September 25, 2015

Exemption No. 12988 Regulatory Docket No. FAA

− 20 15

− 2650

Mr. Paul W. Anderson Personal Presence Home Watchers and Services LLC 387 Bay Tree Drive Miramar Beach, FL 32550

Dear Mr. Anderson :

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 letter dated June 11, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Personal Presence H ome Watchers and Services LLC ( hereinafter petitioner or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial surveys, photography, videography, and inspections

.
See Appendix A for the petiti on submitted to the FAA des cribing 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

.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3

.
The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic 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 the2

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

, C ertification 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 d ata collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 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 Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications des cribed 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 th e 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.

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, Personal Presence Home Watchers and Services 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 all ow the petitioner to operate a UAS to perform aerial data collection

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

1 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 (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

Conditions and Limitations

In this grant of exemption, Personal Presence Home Watchers and Services 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 Phantom 3 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 cer tificate 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 a lways maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her des ignation 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 st ated 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,4

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating document s. 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 p etition for an amendment to its grant of exemption. The FA A’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 ensur e 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.

, inop erable 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 conditio n 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.

12. Each UAS operated under this exemption must comply with all manufactu rer 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or he r pilot certificate.5

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 V Os (traini ng, 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, trainin g operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appr opriate 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 air port symbo l 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 managem ent 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 PI C.

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

- determined location within the pr ivate or controlled

- access property.

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

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 recommen ded by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intend s to conduct operations that cannot be conducted under the terms of the attached COA

.6

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 nonpartici pating 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 r emain 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 control led

- access property with permission from the property owner/controller or aut horized representative. 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 opera tional area as defined by the applicable COA must be reported to the FA A'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

.7

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 Standa rds District Office (FSDO) with jurisdiction over the a rea 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 th e 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 certific ate 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 t o 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 essenti al 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 specifie d 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

EnclosuresPersonal Presence Home Watchers and Services LLC Paul W. Anderson 387 Bay Tree Drive Miramar Beach, FL 32550

(850) 460

- 4818 pwa850@gmail.com

Date: June 11 , 2015

U. S. Department of Transportation Docket Management Sy stem 1200 New Jersey

Ave., SE Washington, DC 20590

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Personal Presence Home Watchers and Services , LLC , operator of Small Unmanned Aircraft Sy stem (“sUAS ”) equipped to conduc t aerial photography and videograph y, News gathering, Aerial Survey ing, and Close d set Video production hereb y applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, so 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 333.1

As described more full y below, the requested exemption would permit the operation of small, unmanned and relativel y i nexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Personal Presence Home Watchers and Services , LLC to conduct commercial operations of small unma nned aircraft sy stems (“UAS”) meeting or exceeding all of the operational and safet y requirements Congress has set forth in Section 333. Page 2

. Personal Presence Home Watchers and Services , LLC asks that if any part of this request is deemed not in compl iance, that part be removed and process the remaining of this request as applicable.

Personal Presence Home Watchers and Services , LLC plans to exploit the capabilities of Unmanned Aerial Sy stems to offer a multitude of services, including:

- Aerial sur

vey ing

- Event Photograph y/ Videograph y

- Agriculture purposes

- Real Estate Photography

- Aerial filmmaking and photograph y

- Construction site inspections and monitoring

- Closed set video production

- News Gathering

Statutory Authorit y Section 333, titled “Special Rules for Certain Unmanned Aircraft Sy stems”, provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraftsy stems may operate safely in the national airspace sy stem before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required b y section 334 of this Act.” In Section 332(b)(1), Congress made it clear that S ection 333 provides a mechanism for “expedited operation authorization” if several factors are met. Peti tioner meets all requirements to permit FAA approval of commercial UAS operations.

Small U nmanned Aircraft Sy stem s are oftentimes seen as superior to h elicopters due to the smaller devices

, cheaper equipment and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safet y.

We are petitioning for exemption to enable Personal Presence Home Watchers and Services

, LLC to operate the DJ I Phantom 3 equipped with a two

- axis camera gimb al and using a High

Def camera. This sUA S has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator

. They also has the failsafe function of the autopilot sy stem which means when the communication between the Main Controller and the transmitter is disconnected, the outputs of all command sticks from controller will go to the center position. If GPS signal is available , the s ys tem will automatically trigger Return to Home and will land safel y.

Aircraft Gross weight is less than 2.8 pounds with battery and camera pay load.

A Pre

- flight inspection will be performed by the PIC in accordance with the fac tory instruction manual. An added step will be the inspection of the propellers. A propeller will be replaced if it has an y nicks and cracks with a manufacturers authorized propeller.

The sUA S will be maintained in accordance with the manufacturer’s instruction manual and only manufacturer's authorized replacement parts will be used.

**FCC Information** This transmitter s used for controlling the sUA S complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This device may

not cause harmful interference, and (2) this device must accept an y interference received, including interference that may cause undesired operation. The radio transmitter s used for controlling the sUA S is wireless technology which has been
t es ted and found to be compliant with the applicable regulations governing a radio transmitter s in the 2.400GHz to 2.4835GHz frequency range. Antenna Separation Distance When operating our transmitter s , the PI C will maintain a separation distance of at least 5 cm between his body

(excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RF exposure safety

requirements as determined by FCC regulations.

**Pilot in Command and Observer Qualifications and Duties**  The PI C will maintain a driver’s l icense and at least 1 hour’s fly ing time and 3 takeoffs and landings within the previous 9 0 day s in the t ype of UA S utilized in operations. The PI C will haveat least 100 hours fl yi ng Radio Controlled Mo del Aircraft in the form of sUA S 's for recreational

use.

The PI C is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but not limited to:

 Safe in flight operations

 Risk mitigation to p ersons and propert y

 Airfield Suitability

The Observer must have the visual acuity to observe the sUAV and be able to communicate clearl y with the PIC.

The Observers duties are;

 warning the PIC of an y i mpending obstacles in the flight path of the sUA S

.

 warning the PIC of an y deviations in the planned flight path of the sUA S

.

 warning the PIC should any unauthorized personnel appear in the area of the planned flight. The Observer will have the authority to order the PI C to terminate the flight should he feel the flight cannot be conducted safel y.

**General Operating Standards**

• Personal Presence Home Watchers and Services , L LC will only operate its sUA S in line of sight of a pilot and observer and will operate at sites that are a 'sufficient distance' from populated areas. Such operations will insure that the sUAS will "not create a hazard to users of the national airspace s ys tem or the public."

• Before an operation of a sUAV within 5NM of a n airport with a control tower, the control tower wi ll be called to gain permission to operate the sUA S . The PI C will give the position

, altitude and the times the sUAV will be operated. The sUA S will not be ope rated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling.

Before an operation of a sUA S within 5NM of a non

- tower controlled , airport operators will be notified and the PI C will give the right of way to avoid fly ing in the proximity of full

- scale aircraft. At no time will the sUAV be operated within the final approach course and the takeoff course of an y runway . The sUAV will not be ope rated at an altitude of over 400 feet AGL. Weather minimums will be 3 miles visibility and a 1000 f

oot ceiling.

• Maximum flight time for e ach operational flight will be 3 0 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 3 0 minute limit.• The sUAV will be programmed so that it will be operated at an altitude of no more than 400

feet AGL

. • Minimum crew for each operation will consist of the sUAS Pilot and Visual Observer.

• The sUA V operated b y the petitioner weighs less than 55 pounds, including the
pay load (i.e. camera, lens, and gimbals ).

• The sUAV will operate at speeds of no more than 2 5 knots, can hover, and can simultaneously move verticall y and horizontally

.

• Given the small size of the sUAV and the restricted sterile environment within which they will operate, our sUA V operations adhere to the Reform Act's safet y requirements.

The UA S , powered b y batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it operates at lower altitudes with no people on board and will thereb y reduce current risk levels and thereb y enhance safet y and diminish the likelihood of death or serious bodil y injury . With a small pay load and maximum flight time of only 20 minutes per battery

cy cle, this offers no risk to national securit y.

Low level oblique photos and video from several angles are far more effective than ground based imagery for display ing the characteristics of large, complex properties with several buildings and large trees. The applicants in the past have chartered 2

- seat full

- sized helicopters for this purpose, which has proven more costly than many

potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit man y bu ye rs and sellers of real property as well as mitiga ting risk by not carry ing personnel for flight operations.

(a) No flight will be made with a Gross weight exceeding 55 pounds ;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate b y voice at all times during a flight operation;

(d ) All required permits will be obtained from state and lo cal government prior to operation;**EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY**

Personal Presence Home Watchers and Services , LLC requests an exemption from the following regulations as well as any additional regulations that may technicall y apply

to the operation of the sUAV Sy stem:

**14 CFR Part 21, Airworthiness Certificates** This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned A erial Sy stems, we request an experimental certificate be issued for the DJ I Phantom 3 under either or both of the following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: **(a) Research and deve**  **lopment**

. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations** 

. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of t ype and supplemental ty pe certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requ irements of the regulations. Since the experimental certificate can be used for commercial purposes such as market survey s, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpo se as well. The aircraft will not carry persons or propert y, will not carry fuel, and will only fl y under strict operational requirements. Combined with the UA's light weight, being constructed primaril y of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. I f an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H

, and the requirement for an airworthiness certificate in general, citing the equivalent level of safet y outlined in the previous paragraph.

**14 CFR 45.23 Display of marks; general and 45.29 Size of marks.** These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally , the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV doe s not have an entrance in which the word "EXPERI MENTAL" can be placed, and may

not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safet y b y including the word "EXPERI MENTAL" in the placard on the top of t he aircraft, as shown above, where the PI C (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally , we feel that the permanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally , we will display

at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inch es high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to any one that observes the aircraft and chooses to investigate its point of origin.**14 CFR 91.7 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 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements**

. This regulation provides t hat no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We reques t an exemption to this requirement since the aircraft is not only too small to carry

documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safet y and meet the intent of 91.9, we propo se that a current, approved sUAS Flight Manual must be available to the crew at the ground station any time the aircraft is in, or preparing for, flight.

**91.119 Minimum safe altitudes** : General. The regulation states that over sparsel y populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be
necessary to operate closer than 50 0 feet to the items listed. Operations will only be flown over propert y or persons where permission has been obtained and careful pre

- planned flight path has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, a n emergency

landing without undue hazard to persons or propert y on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered i n granting the exemption.

**CFR 91.121 Altimeter settings**

. The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will alway s fl y below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board computer to the display screen held by th e PI C, providing a constantl y updated AGL readout.

**14 CFR 91.151 Fuel requirements for flight in VFR conditions**

. The regulation provides that no person may begin a flight in an airplane under day

- vFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fl y after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safet y buffer for delays to landing. The sUAV is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly

more than 3 / 4 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the r eserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy ".**14 CFR 91.203(a) & (b) Civil aircraft: Certifications required**

.

The regulation provides that an airwor thiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally

, subparagraph (b) provides that the airworthiness certificate be "display ed at the cabin or cockpit
entrance so that it is legible to passengers or crew." At a maximum gross weight of 6.1 p ounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of

carr yi ng passengers or crew. To obtain an equivalent level of safet y and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and available for inspection upon request. I n order to identify the aircraft, we propose that the infor mation found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

**14 CFR 91.205(a), (b), (c) Instrument and Equipment Requirements**  This regulation provides a minimum set of instruments and equipment required for day and night VFR flight. Due to the small size of the sUAS it would be impossible to carry man y of these instruments. 91.205 ( b ) 4,5,6,7 ,8,13,14,16,17 are not applicable as the sUAS has no Reciprocating engines or seats. 91.205 (b) 2,3,9 are provided on the hand held controller

. 91.205(b) 1 is not applicable as the maximum available speed of the sUAS is less than the maximum required by

th is exemption and has no effect on performance. 91.205 (b) 10 is not applicable as the landing gear position can be verified visually before landing. 91.205 (b) 15 Due to the size it would be impossible for the sUAS to carry any known ELT. 91.205 (c) Much o f this equipment is too he avy

to be carried by

the sUAS . We feel that visual contact with the sUAS and indications provided via the controller that all critical information can be monitored.

**14 CFR Subpart E (91.401**

**- 91.417)** 

**- Maintenance, Preventive Mai**  **ntenance, Alterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in

an airworth y condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service b y a person authorized under 43.7" after maintenance and inspection. I t is our intention that the PI C perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PI C will e nsure that the aircraft is in an airworthy condition prior to every

flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed b y the PI C is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All other maintenance will be performed b y the manufacturer or their des ig nated repair facility

. We fee l that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safet y.

**Safety and Benefits of the UAS** Personal Presence Home Watchers and Services , LLC will be using the UAS in a variety of applications tha t generally require expensive full

- size manned aircraft to complete. Small, light, unmanned aerial vehicles offer my riad benefits over the use of full

- sized manned aircraft for electric power line inspection, oil/gas pipeline inspection, advanced agriculture, film and stillphotograph y, just to name a few. Replacing significantly larger manned aircraft carry ing crew and flammable fuel with small UAS carr yi ng no passengers or crew creates a much greater margin o f safety

for the pilots and crew.By granting Personal Presence Home Watchers and Services , LLC ‘s requested exemptions, the FAA will help drive development of safe and successful commercial UAS operations and will advance the public knowledge base for such operations. Personal Presence Home Watchers and Services , LLC is committed to promoting the UAS research efforts of policy makers including the FAA, NASA, DOD and DARPA by sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.

**Conclusion** As poin ted out in this application, the s UAs which our compan y would use, under auth orization by

the US DOT

- FAA, is a small, light

- weight device operated within the line of sight of the Pilot

- in

- Command (PI C), less than 400 feet above the ground and outside 5 miles from an y airport, heliport, seaplane base, spaceport, or other location with aviation activities, unless the air traffic control autho rities (ATC) have been notified and have authorized each flight within a radius of this distance.

The s UAs have proven capability for controlled flight. They are devices offered for general sale on the market around the world and have often been used as M odel Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law 112

- 95, 2014, have already provided y ou with the assurances on the airworthiness of SUAs such as ours.

For the foregoing reasons, the e xemptions requested herein should be granted and Personal Presence Home Watchers and Services , LLC should be permitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate b y the FAA. The submission of this application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some SUAs
may be used for legitimate commercial activities and under reasonabl y safe conditions. If a ny individual aspect of this request for exemption be unacceptable we ask that it be struck alone and the remainder of the exemption be allowed as requested.

Signed

Paul W. Anderson Personal Presence Home Watchers and Services , LLC