**Summary the FAA may publish in the Federal Register:**

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and al ike. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operational area of DSH permit exemption from Part 21 because DSH meet an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is
authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S. C. § 44701(f)) and A. Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity

to areas such as airports and dense populations. DSH meet or exceed each of the elements. 14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate . As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level
of safet y will be achieved by maintaining a Flight log. 14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as DSH UAS's utilize electronic global positioning s ys tems and inte rnal gy roscopes to provide spatial coordination. Also preprogram height and distance. 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They

are inapplicable for the same reasons described above. T he equivalent level
of safet y will be achieved by maintaining such information buy flight log at the DSH Office. B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain speci fications. DSH are, b y definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft. C. 14 C.F.R. § 61.113: Private P ilot Privileges and L imitations. PI C Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non

- commercial operations. DSH can achieve an equivalent level of safet y as achieved b y current Regulations because DSH do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure remote control piloting skills, though DSH pilot vetting and training programs (based upon completion of an FAA Approved Ground School
and a self

- administered UAS flight training program and internal procedures) will. All Further, the risks attendant to the operation of DSH is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C. F. R. § 91 .119 prescribes safe altitudes for the operation of civil aircraft. It allows Helicopters to be operated at lower altitudes in certain conditions. DSH will never operate at an altitude greater than 2 00 AGL. DSH will, however, operate its UAS's in sectioned off areas with security perimeters, providing a level of safet y at least equivalent to those in relation to minimum safe altitudes. Given the size, weight, maneuverability

and speed of DSH, an equivalent level of safet y will be achieved.

E. 14 C.F.R. 91.4 05 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.
The above

- cited Regulations require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E of this part and shall between re quired inspections, except as provided in paragraph C of this section, have discrepancies repaired asprescribed in part 43 of this chapter." These Regulations only appl y to aircraft with an airworthiness certificate. They will not, therefore, apply to DSH should its requested exemption be granted. DSH conducts an extensive maintenance program that involves regular software updates and constant inspection for assessment of any damaged hardware. Therefore, an equivalent level of safety will be achieved. All UAS can now be maintained here in Hawaii on
the island of Lanai. Future Clients of DSH will have the same level of maintenance thru DSH repair shop in the state of Hawaii.

F. Summary Drone Services Hawaii seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R. § 91.409 (a)(2); and, 14 C.P.R.§§ 91.417 (a) & (b) to operate its Inspire 1 for education and demonstration to Hawaii’s Emergency Services, Community

education an d DOE STEM program’s. Drone Services Hawaii will offer education to change the present and change the future. Hawaii’s economic future is bright if DSH is granted the opportunity to educate our state to be respectful and responsible operators as hobbyist a nd future professionals of UAS. Granting DSH request for exemption will reduce current risk levels and thereby enhance safety. Further, DSH operates at lower altitudes and in controlled airspace. DSH owners have strong ties to its
Government and communitie s to affect change if exemption is granted. UAS's and therefore the likelihood of death or serious bodily injury are significantly

limited. DSH respectfully

requests that the FAA grant s its exemption request without delay . The FAA
has the authorit y to iss ue the exemption sought by Drone Services Hawaii pursuant to the Federal Aviation Act, 85 P.L . 726 (1958), as amended (the "Act").

Sincerel y,

Mike Elliott ( Co

- Owner) George K. Purdy I V (Co

- Owner)