21812016 

U.S. Department of Transportation. Docket Operations 

Ground Floor, Rm. W12-140 

1200 New Jersey Ave. SE 

Washington, DC 20590 

Bjorn Nichols 

7911 Calle Jalisco 

Carlsbad CA 92009 

T: 760.685.4550 

bjom@searchlightinspcctions.com 

Regarding: FAA Exemption Rulemaking Section 333 of the FAA Reform Act and Part 11- 14 C.F.R. § 

45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) & (b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 

91.1Sl(a); 91.203(a) & (b) 91AOS(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b) 

Dear Sir or Madam: 

Searchlight Home Inspections, is requesting exemption from the Federal Aviation Regulations ("FARs") 

listed below and pursuant to the f7AA Modernization and Reform Act of2012 and the procedures contained 

within 14 C.F.R. II. in order to commercially operate a small ultra light unmanned aircraft system ("UAS"). 

specifically the following UAS platforms will be used: 

DJI Phantom Ill Pro 

Yuneec Typhoon H 

YuncccH920 

Attachment I lists the technical specifications for each of the previously listed UAS(s). 

The Pilot To Command (PIC) will hold either an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC will also bold a current FAA ainnan 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. 

Searchlight Home Inspections, would like to expand its operations, and wishes to add the followng 

photograpby/vidcography services. 

• Real Estate 

• Home Inspections 

Specifically, it wishes to provide aerial imaging to its customers in need of aerial photography/vidcography. 

With the advancement of Internet technology and consumer adoption of shopping for properties online. the 

demand for high-resolution aerial graphics and video is unprecedented. in addition, it wishes to be able to 
perform property (primarily roof) inspections via UAS. All UAS pertinent safety and risk management 

mca.-;ures as specified in the FAA's Risk Management Handbook shall be comp(jed with. 

A grant of the exemption request, by the FAA, would permit operation of ultra lightweight and unmanned 

UAS to operate in predetermined areas away from the general public, airports, heliports and vehicular traffic, 

primarily over individual properties/communities for the purpose of recording real-estate listings 

(photo/video). 

In summary and in accordance with this request of exemption request a-; authorized and outlined by the FAA 

under Section 333(c) of the Reform Act specified for use of UAS' for "Real Estate" purposes, Searchlight 

Home Inspections will adhere to all FAA regulations at all times and shall conduct all flight operations in 

strict compliance and safety protocols as mandated and required by regulations and best practices. 

Respectfully, we request the grant of exemption to operate ultra light weight, remote controlled UAS's for 

commercial purposes as described in this request and as allowable by law. This grant of exemption will allow 

tbe company to offer such services to private and governcmcnt entities who have little to no experience 

piloting UAS's but have a need to get images that are only possible from a UAS in order to compete within 

an ever demanding technology driven market. Searchlight Home Inspections submits that this application has 

been prepared by Bjorn Nichols (owner of Searchlight Home Inspections) and not an attorney using his 

personal knowledge of existing FARs as well as utilizing excerpts from other similar applications and 

assistance from Mile High Drone Services. Consequently. if Bjorn Nichols has unintentionally omitted any 

relative FARs. Searchlight Home Inspections, humbly request an opportunity to submit to those accidental 

omissions. The essence of this application is to declare that, Search(jght Home Inspections meets and exceeds 

the FAA's expected competency for piloting the listed UASs for commercial purposes and that the UAS that 

we specified earlier meets and exceeds the safety requirements as set forth by the Secretary ofT{ansportation 

thereby prompting the request for COA under Section 333. 

I. Contact Information: 

Searchlight Home Inspections 

Attn: Bjorn Nichols 

7911 Calle Jalisco 

Carlsbad CA 92009 

760.685.4550 

bjom@searchli&>htinspections.com 

2. The Specific section(s) of 14 C.F.R. seeking an exemption from arc: 

14CFR21; 

14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 14 C.F.R. 91, ct seq.: 

14 CFR 407 (a) (1): 

14 CFR 409 (a) (2); and, 14 Cr'R 417 (a) & (b). 

3. The extent and reason of relief: 

Scarch(jght Home Inspections, is seeking relief from existing FARs that currently prohibit the use of 

UASs from operating commercially for the purpose of aerial photography/vidcography in accordance 

with the FAAModerni<;ation and Reform Actof2012 112 P.L. 95 § 331-334. The Reform Act Subtitle 

B: Unmanned Aircraft Systems-(Sec. 332) "Requires the Secretary to develop a plan to accelerate 

safely the integration by September 30,2015, of civil unmanned aircraft systems (UASes, or drones) 

into the national airspace system." The company humbly requests that it be allowed to commercially 

operate the listed UASs during the time period the FAA is further establishing rule-~ and regulations 

governing the operations of such craft. 
The Secretary of Transportation has been asked by Congress to, among other things, consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the rulemaking required under Section 332 of the Refom1 Act. In making this 

determinatioo.the Secretary is required to determine which types of UASs do not 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 si1.e, weight, speed, and operational capability; 

Operation of tbe UAS in close proximity to airports and populated areas; 

and Operation of the UAS within visual line of sight (VLOS) of the Pilot and VO 

Accordingly, all flight~ will be conducted by a PIC and a VO in accordance with FAA Policy N 

8900227 Section 14 "Operational Requirements for UASs" and with the following restrictions: 

All aircraft will be made with a UA Gross weight of less than 55 pounds 

All flights will occur only during daylight hours. 

All flights will occur at or below 400 feet AGL 

5 nautical miles from an airport having an operational control tower; or 

3 NM from an airport with a published instrument flight procedure, but not an operational tower: or 

2 NM from an airport without a published instrument flight procedure or an operation tower; or 

2 NM from a heliport with a published instrument llight procedure. 

For safety, no flight with winds over 10 mph. 

Flight only in GPS mode that allows UAS to hover in place when radio controls are released. All 

operations to be conducted in GPS mode only. 

4. How the request will benefit the puhl.ic a~ a whole: 

Aerial photography is becoming a critical component of the way a company does business. Aerial 

photography via UAS allows people to get a vantage point that never used to be possible or 

economically feasible. It is much too dangerous and expensive to hire a manned aircraft to take many 

aerial images thereby making the UAS option more cost effective and safer. There simply is not enough 

UAS Pilots to cover the demand for these images, which is leading to unlicensed UAS operators which 

ultimately results in untrained and unqualified operators. 

5. Reasons why the exemption would not adversely affect safety; or how the exemption would 

provide a level for safety at least equal to the existing rule: 

An exemption would not adversely affect safety because this application applies only to aircraft 

characteristics and applications within FAA specified limitations. These limitations provide for at least 

an equivalent safety standard. However, the experience of a certificated rated pilot allows him/her to 

utilize his/her experience in UAS operations thereby exceeding safety and improving airspace 

operations by allowing aerial imaging clients to choose an pilot that knows bow to pilot an aircraft 

safely and within regulated limits. In addition, by providing unmanned services to the market place. 

there will be less of a demand for manned operations, which will provide for safer and quieter 

residential aerial photography. In addition, inspecting roofs via UAS will reduce the risk of personal 

injury because people who no longer have to walk on roofs which is inherently dangerous. 

As previously stated, all flights will be conducted by a PIC and aVO in accordance with FAA Policy N 

8900.227 Section 14 "Operational Requirements for UASs" and with t11e following restrictions: 

All aircraft will be made with a UA Gross weight of less than 55 pounds 
All flights will occur only during daylight hours. 

All flightS will occur at or below 400 feet AGL 

5 nautical miles from an airport having an operational control tower; or 

3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 

2 NM from an airport wilhout a published instrument night procedure or an operation tower; or 

2 NM from a heliport with a published instrument flight procedure. 

Extensive, pre-flight briefings are required between the PIC and the YO. 

A flight plan is required prior to each flight. 

All aircraft operations must be conducted within manufacturer recommended specifications. 

All site permissions must be obtained prior to flight. 

6. A summary the FAA may publish in the Federal Register: 

14 CF.R. 21 and 14 C.F.R. 91: Airworthiness Certificates. Manuals and The Like. 

14 C.P.R. 21, Subpart H, entitled Airworthiness Certificates. setS forth requirements lor procurement of 

necessary airworthiness certificates in relation to FAR §91.203(a)(l ). The size, weight and enclosed 

operational area of the listed UASs permit exemption from Part 21 because the listed UASs meets (and 

exceeds) 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 Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness cc.rtificatc requirement in consideration of the weight, size. 

speed, maneuverdbility and proximity to areas such as airports and dense populations. The current and 

projected UAS's meet or exceed each of the elementS. 

14 C .F.R. 91.7(a) prohibits lhe 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 arc no on board piloL~ 

or passengers. and given the size of the UAS's, lhis Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining such manuals on location with the Pilot. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607,8737, 8738,9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602,10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as all UAS utilizes electronic 

global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for lhe 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 any such required certifications and registrations with lhe Pilot. 

14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircmft to be marked according to certain 

specifications. The listed UASs 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 

diflicult to place on such small aircraft with dimensions smaller that mininlal lettering requirement. 

The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167. 

10167Aand 10700. 

14 C.F.R. § 61. ll3: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 CF.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. The 
PIC can achieve an equivalent level of safety as achieved by current Regulations because the listed 

UASs do not carry any pilots or passengers. Further. the PIC possess an FAA pilot cenificate, which 

helps his remote control piloting skills and factor.; in his experience in assessing any night risks. The 

risks attended to the oper.uion of the listed U/\Ss are far less than the risk levels inherent in the 

commercial activities outlined in 14 CF.R. § 61, ct seq. Thus, allowing the PIC to operate the listed 

UASs and meet and exceed current safety levels in relation to 14 C.F.R. §61.113 (a) & (b). 

14 C .F .R. 91.119: Minimum Safe Altitudes. 

14 CF.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopter.; to be 

operated at lower altitudes in certaln conditions. The listed UASs will never operate at an altitude 

greater than 400ft AGL. The PIC will also operate the listed UASs in safe areas away from public and 

traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of the listed UASs, an equivalent or higher 

level of safety will be achieved. 

14 C.F.R. 91.405 (a); 407 (a) (l); 409 (a) (2): 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require. amongst other things, aircrdft owners and operators to "have [the) 

aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except 

a~ 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 cenificate. They will nor, therefore, 

apply l.o the listed UASs. However, as a safety precaution the UAS which will be used will be 

inspected before and after each flight. 

In Summary: 

Searchlight Home Inspections, respectfully request that the FAA grnnt the exemption request and further 

volunteer any information gathered during flights in the event the FAA is interested in live field data. 

Searchlight Home Inspections, agrees and attests to adhere 10 any further limitations the FAA imposes, now 

or in the future. Satisfaction of the current criteria provided in Section 333 of the Reform Act of 2012 - si?.e, 

weight, speed, operating capabilities, proximity to airport~ and populated areas and operation within visual 

line of sight and national security- provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of the listed UASs for commercial purposes. Searchlight Home 

lnspcctions looks forward to support the FAA and UAS community in its quest to establish proper regulations 

and protocols for the safe introduction of unmanned aircraft into the national airspace. 

Sincerely. 

Bjorn Nichols 

Searchlight Home Inspections 

7911 Calle Jalisco 

Carlsbad CA 92009 
Attachment I 

DJJ Phantom Ill Pro (hup://www.dji.com/product/phantom-3/spec) 

Weight (Including Battery And Propellers): 1280 g Diagonal Size (Including Propellers): 590 mm 

Max Ascent Speed: 5 mls 

Max Descent Speed: 3 nlfs 

Hover Accu.racy 

• Vertical:+/- 0.1 m (when Vision Positioning i~ ac- tive) or +1- 0.5 m 

• Horizontal: +/- 1.5 m 

Max Speed: 16 nlfs (ATII mode, no wind) 

Max Altitude Above Sea Level: 6000 m 

Operating 1i:mperaturc: O(C) to 40(C) 

GPS Mode: GPS/GLONASS 

Yuneec Typhoon H (http://yuneec-forum.conlftbrcadslyuneec-typhoon-h-specifications-st 16-photo.27571) 

Hight Time 

Dimensions 

Battery 

Traosmiuer 

Max. Flying Altitude 

Max. Rotations Rate 

Max. Roll Angle 

Radio Control 

Frequency 

Max. Climbing Speed 

Max. Speed in Angle 

Mode 

Max. Descending 

Speed 

Motor 

ESC 

Yunccc Typhoon H Specifications 

22 Minutes (hovering) 

711mm X7llmm X 294mm 

5400mAH 45114.8 LiPo 

SC4000-44S 14.8V 

Default: 400 feet above ground level 

85 degrees per second 

35 degrees 

2.4GHz 

5 meters per second 

I 0 meters per second 

2.5 meters per second 

KV:850kv 

Max Power: 200W 

Working Current: < !SA 

Working Voltage: 12-25V 

Signal Frequency: 50-400Hz 
Flight Parameters 

WaypointS Supported? 

GPS Antenna? 

Air Pressure Sensor? 

Dynamic Return to 

Home? 

Intel Realsense Anti 

Collision? 

Auto Landing? 

Takeoff' Weight: 1800g 

Drone Weight: 1530 +/-lOg 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yuneec H920 (https:/lwww.yunccc.com/Specilications-Toroado-119W) 

Aircraft 

Flight Time 24 min 

Dimension 38.1x33.4xl8.lin (969x849x461mm) 

Diagonal Length Without Rotor Blades 362 in (920mm) 

Propeller/Main Rotor Diameter 17.3 in (440mm) 

Weight with GB603, GH4 Camera and Battery 176.0 oz (4990g) 

Battery LiPo 6s Charger 6S 222V LiPo DC Balancing Smart Charger with AC Adapter (included) 

Transmitter 24-channei2.4GH7. with 5.8GHz video downlink (included) 

Aight Modes Smart.Anglc. and Home Modes 

Maximum Aying Height? Absolute altitude? 4000m (13124 ft) 

Maximum Flying Height?Relative altitude? 400ft (122m) 

Maximum Rotation Rate I 00 degrees /s Maximum Roll Angle 35 degrees 

Maximum Horizontal Speed II m/s 25MPH 40KPH 

Radio Control Frequency Band 2.40Hz 

Operating Temperature Range - I O(C) to 50( C) 

ST24 

Operating System Android (TM) 

Number of Channels 24 

Control Transmission Distance/Range (Optimum Conditions) 2km 

Robust Radio Control Modulation Yunccc Protocol 

Video link Frequency Band 5.8GHz 

Video Transmission Distance/Range (Optimum Conditions) rCC Compliance: Up to 2296.57ft (700m) CE 

Compliance: Up to 300m (984.252 ft) 

Flight Systems Telemetry Data On Screen Display (OSD) Yes 

LED Backlit LCD Screen 7 inch Tactile (Vibrating) and Audible Feedback Yes 

Built-In LiPo Battery Voltage I Capacity 8700mah Li-ion Is Charger Smart Balance Charge 

GB603 
Weight Without camera: 31.4 oz(890g)!With camera; 56.5 oz ( 1600g) 

Dimension 6.5x8.6x7.7in ( 165x219xl96mm) 

Control Angle Accu.racy +1-0.02 degrees 

Maxumum Control Range Pitch: between -30 degrees to 90 degrees 

Yaw: between 0 degrees and 360 degrees 

Mechanical Range Pitch: -120 degrees -75 degrees 

Roll: between -40 degrees and 40 degrees 

Yaw: between 0 degrees and 360 degrees 

Maximum Control Speed Pitch: 30 degrees Is 

Yaw: 30 degrees Is 

V l8 

Dimension 6.9x4.9x8.1 in (175x 125x205mm) 

Weight 26.5oz (750g) 

Focusing System 18x Optica.l Zoom 

Field Of View 54.8 degrees (for wide-angle) -3.4 degrees (for distal end) 

Video Transmission Range Pitch: 1968.5ft?600m? 

Video Resol ution FULL HD 1080p 30rPS 

Photo Resolution 2 Mcgapixels Storage( memory) l\1icro SO Class 10, 4--32GB 

Control Angle Accuracy +1-0.02 dc!,>reeS 

White Balance Automatic White Balance 

Tmnsmission System 5 .8GHz 

Input/Operating Voltage 13V to 24V 

Working Temperature O(C) to 40(C) 

Storage Temperature O(C) to 40(C) 

Angular Vibmtion Range +1-0.02 degrees 

Adjustable Incline Pitch: +30 degrees- -120 degrees ; Yaw: +1- 0 degrees- 360 degrees ; Roll: -45 degrees-

+45 degrees Maximum Control Speed Pitch: 30 degrees Is 

Yaw: 35 degrees Is