August 31, 2015

Exemption No. 12675

Regulatory Docket No. FAA−2015−0883

Mr. Mike Elliott

Mr. George Purdy, IV

Drone Services Hawaii LLC

98-1827A Kaahumanu Street

Aiea, HI 96701

Dear Messrs. Elliott and Purdy:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letters dated March 27, 2015, and July 13, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Drone Services Hawaii LLC (hereinafter petitioner or 

operator) for an exemption. The petitioner requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography, videography, education, and UAS training1.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. However, the FAA 

received five comments in support of the petition made to the docket.

 

1 The petitioner requested authority to conduct UAS training. At this time, the FAA is unable to authorize UAS 

operations for training until a further assessment is completed. When the FAA completes its review, we will 

proceed accordingly and no further action will be required by the petitioner. However, the petitioner is permitted 

to train its own pilot in commands and visual observers in accordance with condition no. 14 and the other 

conditions and limitations in this exemption.
2

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection2. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

 

2 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Drone Services Hawaii LLC is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Drone Services Hawaii LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 
4

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.
5

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
6

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 
7

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
 

March 27, 2015

Drone Services Hawaii LLC

Mike Elliott/George K. Purdy IV

Owners

98-1827A Kaahumanu St.

Aiea, Hi 96701

Phone (808) 225-2968 (Mike)

Phone (808) 559-0175 (George)

Fax (808) 445-1954

Re: Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from:

14 C.F.R. Part 21 Subpart H

14 C.F.R. § 21.191(a)

14 C.F.R. § 45.23(b)

14 C.F.R. § 45.27

14 C.F.R. §§ 61.113(a) and (b)

14 C.F.R. § 91.l 19(c)

14 C.F.R. § 91.121

14 C.F.R. § 91.151(a)

14 C.F.R. § 91.405(a)

14 C.F.R. § 91.407(a) (l)

14 C.F.R. §§ 91.409(a) (l) and (2)

14 C.F.R. §§ 91.417(a) and (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14

C.F.R. Part 11, Drone Services Hawaii hereby applies for an exemption from the listed Federal 

Aviation Regulations (" FARs") and any other necessary to allow operation of its small 

Unmanned Aircraft Systems ("UAS") for commercial photography and video Education, 

Training and Demonstration for Hawaii’s Emergency First Responders to intergrade UAS into 

certain Departments of Government. Second is to educate Hawaii’s Public and students 

participating in Science Technology Engineering and Math (“STEM”) programs in the State of 

Hawaii. Drone Service Hawaii is owned and operated by two military Veterans deeply rooted in 

its communities. Early awareness and education on UAS Safety will have a major impact on the 

overall future of our youth and the ability to operate these UAS in a professional manner. 

Therefore by opening the door for future opportunities, employment, and business development.
Respectful and responsible UAS flying is of the highest priority and the corner stone of our 

company. UAS operations are conducted under the conditions outlined herein.

Drone Service Hawaii requests such authorization to conduct controlled training scenarios with 

local government departments. (ex: police, fire, department of land and natural resources, and 

local federal agencies such as National Oceanic Administration)

The Training Mission’s to include: Search and rescue, natural disaster, hazmat incidents, fire 

events, and public education. We are a mobile company designed to travel to all 8 Hawaiian 

Islands to educate government and communities on UAS. Drone Services Hawaii is sensitive to 

the unique situation of Hawaii and its native people. We are culturally sensitive to Hawaii’s 

needs and will personally protect Hawaii’s best interest because Hawaii is our home. Drone 

Services Hawaii’s training operations will help define the role of UAS technology intergraded 

with emergency services and the local population as they become more educated and define 

appropriate uses in the community. The opportunity for future employment in the field of UAS 

is promising and will provide Hawaii’s retuning Veterans, graduates with degrees in the field of 

STEM and the physically challenged a career in UAS. 

Co-Owner and Repair Shop Manager, Mr. George Purdy who resides on the Island of Lanai, and 

is currently an Airport Fire Equipment Operator at Lanai Airport, for the past 17yrs. George’s 

knowledge for the past 30 years of operating and building RC Models, from Cars to Quad 

copters and his trial and error with practical application makes him uniquely qualified. George’s 

first-hand knowledge of his community and its assets and limitations helped to create and 

develop the Lanai Airport Emergency Plan with the assistance of the Maui Airport District 

Office. This plan includes and is not limited to working with its community for an aircraft 

disaster and among other community emergencies that may arise. He knows the importance of 

FAA’s mission on air safety. His personal mission is to help the state of Hawaii should they 

choose to use UAS and to become educated about how to implement a program and to intergrade 

FAA’s mission on being safe. He also has good working relationships with current Hawaii FAA 

Staff and the state of Hawaii’s Department of Transportation. This will assist in executing a 

well-organized education program based off of FAA and Airport Rescue Fire Fighting (“ARFF”)

training. George Purdy is a father of two and is very involved with his local school’s STEM 

programs, He was contacted by the school counselor because of his knowledge and practical 

application to give a couple of classes. The goal of these classes was to educate students and to 

introduction them to drone technology and air space safety in 2014. George is a strong believer 

in what the FAA is doing and understands the “Big Picture”. First responder education, 

community and personal safety along with training is his background. George strives daily to 

personally accomplish these goals and pass it on to the youth of his community.

Training syllabus for emergency service:

1. UAS Safety Over View Guidelines, FAA regulations and ARFF’s application on air safety.

2. Communications. What is available?

3. Privacy issues?

4. Permission to operate on property?

5. UAS Aircraft Familiarization.

6. Table top exercise. (Mutual-Aid Resources working together.)

7. UAS integration into actual real life scenario exercise.

8. Debrief: Does it work? What doesn’t work? What have we learned?
Public Education:

Attend Public events and distribute educational information from FAA News, UAS industry 

news, keeping people informed and a simple flight demonstration if open space is available. 

Drone Services Hawaii’s goal is to be available to the community, to have that face to face 

interaction and educate our community. Provide information if questions arise. Also to be armed 

with information and supply resources to educate our communities.

STEM Programs Hawaii’s DOE:

Support our local students by explaining FAA regulation on air safety and why it is important to 

be respectful and responsible operators. Providing information to be sent home, therefore the 

influential adults in the student’s life know what the student has learned and what the 

responsibilities are if the household decides to purchase a UAS. A big goal of Drone Services 

Hawaii is to provide opportunities to our local youth and introduce them to the future of UAS 

technology in a professional, responsible, and educational environment.

We are writing to request that Drone Services Hawaii (“DSH”), an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") listed below so 

that DSH, may operate its small unmanned aircraft systems ("UAS") for the purpose of 

education and safety in airspace regulated by the Federal Aviation Administration ("FAA"); as 

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. Drone Services Hawaii has been actively 

involved in the Education development of UAS/ UAV in Hawaii.

Aircraft

Drone Services Hawaii will operate the DJI Inspire 1, Model T600, with a total weight of 2935g 

or 6.47lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch x 11.85 

inches. Under still air the Maximum speed is no more than 22m/s or 49mph with a cruising speed 

of 11m/s or 25mph. The DJI Inspire 1 has the ability to hover and move along a vertical and 

horizontal plane simultaneously. The DJI Inspire 1 has four motors, Motor Model DJI 3510, 

powered by a 6-cell 4500mAh or 5700mAh Lithium Polymer battery. There are four propellers, 

Propeller Model DJI 1345, in use. The DJI Inspire 1 will be controlled with the C1 remote 

controller with an operating frequency of 2.400GHz – 2.483GHz. The live video feed will have 

an operating frequency of 5.728GHz – 5.850GHz. DJI Inspire 1 has a program to limit height it 

will be set to 200ft AGL.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY.

The UAS will weigh less than 55 lbs.

The UAS will have a maximum operating speed of no more than 50mph.

Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO).

Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at

25% battery power reserve or 30 minutes of flight time whichever occurs first.

Flights will be operated at an altitude of no more than 200 feet Above Ground Level (AGL) and 

remain in the line of sight.

Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and 

may include but not limited to a Camera Operator.

The UAS pilot will be a designated Pilot in Command (PIC).

A briefing will be performed regarding the planned UAS operations prior to each day’s flight.
The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference 

Point (ARP) of a tower controlled or uncontrolled airport.

If operations will be within a 5 mile radius of the geographic center/Airport Reference Point 

(ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted 

advising them of the estimated flight time, flight duration, elevation of flight and other pertinent 

information.

The PIC and VO will have been trained in operation of UAS and receive up-to-date information 

for the particular UAS to be operated.

The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

If the UAS loses communications with the remote controller or loses GPS signal, the UAS will 

have the capability to return to a pre-determined location within a designated location and land

autonomously.

The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or 

emergencies.

UAS has in its program to limit height and distance from PIC.

See user manual for more information.

 
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)
July 13, 2015

Mike Elliot

George Purdy

Drone Services Hawaii LLC.

U.S. Department of Transportation

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Amendment to Docket No.FAA-2015-0883 in pursuant of Section 333 FAA Reform Act and 

part 11 of the Federal Aviation Regulations in Regulatory Docket No. FAA -2015-0883.

Dear Sir/Madams:

Drone Services Hawaii Received a letter on Friday July 9, 2015 stating it does not comply with the 

requirements of & 11.81. For you to consider the request any further, we are sending what is being 

requested.

1. The reason why granting the request would be in the Public interest; that is; how it would benefit the 

public as a whole.

2. Any additional information, views, or arguments to support your request.

See below for response.

Public interest granting the petition would be in the public interest because:

1. The Congress of the United States has determined that early accommodation of sUAS into the 

National Airspace System advances the public interest. The Committee Report leading the House to 

adopt H.R. 658 said: "The successful integration of unmanned aircraft systems (UAS) into the 

National Airspace System (NAS) can support more than 23,000 high paying jobs in the United 

States. . . . The absence of a plan to integrate UASs into the NAS is a barrier to such job creation . . . 

."1 Granting the Petition represents a step toward such integration, in the absence of a comprehensive 

regulatory regime for sUAS, and thus would serve the Congressional goal and the public interest.

2. Granting the Petition will facilitate a new era in Emergency Response activities here in Hawaii, 

one in which the responders themselves have a tool to safely, quickly and remotely assess a situation 

without placing lives in harm’s way. In comparison, the EOD robots have saved countless lives since 

their inception, a feat that will become common place for aerial assessments. For the present day

improvement on the island of Lanai a sUAS is needed because this island has no Aerial assets 

stationed on island. Any aircraft support is 2hr or more depending on time of day. Hurricane season 

in Hawaii is upon us now sUAS will play a big role in recovery efforts when a hurricane hits Hawaii 

this year. This will be a huge tool for State and County Civil Defense in developing recovery plans 

for emergency service to execute. The State of Hawaii is 5,000 miles away from the west coast of the 

United States, Drone Services Hawaii LLC is request to be granted exemption because of these 

reasons.

3. Granting the Petition will enable Drone Services Hawaii LLC the Petitioner to demonstrate the 

commercial viability across the State of Hawaii creating new safety techniques and tactics with new 

aeronautical technology, thereby improving the efficiency of Emergency Responders around the 
world and making for a safer society. The rules from which Petitioner seeks exemption artificially 

and irrationally limit the effective use of new technologies to expand Emergency Response safety 

and improve the efficiency of markets, thereby subverting the public interest.

Exemptions Granted based upon similar request demonstrated by Drone Services Hawaii LLC.

DSH has an exemption written following FAA’s request and represent the state of Hawaii’s 

communities in mind with safety as its number 1 goal. In Grants of Exemption Nos. 11062 to 

Astraeus Aerial No. 11109 to Clayco Inc. No. 11112 to VDOS Global LLC No. 11213. The 

following exemption dockets where also granted. Docket No.11269, 11888, 11895, 11311, 11918,

11905, 11925 and 11962.

Sincerely,

George Purdy

Drone Services Hawaii LLC.