI S800 demonstrates that the sUAS can be safely used 

at these lower altitudes and closer operating environments. 

I. 14 C.F .R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person 

operating an ~1rcraft to maintain cruising altitude or flight level by reference to an 

altimeter tha(is set-~to the elevation of the departure airport or barometric pressure. An 

exemption is\requirea:-be~ause the sUAS does not have a barometric altimeter, but rather a 

GPS altitude read ~\~t. ~/) /0 ~<~:::::</'. / .. -~~.' l // '' /'> Equivalent Level'!of $.af1Jty, , 

An equivalent level f~~J:l be achieved by following the procedures set forth 

in the Flight Operation Manual. A~;P~e.jcti})ed in the Flight Operation Manual, the 

operator will confirm the altitude <o{-"tne la#c!J: site shown on the GPS altitude indicator 

before flight. Moreover, the Operator~-:wHl"us~tQ:(( GPS altitude indicator to constantly 

monitor the sUAS's height, thus ensurinw6p~rati8n.at safe altitudes. 

'·,~~'> v f.J / ' ' 

J. 14 C.F .R. § 91.151(a): Fuel Requirelite#!s:fur,:J(Iight in VFR Conditions 

f '~/ / ··'·, ""' // '>.,) 

Petitioner requests an exemption from 14 C.F.~§ 91,~~51(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states: ij;.::{jl 

(a) No person may begin a flight in an airplane under VFR.,~ditions unless 

(considering wind and forecast weather conditions) there is eno~gh 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. 

Here, the battery powering the DJI Innovations S800 provides approximately 15 

minutes of powered flight. To meet the 30 minutes reserve requirement in 14 C.F.R. § 

91.151, sUAS flights could not be conducted. Given the limitations on the sUAS's 

proposed flight area and the location of its proposed operations within a predetermined 

area, a safety margin based on a reserve amount of battery life is needed. Petitioner will 

not be conducting any sUAS flights at night. 
U.S. Department of Transportation 

February 18, 2015 

Page 10 

Equivalent Level of Safety 

An equivalent level of safety will be achieved because the operations will be 

conducted on-site without significant transit time by the sUAS. All flights will be planned 

to be terminated with no less than 25% reserve battery power still available. This 

restriction would be more than adequate to return the sUAS safely to the ground and its 

planned landing zone from anywhere in its limited operating area even in the event of an 

unexpected occurrence. Operation of the sUAS with less than 30 minutes of reserve fuel 

does not include the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS, and the proximity of the flight operation to the landing 

zone. 

This request for exemption falls within the scope of prior exemptions, including 

Exemption ~<!sff0~73, 2689F, 5745, 10673, and 10808. 

1/ ~~ \\ < ---~. 

K.14 C,~F:R,.~§91~~03(a) and (b): Carrying Civil Aircraft Certification and 

Registration (( )) . 

Petitioner se~~mj)tion from civil aircraft certification and registration 

requirements of 14 C.F.R. !§':91;~~3{~) and (b). The regulation states in pertinent part: 

(> '<> /_:. 

_(a~ E~cept as pro~ided in§(~~~ person may operate a civil aircraft unless it 

has W1th1n 1t the follow1ng: <<-...--"/). / /.~:><."' .. 

-~ -~- /:.~:,. '" 

(1) An appropriate and current airwortiUne.~s/certificate ... ""'' v .. /.. ; ''\,'·'\... //?I '.> / / ; i /., 

(b) No person may operate a civil aircraft ·~le~s"t~~,.airworthiness certificate 

required by paragraph (a) of this section or a spec'ia'l fligpt·~uthorization issued under 

/)/ '~" 

§ 91.715 is displayed at the cabin or cockpit en'~~)'lj1tt it is legible to 

passengers or crew. · <::'/"-..Y. /. // 

(/h// 

In addition to the fact that Petitioner is seeking an exemptl6n from the ".,;"., 

airworthiness certificate requirements, an exemption to this regulation is necessary 

because: (1) the sUAS's configuration, load capacity and size does not allow it to carry 

certification and registration documents; (2) the sUAS does not have a cabin or cockpit 

entrance at which documents could be displayed; and (3) there are no passengers or crew 

for whom the certificates need to be displayed. 
U.S. Department of Transportation 

February 18, 2015 

Page 11 

Equivalent Level of Safety 

To the extent these regulations are applicable to the proposed sUAS operations, 

an equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the Operator will have immediate access to them. 

The FAA has issued numerous exemptions to this regulation, including: 

Exemption 

Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

L.14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(l), 91.409(a)(2); 91.417(a) 

and 

(b): Mainte.,ait~~~l~spections .1 ( ) i ·,\ ""-! 

Petitiori~t-als6:fe6k's an exemption from the maintenance inspection requirements 

contained in 14 C.F\.R. ?'1~.405(a), 91.407(a)(1), 91.409(a)(1), 91.409(a)(2), 91.417(a) 

and (b). These regtilaftQiyS~spesiry maintenance and inspection standards in reference 

to </'. ·' .: /·.· // / . .r· '· v/ -- /<'· 

14 C.P.R. Part 43. See, e.g~/1}!(~ .. f:k. § 91.405(a) (stating that each owner or operator 

of an aircraft "[ s ]hall have tne' aircr~f}1nS,pected as prescribed in subpart E of this part 

and shall between required inspectfons<?:llave discrepancies repaired as prescribed in 

part 43 of this chapter"). An exe~pt{<;)~ tq;th~se regulations is needed because Part 43 

and these sections only apply to airc~hfC\\i~t(_an>~irworthiness certificate, which the 

sUAS will not have. <( '-.,~, ·/--\ 

"-'\.. /./! ,' 

"..·' /, ·~> 

(~ i··.l /. "'' Equivalent Level of Safety It// "'~ 

I / (~' <.0, 

An equivalent level of safety will be achiev:d ~~usffuaintenance and 

inspections will be performed in accordance with the Op/r~toJ~f;Handbook as 

referenced in the <.:;-·-~~I /,) 

Flight Operation Manual. As provided in the Flight Operatiorr:M~riual, the operator 

will ensure that the sUAS is in working order prior to initiatin{tlight, perform '\'>) 

required 

maintenance, and keep a log of any maintenance performed. The operator is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy 

condition to provide the equivalent level of safety. 

If mechanical issues arise, the sUAS's size and carrying capacity, and the fact that 

flight operations will only take place in restricted areas for limited periods of time 

during daylight hours, creates less risk than that associated with conventional rotorcraft 

performing the same operation. 

VI. Public Interest 

Granting SL's exemption request furthers the public interest. National policy set by 
U.S. Department of Transportation 

February 18, 2015 

Page 12 

Congress favors early integration of U AS into the national airspace in controlled, safe 

working environments such as those propose in this petition. In addition, maintaining 

industrial safety has been a priority of state and local governments for decades. 

By their nature, structural inspection sites present unique difficulties for persons 

attempting to inspect and maintain the structure. The components can be tall and have limited 

access. Sending a human observer or using helicopters to inspect such elevated structures 

carry certain risks. These risks can be avoided by using a small U AS under controlled 

conditions to photograph and document the state of the equipment. This helps to facilitate 

repairs and 

identify issues before they become problems. Current options for inspecting structures is 

li~ited to using hum~erso~el. Inspectors will either use a normal ~~tor wing mannedarrcraft or crane ba~J<ets"'tR rmse a human observers to an elevated position. The use of an 

sUAS reduces the fisk to'blJP!an life by removing them from dangerous aspects of the 

inspection process.\~_:}~~~----~~\ ,f r! 

\\ ~/ /> 

In addition, grantin'~'llie~ei9~pti9n will help advance the knowledge base for 

conducting ~ommercia~ UAS<'ripe~~!i~!l~<Jhis additional data will ~elp t~e FAA set fu~ure rules regarding U AS fhght operatiOJlS/ maintenance, and crew qualifications. The pubhc also 

has an interest in reducing the hazatds .dnd"(missions associated with alternate use of 

helicopters to conduct similar inspectio~r6P.,~{atl9ps. The UAS in question is very light 

weight and does not carry any flammabledi.iel, fUrther reducing the risk from any potential 

accident. '\'>.: .::::..-~/ ".,~~ /~ v 

\ -,~ ~ 

VII. Privacy .,.,~ /,/jl 

(/I' /,/ 1>~~>-,, 

All flights will occur over property with the prop~ri)r o/~~iYs .. prior consent 

and knowledge. .:)/ /(// _ 

VIII. Federal Registry Summary :C~J)'; //' 

l/ // (!~/· 

Pursuant to 14 C.F.R. Part 11, the following summary is provide~ for publication in the 

Federal Register, should it be determined that publication is needed: ·.¢ 

The Simple Life LLC seeks an exemption from the following rules: 

14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. 61.113; 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 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 91.407(a)(l); 

14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

Approval of these exemptions allowing commercial operations of small and lightweight 

unmanned aircraft(" s U AS") to conduct structural inspections will enhance safety by reducing 

risk to SL's employees, the general public and property owners. 

The DJI Innovations sUAS, weighing less than 35 pounds, with payload, and powered 

by batteries, eliminates virtually all of that risk given the reduced mass and lack of 
U.S. Department of Transportation 

February 18, 2015 

Page 13 

combustible fuel carried on board. The sUAS is transported to the designated survey area set 

up. It is not flown from an external location to the work-site. The sUAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. 

The operation of this small UAS 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 commercial operations. These lightweight sUASs 

operate at slow speeds, close to the ground, and in a controlled environment. As a result, they 

are far safer than conventional aerial survey and inspection operations conducted with fixed 

wing aircraft or helicopters. 

IX. Conclusion f? -~ 

Satisfaction &t:l~teria provided in Section 333 of the Reform Act of2012-size, ""·~ ,..,.,,, .. ~ ./' ,~ ~ ... . :-.... 

weight, speed, operating/capabilities, proximity to airports and populated areas and 

operation within visuall1ne oJ/J;igh~ and national security-provides more than adequate 

justification for the grant 'ati}\eiequ~_sted exemptions to permit The Simple Life LLC to 

operate sUASs in support of its s_i~~:s4rv~~s and structural inspections, teaching and 

videography in accordance with theJl}tght;Operation and Operator's Handbook appended (/ · .. ,) /,'' hereto. · /;/ 0 . 

/ ,.· ~-''"\\ 

Granting the requested exemptio~,~~ilhe_n]fit .. the public interest as a whole in many 

ways, including (1) significantly improving<safe.,.i)(~ii'tl~,educing risk by alleviating human 

exposure to danger, (2) improving the inspectioij:process"and decreasing operating costs, and 

(3) providing an environmentally conscientious WayL9:f~~nst)l~ting site surveys and structural 

inspections, and (4) providing the general public a plac~Lt§'pr~pxrlY learn about sUAS, and 

( 5) utilizing this technology to capture video and stills foc ~a:fketil)g purposes. 

<>/~<-/ / -·-<.0 

·/· ..,.-/~,/'!/ 

<:,:>,, / /)'> ., 1 / 

) (' '' '.I /:r/ 

VI'/' 

Sincerely, ·--,:::~ 

Parnell Quinn