Veterans Home Inspection Services LLC Henrey Dee Jetty 28 larchwood Drive Pittsford NY 14534 Email: hjetty@rochester

..rr.com 585-363-2848 (Call ortext) NY Home Inspector Lie# 16000044801

US Department OfTransportation Federal Aviation Administration 800 Independence Ave SW Washington DC 20591

Subject: Exemption Application FAA Modernization and Reform Act of2012 (Public Law 112- 95). Section 333 of Public Law 112-95

DearSir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012(the reform act) and CFR Part 11 Veterans Home Inspection Services LLC, owner and operator ofa Small Unmanned Aircraft Systems (UASs), requestto be exempted from the Federal Aviation Regulations (FAR) listed belowsothat Veterans Home Inspection Services LLC may operate UASs commercially in airspace regulated bythe FAA., as longas such operations are conductedwithin and underthe conditions outlined herein or as maybe established bythe FAA as required by Section 333. Veterans Home Inspection Services LLC is a small business owned

### by HenreyD. Jetty. Retired CSM, US Army, Special Forces. I have a Class CFAA License as a Parachutist, Sky Diver and a NAUI Scuba license. I also hold a valid New York Drivers licenses for both a car and a motorcycle. Conducting safe operations has always been paramount in both my professional and private life style. All operations withthe UAS 

### will be performed with the public's safety and right to privacy safe guarded at all times. 

### As described below, the requested exception would permitthe operation of light weight {less than 55 lbs. total takeoffweight) UASs under controlled conditions for commercial use by a certified private pilotthereby enhancing safety and fulfillingthe Secretary ofTransportation's (the FAA Administrator's) responsibility to" establish requirements for safe operation ofsuch aircraft systems in national airspace systems." Section 333(c), ofthe Reform Act. Veterans Home Inspection Services LLC video UASs are rotorcraft weighing less than 55 pounds including payload. Veterans Home Inspection Services LLC uses the DJI Phantom 2 Vision Plus Version 3 Quad Copter Model PV331 serial# DH645440916. It operates at a speed less,than 50 knots and have the capability to hover and

move in the vertical and horizontalplane simultaneously. ·The: UAS has an auto return to launch point when battery power is under25%. The UAS 

### wit!·operatewithhi the litie 1ofsight with in a protected flight area as described below and at 200 feet AGL or less with'a trained operator and observer located in closevrcinity as to make voice communication possible. These flight operations will notcreate a hazard to users ofthe nation airspace, public norto the environment. Veterans Home Inspection Services LLC respectfully requests the grant ofan exceptiontothe following specific sections oftheTitle 14 Code of Federal regulations allowingitto operate lightweight UASs for commercial use, 14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121,91.151,(a), 91.203(a) &(b),91.40S(a),91.407(a)(1), 91.409(a)&(b). Veterans Home Inspection Services llCsubmits this application in accordance with the Reform Act ,112 P.l. 95 331-334, seeking relieffrom any currently applicable FAR'S operatingto prevent Veterans Home Inspection Services LLC future commercial use ofsmall UASs to operate in the national airspace system as described below. The reform Act section 332 provides for such integration ofcivil unmanned aircraft into our national airspace system as it is in the public's interestto do so. Veterans Home Inspection Services llC UAS meets the definition ofa "small unmanned aircraft" as defined in Section 331 and thereforthe integration ofthe UAS are expressly contemplated bythe Reform Act. Veterans Home Inspection Services llC would liketo operate its light weight UAS priorto the time period by which the Reform Act requires the FAA to promulgate rules governingsuch aircraft. The Reform Act directs the Secretary ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe reform Act. In makingthis determination, the Secretary ofTransportation is required to determine which UASs do create a hazard to users of the national airspace system orthe public orpose athreat to national security in light ofthe following: The UAS's size, speed, weight and operational capability, operation ofthe UAS in close proximityto airports and populated areas, operation ofthe UASs within visual line ofsight of the operator Reform Act 333(a). Ifthe Secretary determines that such vehicles "may operate safely in National Airspace System, the Secretary shall establish requirements forthe safe operation in national airspace. Veterans Home Inspection Services llC UAS will only operate within the line ofsight ofthe operatorwithin a protected flight area and at 200feet AGL or less. Mostflighttimes are less than 10 minutes. These flights ofthe UAS will not present a hazard to the national airspace northe public. The very small nature ofthis UAS combined with the safe guards presented below, will allow for the safe operation greater than that envisioned by Congress forthe FAA to establish and by exemption allow commercial operations of UASs to

commence immediately. Also due to the size of UASs and the areas and altitudesthey will operate approval ofthis exception presents no national security issues and absolutely minimal safety concerns which have been mitigated through our rigorous risk management process. Given the clear direction given in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level ofenhanced safety, reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact ofgreatly reducingthe cost of aerial photographythereby benefitingthe greater public's interest. Accordingly, Veterans Home Inspection Services LLC respectfully requests that the FAA grant the requested exemption without delay. The following will be considered as the binding limitations on flight operations ofany Veterans Home Inspection Services LLC UAS: 1. Flights

### will only occur in the daytime hours. 

### 2. Flights will be operated in the line ofsight ofthe Pilot in Command (PIC) and Visual Safety Observer, (VSO). 3. Flights will be terminated at any time weather and wind deteriorate to "unsafe forflight" by manufacturers recommendations.

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4. The UASs will weigh less than 55 lbs

.. 5. Flights will be operated at 200feet AGl or less. 6. The crew will be at a minimum ofoperator (PIC) and an observer and/or camera operator (VSO). 7. Operatorand crew will remain in contact duringthe flight operation. 8. The UAS operator 

### will perform a check ofthe flight area and make certain ofthe safety of

### all persons in the area. 9. Consent will be obtained from all owners of respective properties within the photography

area to further reduce the chance ofviolating anyone's privacy. 10. All required FAA clearances, 

### will be obtained and distances from airports and other restricted airspace areas will be strictly observed. 11. All UASs will have the capabilityto return automaticallyto the operator in a safe manner with the auto return function checked and working. 12. Flights will only operate in highly favorable weather conditions and adequate flyingspace from any obstructions. 13. The UAS has afunction on the control totell operatorthe distance away from the operator and its batterypower remaining. 14. Flight team will communicate bythe use oftwo-way radio ifthe area is too bigto hear an operator's normal voice from all observer members. 15. The UAS will be used to take pictures and videos of real estate property. 16. When operating over or near waterthe UAS will be equipped with flotation devices so that recovery can be made as to prevent lithium battery exposure to the water table. 17. All flights will have a pre-flight check and a functions check ofplatform stability and control priorto elevatingthe UAS to required heights. This will be in compliance with the manufacturer's pre-flight instructions. 18. All required permission s and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 19. The UAS has been registered with the FAA as required. In regards to 14CFR part 21 Subpart H: Airworthiness Certificate 14CFR 91.7(a), 91.203(a)(l) Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Veterans Home Inspection Services llC UAS flights permits exception from Part 21 because they meet an equivalent level ofsafety pursuant to Section 333 ofthe Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 USC 4470(f) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAA to exempt UASs from airworthiness certificates in consideration ofweight, size, speed, maneuverability and proximityto areas such as airports and dense populations. Veterans Home Inspection Services llC meets or exceeds each ofthese requirements. As of March 23, 2015 the FAA has stated that itwill automatically grant a "blanket" COA for flights at or under 200 AGlto any UAS operatorwith a section 333 exemption. 14 CFR 91.203 (a&b) provides for carrying ofcivil aircraft certifications and registrations. These are inapplicableforthe same reasons stated above. The equivalent level ofsafety will be achieved by maintaining such certifications and registrations as required atthe Veterans Home Inspection Services llC home office. 14CFR91.7 (a) prohibits the operation ofan aircraftwithout an airworthiness certificate. As no such certificate will be**appHca~.le** in theform contemplated by FAA's this regulation is inapplicable: 14 CFR 91.9(b)(2J,.C:ivil Aircraft Flight Manual in Aircraft 14CFR 91.9(b)(2) requires an aircraft flight

### manu.~!in the aircraft. As there

are no pilots or passengers, and given the size ofthe UASs this regt:lt<lltion is inapplicable. An equivalent level ofsafetywill be achieved by maintaining such certifications and registrations at the Veterans Home Inspection Services LLC home office.

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## ·< 1 ;;' The FAA has previously issued exemptions tothis regulation

### irl:Ex~mptions No's 8607,8737,8738,9299,9299A,9565,9565B,10167,10167

### A,1{)(:;Q~J0700 and 32827. 14 CFR 91.119 Minimum safe altitudes, prescribes safe

### altlt~des for operation ofcivil aircraft. It allows helicopters to be operated at lower altitudes in'eertain

### .~onditions. Veterans Home Inspection Services LLC will only operate its UASs at .()r below 200AGL. They will be operated on

a will defined AOR that has been carefully reviewedforhaz:ards and minimizes the presence of any persons not essential forthese operations. Flightswill. only be over private propertythat the owner has consented and all persons within

### thi~\ih;f~p area also give consent forthis filming. Compared to flight operations ofconventional

### ~hd traditional aircraft or rotorcraft weighingfar morethan 50 lbs., operating below 500 AGL with flammable fuel UASs operations present a negligible risk tothe public. Approval ofthese 333 Exemptions allowing commercial operations ofsmall UASs inthe service ofaerial photographywill greatly enhance safety by reducingthe overall risk associated with traditional aircraft. Traditional aerial photography requires large aircraftwith flammable fuel to fly in close proximity of populated areas and people in general. With the use of small UASs of55 lbs. or less, battery operated and fling below200feet AGL the risk of injury ofpeople on the ground orthe crew has been reduced or almost erased. The granting ofthe use ofthese small UASs by Veterans Home Inspection Services LLC will give my company a safe venue to provide my clients atop down viewpoint of the property being inspected. Inspections of properties with high pitch roofs that are multiple stories is 

## ahazardous endeavorthat has limitations forthe inspector. This application ofdrone technology is a critical component of providing essential information in real time. An aerial view provides visual information ofthe property not readily available with observation from the ground. These pictures and videos will provide myclients with accurate information to make decisions in their real estatetransactions. Granting Veterans Home Inspection Services LLC the above exemption will allowforthe expansion of UAS systems in the Rochester, NY area and for futurefor thesafe conduct offree enterprise and providing my clients with safely acquired

same day photography of real estate. Veterans Home Inspection Services LLC respectfully requests the FAA grant its exception without delay. The FAA has the authorityto issue the exemption sought by Veterans Home Inspection Services LLC pursuantto the Federal Aviation Act, 85 P.L. 726 (1958) as amended.

Inspection Services LLC

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