Docket	Operations,	M-30

U.S.	Department	of	Transportation	Docket	Management	System

1200	New	Jersey	Avenue SE

Room	W12-140

West	Building	Ground	Floor

Washington,	D.C.	20590

Petitioner: Joel	Stone

Value	Rental	Homes	of	MN	LLC (VRH)

6509	Bonner	Ct

Inver	Grove	Hts,	MN	55076

Phone:	651-334-7090

Email:	jstonemsp@gmail.com

Re:	Exemption	Request	for	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	from	14	C.F.R.	91.7	(a),	14	C.F.R.	91.9	(b)	(2),	14	C.F.R.	

91.103,	14	C.F.R.	91.119,	14	C.F.R.	91.121,	14	C.F.R.	91.405	(a),	14	C.F.R.	91.407	

(a)(1),	14	C.F.R.	91.409	(a)(1)&(2),	14	C.F.R.	91.417	(a)&(b),	14	C.F.R.	§ 45.23	(b).

To	Whom	It	May	Concern

This	application	is	being	submitted	on	my	own	behalf.

As	required	by	Section	333	of	the	Federal	Aviation	Administration	(FAA)	

Modernization	and	Reform	Act	of	2012	and	14	C.F.R.	Part	11,	Value	Rental	Homes	of	

MN	(VRH)	applies	for	an	exemption	from	the	above	listed	federal	regulations.	Value	

Rental	Homes	of	MN operates small,	unmanned	aircraft	equipped	to	conduct	

photography	and	videography	for	the	real	estate	industry,	engineering	inspectors,	

landscape	gardeners,	and	site	development	engineers.	If	this	exemption	is	granted,	

all	operations	will	be	conducted	within	and	under	the	conditions	established	by	the	

FAA.

This exemption	would	permit	the	operation	of	small,	unmanned, and	relatively	

inexpensive	Unmanned	Aircraft	Systems	(UAS) under	controlled	conditions	in	

airspace	that	is	1)	limited	2)	predetermined	3)	controlled	as	to	access	and	4)	would	

provide	safety	enhancements	to	the	already	safe	operations	in	the	real	estate and	

engineering	industries presently	using	lifting	devices	such	as	cranes	and	

conventional	aircraft.	Approval	of	this	exemption	would	enhance	safety	and	fulfill	

the	Secretary	of	Transportation’s responsibilities	to	establish	requirements	for	the	

safe	operation	of	such	aircraft	systems	in	the	national	airspace	system.

The	petitioner,	Joel	Stone	has	been	flying	remote	control	aircraft	since	the	mid-1970	

and	has	recently	began	flying	quadcopters,	both	for	recreational	purposes	and	with	

the	intent	of	flying	as Value	Rental	Homes	of	MN.	He	has	acquired	over	200 hours	
with quadcopters.	Granting	this	petition	would	be	in	the	interest of	the	public,	

property	on	the	ground,	and	the	national	airspace	system.	

The	aircraft	to	be	used	is	a	DJI	Phantom	3 Standard.

For	additional	information,	please	contact:	

Owner:	Joel	Stone

Value	Rental	Homes	of	MN	LLC

6509	Bonner	Ct

Inver	Grove	Hts,	MN	55076

Phone:	651-334-7090

Regulations	from	which	the	exemption	is	requested:	14	C.F.R.	91.7	(a),	14	C.F.R.	91.9	

(b)(2),	14	C.F.R.	91.103,	14	C.F.R.	91.119,	14	C.F.R.	91.121,	14	C.F.R.	91.405	(a),	14	

C.F.R.	91.407	(a)(1), 14	C.F.R.	91.409	(a)(1)&(2),	14	C.F.R.	91.417	(a)&(b)

Section	333	(a)(c)	allows	the	Secretary	of	Transportation	to	determine	the	ability	of	

an	unmanned	aircraft	to	operate	safely	in	the	National	Air	Space.	The	Secretary	is	

directed	to	determine	which	UAS are	able	to	operate	safely	without	posing	a	threat	

to	persons,	property	on	the	ground, the	nation	airspace system,	or	to	national	

security.	These	determinations	will	be	made	based	upon	several	factors:

The	weight,	speed,	and	operational	capability	are	important	components	of	the	

aircraft	as	well	as	whether	or	not	the	aircraft	will	be	operated	in	close	proximity	to	

airports	and	population	centers.	

VRH aircraft	are	quadcopters	weighing	five	pounds	or	less with	the	camera	

included.	The	camera	is	the	only	payload	of	these	UAS.	They	operate	at	speeds	no	

greater	than	30	miles	per	hour,	have	the	capability	to	hover,	and	move	in	the	

vertical	and	horizontal	plane.	They	will	only	operate	in	line	of	site.	These	very	

restrictive	operations	help	ensure the	UAS	will	not	create	a	hazard	to	the	public	or

the	national	airspace	system.

As	a	result,	VRH aircraft	clearly	present	an	equivalent	level	of	safety	to	the	NAS as	

envisioned	by	Congress.	The	relatively	small	size	of the	UAS	and	restrictive	

operational	parameters	imposed	by	VRH will	result	in	an	improved	level	of	safety	to	

the	NAS	and	the	public	when	compared	with	traditional	methods	of	conducting	

photography	and	videography	at	real	estate, landscaping,	and	engineering	

preparation	sites.	As	a	result,	VRH respectively	requests	the	Secretary	of	

Transportation grant	our	petition	of	exemptions	from	Section	333.	

Aircraft	and	Equivalent	Level	of	Safety

The	applicant	asks that	the	exemption	requested	above apply	to	unmanned	civil	

aircrafts that	have	the	characteristics	and	operate	with the	limitations	as	described
below.	These	limitations	provide	for	at	least	an	equivalent	or higher	level	of	safety	

to	operations	under	the	current	regulatory	structure	because	the	proposed	

operations	represent	a	safety	enhancement	to	the operations	conducted	with	other	

equipment	such	as	cranes	and	conventional	aircraft.

The	following	limitations and	conditions	to	which	VRH agrees	to	follow when	

conducting	commercial	operations	under	an	FAA	issued	exemption	include:	

1.	The	UAS	will	weigh	less	than	5	lbs.	

2.	Flights	will	be	operated	within line	of	sight	of	a	pilot	and/or observer	when	

necessary.	The	pilot	and	observer	will	be	able	to	communicate	with	each	other	at	all	

times.	

3.	Maximum	total	flight	time	for	each	operational	flight	will	be	25	minutes.	Flights	

will	be	terminated	at	25	percent	battery	power	should	that	occur	prior	to	the	25	

minute	limit.	The	battery	of	the	UAS	represents	the	fuel	of	the	vehicle	and	provides	a	

much	safer	and	predictable	environment	than	traditional	flammable	fuels.

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	200	feet	above	ground	level	

(AGL).	

5.	Crew	for	each	operation	will	consist	of	the	UAS	Pilot.	

6.	The	UAS	Pilot	will	be	the	Pilot	in	Command	(PIC).

7.	The	UAS	will	only	operate	within	a	confined	area.	

8.	The	operator	will	obtain	the	consent	of	all	persons	involved	in	the	photography	

and	filming.

9.	Pilot	and	observer	will	have	been	trained	in operation	of	UAS	generally	and	

received	up-to-date	information	on	the	particular	UAS	to	be	used.	

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

obtained.	

11.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS will	have	

capability	to	return	to	a	pre-determined	location and	land.	This	is	called	the	Return	

to	Ground	(RTG)	capability.

12.	Any	applicable	state	rules	and	regulations	will	be	strictly	adhered	to	at	all	times.	

These	limitations	and	conditions	satisfy Part	91.105,	Part	91.109,	Part	91.119	and	

Part	91.151.	

C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§ 91.203	(a)	(1)	

Subpart	H,	entitled	Airworthiness	Certificates.

Based	upon	the	size	of	the	UAS,	its	limited	operating	area,	and	the	other	limitations	

and	conditions	presented	above,	it	is	obvious	the	UAS	could	operate	with	an	

equivalent	level	of	safety	without	an	airworthiness	certificate.	The	FAA	Act	(49	

U.S.C.	§ 44701(f)	and	Section	333	of	the	Reform	Act	authorize	the	FAA	to	exempt	

aircrafts 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.	
The	UAS	to	be	operated	by	VRH is	less	than	5	pounds fully	loaded,	carries	neither	a	

pilot	nor	passenger,	carries	no	explosive	materials	or	flammable	liquid	fuels,	and	

will	operate exclusively	within	a	secured	area.	Operations	under	this	exemption	will	

be	tightly	controlled	and	monitored	by	the	operator.	These	safety	enhancements	

provide	a	greater	degree	of	safety	to	the	public	and	property	owners	than	

conventional	operations	conducted	with	airworthiness	certificates	issued	under	14	

C.F.R.	Part	21,	Subpart	H.		Application	of	these	criteria	demonstrates there	is	no	

credible	threat	to	national	security posed	by	the	UAS,	due	to	its	size,	speed	of	

operation,	location	of	operation,	lack	of	explosive	materials	or	flammable	liquid	

fuels,	and	inability	to	carry	a	substantial	external	load. 14	C.F.R.	§ 45.23	(b).	VRH

respectively	requests	the	FAA	Administrator	grant	an	exemption	from	this	

requirement.	

49	U.S.C.	§44711: Additionally	due	to	the	UAS	limited	size	and	the	lack	of	a	cabin,	

cockpit,	or	pilot	station,	it	is	impossible	to	mark	the	aircraft	as	required	by	

regulation.	An	exemption	is	necessary and	requested for	this	requirement.	

Additionally	no	person	may	operate	a	U.S.-registered	civil	aircraft	for which a	flight	

manual	is	not	required	by	Section	21.5,	unless	there	is	available	in	the	aircraft	a	

currently	approved	airplane	or	Rotorcraft	flight	manual,	approved	manual	material,	

markings,	and	placards,	or	a combination	of	the	above.	However	the	UAS,	given	its	

size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight	manual	on	the	

aircraft. The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	

manual	at	the	ground	control	point	where	the	pilot	flying	the	UAS	will	have	

immediate	access	to	it.	An	exemption	is	requested	for	this	requirement.

14	C.F.R.	§	91.103:	Preflight	action: This	regulation	instructs	the pilot	in	command	to	

perform certain	preflight	actions to	insure	the	safety	of	flight,	the	public,	property	

and	the	NAS.	As	an	FAA	approved flight	manual will	not	be	provided	for	the	aircraft,

an	exemption	will	be	needed.	Following	the	instructions	in	the	UAS	operating	

manual	will	provide	an	equivalent	level	of	safety.	Additionally	the	PIC will	take	

preflight	actions	by reviewing weather forecasts,	flight	battery	requirements,	

landing	and	takeoff	distances, and	aircraft	performance	data	before	initiation	of	

flight.	

14	C.F.R.	§ 91.109:	Flight	instruction:	Section	91.103	provides	that	no	person	may	

operate	a	civil	aircraft that	is	being	used	for	flight	instruction	unless	that	aircraft	has	

fully	functioning	dual	controls.	Remote	control	aircraft	such	as	UAS	are	operated	

through	communications	between	the	aircraft	and	a	remote	control	transmitter.	

These	transmitters	are	not	built	with dual	control	capability.		As	such	it	is	

impossible	to	meet	this	requirement	and	an	exemption	is	requested.	An	equivalent	

level	of	safety	is	provided since	the	aircraft	does	not	carry	passengers	and	because	

of	the	limited	size	and	speed	of	the	aircraft.

14	C.F.R.	§ 91.119:	Minimum	Safe	Altitudes	Section: 91.119	establishes	safe	altitudes	

for	operation	of	civil	aircraft.	Section	91.119(d)	only	allows	helicopters	to	be	
operated	at	less	than	the	minimums	prescribed under	certain	conditions.	

Technically	the	UAS	could	be	considered	to	be	a	helicopter	and	an	exemption	will	be	

needed	to	operate	at	altitudes not	to	exceed	200	feet AGL.

The	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.	No	flight	will	be	taken	without	

the	permission	of	the	property	owner.	Because	of	the	advance	notice	to	the	property	

owner	and	any	participants	in	the	activity,	all	affected	individuals	will	be	aware	of	

the	planned	flight	operations.	Compared	to	flight	operations	with	aircraft	or	

rotorcraft	weighing	far	more	than	the	maximum	5 pounds, and	the	lack	of	

flammable	fuel,	any	risk	associated	with	these	operations	is	far	less	than	those	

presently	presented	with	conventional	aircraft.	In	addition,	the	low-altitude	

operations	of	the	UAS	will	ensure separation	between	these	small	UAS	operations	

and	the	operations	of	conventional	aircraft	that	must	comply	with14	C.F.R.	 §

91.119.	

Section	91.121	Altimeter	Settings: This	regulation	requires	each	person	operating	

an	aircraft	to	maintain	cruising	altitude	by	reference	to	an	altimeter.	However	the	

UAS	only	has	a	GPS	altitude	readout	on	the	remote	control	box	operated	by	the	pilot.	

Therefore	an	exemption	is	needed.	An	equivalent	level	of	safety	will	be	achieved	by	

the	operator	maintaining	awareness	with	the	GPS	altitude	in	an	identical	fashion	as	

a	pilot	would	in	an	aircraft	with	an	altimeter.	

14	C.F.R.	§ 91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions. Section	

91.151(a)	prohibits	an	individual	from	beginning	a	flight	in	an	airplane under	VFR	

conditions	unless	the	aircraft	has	enough	fuel	to	fly	to	the 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. Since	the	battery	

of	the	UAS	has	enough	power	for	approximately	30	minutes	of	flight,	this	

requirement	is	impossible	to	meet.	Under	this	scenario,	the	aircraft	would	not	have	

any	flight	time	remaining	to	accomplish	its	tasks.	With	the	limitations	and	

conditions	VRH has	already	agreed	to	implement,	a flight	time	based	on	battery	life	

is	reasonable.	

An	exemption	from	14	C.F.R. § 91.151(a)	falls	within	the	scope	of	other	exemptions.	

The	UAS	will	be	operated	in	a	controlled	area	with	only	clients	present.	Since	the	

UAS	has	only	30	minutes	of	battery	life,	the	type	of	risks	that	Section	91.15(a)	was	

intended	to	minimize	will	not	be	present,	especially	considering	the	size	and	speed	

of	the	small	aircraft.	

An	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to	25 minutes	as	

already	agreed	or	25	percent of	battery	power, whichever	happens	first. This	

limitation	will	allow	the	pilot	sufficient	time	to	return	the	aircraft	to	its	

predetermined	landing	area.	

14	C.F.R.	§§ 91.203(a)	and	(b):	Carrying Civil	Aircraft	Certification	and	Registration.
The	UAS	is	a	very	small	aircraft,	weighs	less	than	5	pounds,	and	consequently,	is	far	

too	small	to	carry	either	passengers	or	crew	members.	As	such, it	is	impossible	to	

carry	the	airworthiness	certification and	registration	documents,	or	to	display	them	

on	the	aircraft.	An	equivalent	level	of	safety	can	be	achieved	by	maintaining	these	

documents,	appropriately,	at	the	airfield	with	the	pilot.	

14	C.F.R.	§§ 91.405(a);	407(a)(1);	409(a)(2);	417(a)	and (b):	Maintenance	

Inspections.

These	regulations	require	that an	aircraft	operator	or	owner	shall	have	that	aircraft	

inspected	and	shall have	discrepancies	repaired	as	prescribed in	Part	43	of	this	

chapter, and	others	shall	inspect	or	maintain	the	aircraft	in	compliance	with	Part	43.	

Since	these	sections and	Part	43	apply	only	to	aircraft	with	an	airworthiness	

certificate,	these	sections	should not	apply	to	the	applicant.	The	operator will	

perform	all maintenance required	by	the	flight	manual.	The	manual	also	

recommends	the	operator	verify	that	the	aircraft	is	in	safe	operating	condition,	

perform	any	required	maintenance	as	mentioned	before	the	flight,	and	to	keep	a	log	

of	any	maintenance	done.	The	recommendations	will be	accomplished.	An	

equivalent	level	of	safety	will	be	furthered	because	these UAS are	very	small	and

applicant	has agreed	to	operate	only	in	restricted	areas,	no	higher	than	200	feet	

AGL,	and	for	a	short period	of	time.	If	a	mechanical	problem should	arise, the	UAS	

would land	immediately.	

Applicant	believes	all	of	the	requirements	of	Section	333	of	the	Reform	Act	of	2012	

have	been	met	and	exemption	from	all	parts	of	the	Act,	as	requested,	is	appropriate.	

As	stipulated	above,	the	UAS	is	very	small	and	can	travel	at	30	miles	per	hour	at	

most.	The	aircraft	will	not	be	operated	within	close	proximity	to	airports	and	

densely	populated	areas,	with	a	visual	line	of	sight,	and	will	not	be	a	hindrance	to	

the	national	air	space.	

Your	consideration	of	this	request	is	appreciated.	

Petitioner: Joel	Stone

Value	Rental	Homes	of	MN	LLC

6509	Bonner	Ct

Inver	Grove	Hts,	MN	55076

Phone:	651-334-7090

Email:	jstonemsp@gmail.com