21812016 U.S. Department of Transportation. Docket Operations Ground Floor, Rm. W12
- 140 1200 New Jersey Ave

. S E Washington, 

### DC 20590 Bjorn Nichols 7911 Calle Jalisco Carlsbad CA 92009 T: 760.685.4550 bjom @searchlightinspcctions.com



### Regarding: FAA Exemption Rulemaking Section 333 ofthe 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 of201 2 and the procedures contained wit hin 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 i ssued by 

### a s tate, 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 ima ging 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 toperform 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 ofthe exemption request, by the FAA, would permit operation ofultra 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 reco rding real-estate listings (photo/video)

. 

### In summary and in accordance with this request of exemption request a-; au tho r ized 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 ofexemption 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 s uch services to private and governcmcnt entities who have little to no experience piloting UAS's but have a need to get images that are on l y possible f rom a UAS in order to compete within an ever deman ding t echnology driven market. S ea rchlight Home Inspect io ns submits t hat this appl ication has been prepared by Bjorn Nichols (owner of S earchlight Home Inspections) and not an attorney us i ng his personal knowledge ofexisting 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 S ection 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 

### S pecific section(s) of 14 C .F.R. 

### seeking an 

### exemption from arc: 14CFR21; 14 C.F.R

. 4 5.23(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 o f 

### re lief : Scarch(jght Home Inspections, is seeking relief from existing FARs that currently prohibit the use of UASs from operating commercially for t he purpose of aerial photog raphy/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, ofcivil 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 ofsuch 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 secur ity 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) ofthe 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 aff ect 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 exper ience 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 poundsAll 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 Federa l 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 ofan 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 al l UAS utilizes electronic global posit ioning systems with a barometric sensor. 1 4 C.F.R. 

### § 91.203 (a) and (b) provides for lhe carrying ofcivil 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. 14C.F.R

. 

### § 45.23: Marking ofThe 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. ThePIC 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). 14C .F .R. 91.119: Minimum Safe Altitudes. 14 

### CF.R. § 91.119 prescribes safe altitudes for the operation ofcivil aircraft. It allows helicopter.; to be operated at lower altitudes i n certaln conditions. The listed UASs will never operate at an altitude g r

eater 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 t he listed UASs, 

### an equivalent or higher level of safety 

### will 

### be ac hieved. 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 

### Summar y: 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 adequatejustification 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 n at ional 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

-spec ifications

-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 I0 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 (969x849x46 1mm) 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

- IO(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 degr ees -75 degrees Roll: between -40 degrees and 40 degrees Yaw: between 0 degrees and 

### 360 degrees Maximum Control Speed Pitch: 

### 30 degrees 

### I s Yaw: 

### 30 degrees 

### I s V l 8 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 

### I s Yaw: 35 degrees 

### I s