Summary the FAA may publish in the Federal Register:

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and alike. 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 safety 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 systems and internal gyroscopes 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. The equivalent level 

of safety 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 specifications. DSH are, by 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 Pilot Privileges and Limitations. PIC 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 safety as achieved by 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 200 AGL. DSH will, however,

operate its UAS's in sectioned off areas with security perimeters, providing a level of safety at 

least equivalent to those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of DSH, an equivalent level of safety will be achieved.

E. 14 C.F.R. 91.405 (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 required 

inspections, except as provided in paragraph C of this section, have discrepancies repaired as 
prescribed in part 43 of this chapter." These Regulations only apply 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 and 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 and 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 communities 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 grants its exemption request without delay. The FAA 

has the authority to issue the exemption sought by Drone Services Hawaii pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

Sincerely,

Mike Elliott (Co-Owner) George K. Purdy IV (Co-Owner)