Drone Your Home LV, llc

Joshua S. Arnold

215 quest park st apt 1017

Henderson, NV 89074

pcs: 702.981.1001

email: josh@droneyourhome.us

Date: September 8, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

SE Washington, DC 20590

RE: Petition of Utility Aerial Services, Inc. for Exemption Pursuant to Section 333

of the FAA Reform Act

Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act)

and 14 C.F.R. Part 11, Drone Your Home LV LLC, operator of Small Unmanned Aircraft

Systems (“sUASs”) equipped to conduct aerial photography and videography, hereby applies for

an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial

operation of its sUASs, so 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 333.1

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1)

limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow

Drone Your Home LV LLC to conduct commercial operations of small unmanned aircraft

systems (“UAS”) meeting or exceeding all of the operational and safety requirements Congress

has set forth in Section 333.

Drone Your Home LV LLC is a media/technology company that plans to exploit the capabilities

of Unmanned Aerial Systems to offer a multitude of services, including:

­ Aerial surveying

­ Remote sensing

­ Event Photography/Videography

­ Agriculture purposes

­ Real Estate Photography

­ Aerial filmmaking and photography

­ Construction site inspections and monitoring

­ Wildlife and forestry monitoring

­ Educational and research operations
Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft

Systems”, provides a mechanism for seeking expedited FAA authorization of safe civil

UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if

certain unmanned aircraft systems may operate safely in the national airspace system

before completion of the (comprehensive) plan and rulemaking required by section

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited

operation authorization” if several factors are met. Petitioner meets all requirements to

permit FAA approval of commercial UAS operations.

The Petitioner Requests Relief From the Following:

Regulations from which the exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

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) & (b)

14 C.F.R. 91.205 (b)

14 C.F.R. 91.215

14 C.F.R. (91.401 ­ 91.417)

Unmanned Aircraft System sUAVs are oftentimes seen as superior to helicopters due to the

smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much

smaller environmental impact which promotes public safety.

We are petitioning for exemption to enable Drone Your Home LV LLC to operate a DJI Phantom

2 vision plus equipped with a three­axis gimbals and using High­Def cameras. This sUAV has a

built­ in capability to limit the height it flies above the ground, to limit the radius of the distance it

flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone

feature. The Phantom also has the failsafe function of the Naza­M autopilot system which

means when the communication between the Main Controller and the transmitter is

disconnected, the outputs of all command sticks from controller will go to the center position. If

the GPS signal is good enough, the system will automatically trigger Return to Home and will

land safely.

The above specifications meet with the Model Aircraft Operating Standards as set

below:

• Drone Your Home LV LLC will only operate its sUAS in line of sight of a pilot and/or observer
and will operate at sites that are a 'sufficient distance' from populated areas within the sterile

area described in the FOPM. Such operations will insure that the sUAS will "not create a hazard

to users of the national airspace system or the public."

• When flying sUAV within 3 miles of an airport, airport operators will be notified and the

operator will give the right of way to avoid flying in the proximity of full­scale aircraft.

• Maximum flight time for each operational flight will be 30 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the

30 minute limit.

• The sUAV will be programmed so that it will not be operated at an altitude of no more

than 400 feet AGL, and not more than 200 feet above an elevated platform from

which filming is planned.

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

• The sUAS operated by the petitioner weighs less than 55 pounds, including the

payload (i.e. camera, lens, and gimbal).

• The sUAV will operate at speeds of no more than 50 knots, can hover, and can

simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted sterile environment within which

they will operate, our sUAS operations adhere to the Reform Act's safety

requirements.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft

running on combustible fuel, it operates at lower altitudes with no people on board and will

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of

death or serious bodily injury. With a small payload and maximum flight time of only 20

minutes, this is offers little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than ground

based imagery for displaying the characteristics of large, complex properties with several

buildings and large trees. The applicants in the past have chartered 2­seat full­sized

helicopters for this purpose, which has proven more costly than many potential clients have

been able to afford. The benefits of reduced cost and improved quality of presentation from

the UA will be valuable to and benefit many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders

nearby who might require assistance, including fire fighters, the police, the sheriff, et al.,

while remaining subject to all limitations cited in this application as we do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at

an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able

to communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of

the property owner;

(e) All required permits will be obtained from state and local government prior to operation;
(f) Drone Your Home LV LLC will not be operate over densely populated areas;

(g) Drone Your Home LV LLC will not be operating over any open­air assembly of people;

(h) Drone Your Home LV LLC will not be operating over heavily trafficked roads;

(i) Drone Your Home LV LLC will not be operating within 5 NM of an airport or heliport;

We respectfully request exemption under Section 333 to enable Drone Your Home LV LLC

to operate efficient, limited, low­risk commercial sUAV operations for the activities

stated respecting at all times the space and privacy of citizens and property whilst keeping

our skies safe.

Sincerely

Joshua S. Arnold

Drone Your Home LV LLC

Josh@droneyourhome.us

702.981.1001