Docket	Operations,	M

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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

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- 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	with in	and	under	the	conditions	established	by	the FAA.
T his 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)	con trolled	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	sa fety	and	fulfill the	Secretary	of	Transportation’s responsibil ities	to establish	requirements	for	the safe	operation	of	such	aircraft	systems	i n	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	2 00 hou rswith quadcopters.	Granting	this	p e tition	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,	p lease c ontact: Owner: Joel	Stone Value	Rental	Homes	of	MN	LLC 6509	Bonner	Ct Inver	Grove	Hts,	MN	55076 Phone:	651

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- 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	witho ut	posing	a	threat to	persons,	property	on	the	ground, the nation	air space system,	or	to national security.	These	determinations	will	be	made	based	upon	several	factors: The	weight,	speed,	and	operational	capability	are	im portant	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	quadcopter s	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 C ongress.	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	engineerin g preparation	sites.	As	a	result, VRH respectively	requests	the	Secretary	of Transportation grant	our	petition	of	exemption s	from	Section	333

. Aircraft	and	Equivalent	Level	of	Safety The	applicant	asks that	the	exemption	requested	above apply	to unmanne d civil aircrafts that	have	the	characteristics	and	operate	wi th the	limitations	as	describedbelow.	These	limitations	provide	for	at	least	an	equivalent	or higher	level	of	safety

to	operations	under	the	current	regulatory	structure	because	the	proposed op erations	represent	a	saf ety	enhancement	to	the operations	cond ucted	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	commu nicate	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	Pi lot. 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	f ilming. 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	locati on 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 a ircrafts 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	ar ea.	O perations	under	this	exemption	will be	tightly	controlled	and	monitor ed	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 crite ria	demonstrates there	is	no credible	threat	to	national	security p osed	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	aircra ft	as	required	by regulation.	An	exemption	is	necessary and	requested for	this	requirement. Additionally	n o	person	may	operate	a	U.S

. - registered	civil	aircraft	f or which a	flight m anual	is	not	required	by	Section	21.5 ,	unless	there	is	available	in	the aircraft	a currently a pproved	airplane	or	Rotorcraft	flight	m anual,	approved	manual	material, markings,	and	placards,	or	a combinatio n	of	the	above

. However	the UAS,	given	its size	and	configuration	has	no	ability	or	place	to	car ry	such	a	flight	manual	on	the aircraft. The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight manual	at	the	ground	control	po int	where	the	pilot	flying	the UAS	will	have immediate	access	to	it. An	exemption	is	requested	for	this	requirem ent. 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	aircraf

t that	is	being	used	for	flight	instruction	unless	that	aircraft	h as fu lly	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	b uilt	with dual	control	capability.		As	such	it	is impossible	to	m eet	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	beoperated	at	less	than	the	minimums	prescribed under	certain	conditions.

Technically	the	UAS	could	be	considered	to	be	a	helicopter	and	an	ex emption	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	p roperty	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	wi th	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	aircra ft.	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	with 14	C.F.R. § 91.119.
Section 91.121	Altimeter	Settings : This	regulation	requires	each	person	operating an	aircraft	to	maintain	cruising	altitude	by	r eference to	an	altimeter. However	the UAS	only	has	a	GPS	altitude	readout	on	the	remote	control	box	operated	by	the	pilot

. Therefore	a n	exemption	is	needed. An	equivalent	level	of	safety	will	be	achieved	by the operator	maintaining	awareness	with	the	GPS	a ltitude	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) d uring	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 con ditions VRH has	already	agreed	to implement,	a flight	time based	on	battery	life is	reasonable

. An	exemption	from	14	C

. F

. R

. § 91.15 1(a)	falls	within	the	scope	o f	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	lim iting	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,	appropriate ly,	at	the	airfield	with	the	pilot.
14	C.F.R. § § 91.405(a);	407(a)(1);	409 (a)(2);	417(a) and (b):	Ma inten ance Inspections

. These	regulations	require	that an	aircraft	operator	or	owner shall	have that	aircraft inspected	and	shall have	discrepancies	repaired	as	prescribed in P art	43	of	this chapter, and	others	shall	inspect	or	maintain	the	aircraft	in	co mpliance	with	Part	43.
Since these	section s 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 equiva lent	level	of	safety	will	be	furthered	because	these UAS are	very	small	and applicant	has agreed	to operate	only	in	restricted	a reas,	no	higher	than	200	feet AGL,	and	for	a	short period	of	time .	If	a	mechanical	problem should arise , the	UAS would land	imme diately

. 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	ho ur	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.
Petitio ner: Joel	Stone Value	Rental	Homes	of	MN	LLC 6509	Bonner	Ct Inver	Grove	Hts,	MN	55076 Phone:	651

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- 7090 Email:	jstonemsp@gmail.com