Veterans Home Inspection Services LLC 

Henrey Dee Jetty 

28 larchwood Drive 

Pittsford NY 14534 

Email: hjetty@rochester .. rr.com 

585-363-2848 (Call or text) 

NY Home Inspector Lie# 16000044801 

US Department Of Transportation 

Federal Aviation Administration 

800 Independence Ave SW 

Washington DC 20591 

Subject: Exemption Application FAA Modernization and Reform Act of 2012 (Public Law 112-

95). Section 333 of Public Law 112-95 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012(the reform act) and 

CFR Part 11 Veterans Home Inspection Services LLC, owner and operator of a Small Unmanned 

Aircraft Systems (UASs), request to be exempted from the Federal Aviation Regulations (FAR) 

listed below so that Veterans Home Inspection Services LLC may operate UASs commercially in 

airspace regulated by the FAA., as long as such operations are conducted within and under the 

conditions outlined herein or as maybe established by the 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 C FAA 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 with the 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 takeoff weight) UASs under 

controlled conditions for commercial use by a certified private pilot thereby enhancing safety 

and fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibility to" 

establish requirements for safe operation of such 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 horizontal plane simultaneously. ·The: UAS has an auto return to launch 

point when battery power is under 25%. The UAS wit!· operate withhi the litie1of sight 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 not create a hazard to users of the nation airspace, public nor to the 

environment. Veterans Home Inspection Services LLC respectfully requests the grant of an 

exception to the following specific sections of the Title 14 Code of Federal regulations allowing 
it to 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 llC submits this 

application in accordance with the Reform Act ,112 P.l. 95 331-334, seeking relieffrom any 

currently applicable FAR'S operating to prevent Veterans Home Inspection Services LLC future 

commercial use of small UASs to operate in the national airspace system as described below. 

The reform Act section 332 provides for such integration of civil unmanned aircraft into our 

national airspace system as it is in the public's interest to do so. Veterans Home Inspection 

Services llC UAS meets the definition of a "small unmanned aircraft" as defined in Section 331 

and therefor the integration of the UAS are expressly contemplated by the Reform Act. 

Veterans Home Inspection Services llC would like to operate its light weight UAS prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such 

aircraft. The Reform Act directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in national airspace before completion of the 

rule making required under Section 332 of the reform Act. In making this determination, the 

Secretary of Transportation is required to determine which UASs do create a hazard to users of 

the national airspace system or the public or pose a threat to national security in light of the 

following: 

The UAS's size, speed, weight and operational capability, operation of the UAS in close 

proximity to airports and populated areas, operation of the UASs within visual line of sight of 

the operator Reform Act 333(a). If the Secretary determines that such vehicles "may operate 

safely in National Airspace System, the Secretary shall establish requirements for the safe 

operation in national airspace. Veterans Home Inspection Services llC UAS will only operate 

within the line of sight of the operator within a protected flight area and at 200 feet AGL or less. 

Most flight times are less than 10 minutes. These flights of the UAS will not present a hazard to 

the national airspace nor the public. The very small nature of this UAS combined with the safe 

guards presented below, will allow for the safe operation greater than that envisioned by 

Congress for the 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 altitudes they will 

operate approval of this 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 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, reduced 

emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly 

reducing the cost of aerial photography thereby benefiting the 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 of any Veterans 

Home Inspection Services LLC UAS: 

1. Flights will only occur in the day time hours. 

2. Flights will be operated in the line of sight of the Pilot in Command (PIC) and Visual Safety 

Observer, (VSO). 

3. Flights will be terminated at any time weather and wind deteriorate to "unsafe for flight" by 

manufacturers recommendations. 
4. The UASs will weigh less than 55 lbs .. 

5. Flights will be operated at 200 feet AGl or less. 

6. The crew will be at a minimum of operator (PIC) and an observer and/or camera operator 

(VSO). 

7. Operator and crew will remain in contact during the flight operation. 

8. The UAS operator will perform a check of the flight area and make certain of the 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 of violating 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 capability to return automatically to 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 flying space 

from any obstructions. 

13. The UAS has a function on the control to tell operator the distance away from the operator 

and its battery power remaining. 

14. Flight team will communicate by the use of two-way radio if the area is too big to 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 water the 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 of platform stability and control 

prior to elevating the 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 14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 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 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 USC 4470(f) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UASs from airworthiness certificates in consideration of weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

Veterans Home Inspection Services llC meets or exceeds each of these requirements. 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for 

flights at or under 200 AGl to any UAS operator with a section 333 exemption. 14 CFR 91.203 

(a&b) provides for carrying of civil aircraft certifications and registrations. These are 

inapplicable for the same reasons stated above. The equivalent level of safety will be achieved 

by maintaining such certifications and registrations as required at the Veterans Home 

Inspection Services llC home office. 14CFR91.7 (a) prohibits the operation of an aircraft 
without an airworthiness certificate. As no such certificate will be appHca~.le in the form 

contemplated by FAA's this regulation is inapplicable: 14 CFR 91.9(b)(2J,.C:ivil Aircraft Flight 

Manual in Aircraft 14 CFR 91.9(b )(2) requires an aircraft flight manu.~! in the aircraft. As there 

are no pilots or passengers, and given the size of the UASs this regt:lt<lltion is inapplicable. An 

equivalent level of safety will be achieved by maintaining such certifications and registrations at 

the Veterans Home Inspection Services LLC home office. , ·< 1;;' 

The FAA has previously issued exemptions to this 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 of civil 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 for these operations. Flights will. only be over private property that 

the owner has consented and all persons within thi~\ih;f~p area also give consent for this 

filming. Compared to flight operations of conventional ~hd traditional aircraft or rotorcraft 

weighing far more than 50 lbs., operating below 500 AGL with flammable fuel UASs operations 

present a negligible risk to the public. Approval of these 333 Exemptions allowing commercial 

operations of small UASs in the service of aerial photography will greatly enhance safety by 

reducing the overall risk associated with traditional aircraft. Traditional aerial photography 

requires large aircraft with flammable fuel to fly in close proximity of populated areas and 

people in general. With the use of small UASs of 55 lbs. or less, battery operated and fling 

below 200 feet AGL the risk of injury of people on the ground or the crew has been reduced or 

almost erased. The granting of the use of these small UASs by Veterans Home Inspection 

Services LLC will give my company a safe venue to provide my clients a top down viewpoint of 

the property being inspected. Inspections of properties with high pitch roofs that are multiple 

stories is a hazardous endeavor that has limitations for the inspector. This application of drone 

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 my clients with accurate information to make 

decisions in their real estate transactions. Granting Veterans Home Inspection Services LLC the 

above exemption will allow for the expansion of UAS systems in the Rochester, NY area and for 

future for the safe conduct of free 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 authority to issue the exemption sought by Veterans Home 

Inspection Services LLC pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as amended. 

Inspection Services LLC 
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