Below is my request for a 333 exemption.

I have attached an operation manual pertaining to my request. The company name is Just Aviation LLC. I am requesting in addition to the 333 exemption is having my manual approved. This manual hopefully shows how we will operate the drones in a safe and efficient manner. We will operate with safety as our number one priority.

Section 333 Exemption Requesting an exemption of the use of small drones for commercial use such as aerial photographic and property inspectio ns. Seeking relief on AC91

- 57A limiting non

- commercial operations and Part 91.119 as well as others listed below . I will likely want to fly the drone closer than 500 feet to structures, vehicles and persons. I will likely need to operate lower than 500 feet. Requesting permission to operate a drone for aerial photography with some stipulations including limiting operations to daytime hours, at an altitude of no more than 400 feet above ground level within line of sight and at a speed of no faster than 50 miles per hour. Requesting use of drones such as the Blade Chroma, Bla de 350 QX3, Yuneec Q500 Typhoon, Typhoon H , DJI Inspire 1 and DJI Phantom 3 series, weighing less than 50 pounds. I am looking to use these drone for business purposes for home inspect ions, property sale and advertising photos and videos for potential customers. The reasons why granting the request would be in public interest is the UAS provide safer work conditions for company employees because the employees will not have to go into da ngerous environment (not having to climb up and around structures for inspections and photographic documents of property and equipment). A UAS is safer than a helicopter or small plane because it is lighter and less combustible. A UAS is more environmenta lly friendly than helicopters or small planes because it reduces noise and air pollution. UAS use contributes to reduced airport congestion by reducing the commercial use of small planes and helicopters

. There is less risk to life and property on the groun d

. UAS use is more economical for companies and contributes to the U.S. economy by allowing them to stay competitive . Allowing the petitioner to use a UAS would fulfill Congress’s goal under § 333 of the FMRA by allowing UAS operation with significant safety precautions in a low risk environment before the publication of the rulemaking required under FMRA § 332. Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a conside ration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports and populated areas. An analysis of these criteriademonstrates that the sUAS operated without an airworthiness certificate in the areas a nd under the

conditions contemplated by DFAM will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the conditions proposed in this request. The sUAS is less than 55 l bs. fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator and observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area of operation as is now done with conventional equipment, infrastructure, bridge and out building evaluation. These safety enhancements provide a n expanded degree of safety to the inspectors over conventional operations. Lastly, application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS, due to its size, speed of operation, location of op eration, lack of explosive materials and inability to carry a substantial external load. Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equivalent level of safety un der Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 14 C.F.R. §61.113(a) and (b) § 61.1 13 Private pilot privileges and limitations: Pilot in command. a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

***** DFAM anticipates initially using a cadre of specially trained staff to conduct the sUAS operati ons. While these individuals will not hold commercial pilot licenses. The sUAS will not carry property for compensation or hire since they will be used solely to assist in evaluation of the infrastructure, equipment, right

- of

-way, assets, bridges, tunnel s and out

- buildings in furtherance of DFAM’s client’s primary business, the successful operation of a infrastructure; however, the employees’ operation of thesUAS will not be incidental to their employment with DFAM, and they will be compensated for such

wo rk. Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelope under the sole control of DFAM clients. Accordingly, the risk would be limited to DFAM personnel, who will be appropriate ly outfitted in safety gear, and DFAM client’s property on the ground. Requiring a commercial pilot certificate would provide no appreciable safety benefit and would needlessly impose additional cost on DFAM. Because the contemplated operations would not c omply with §61.113(b) (1)and none of the other exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b). 14 C.F.R. 91.119(c) § 91.119 Minimum safe altitudes: General. Except when necessary for takeoff or landing, no person may o perate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to a ny person, vessel, vehicle, or structure.

***** DFAM submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk of collision with another aircraft, safety can only be assured through the grant of an exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because an emergency landing of the aircraft due to a power failure will not create an undue hazard to persons or property on the surface. As noted in the explanation of why an exemption will not adversely affect safety, DFAM clients has exclusive use of the land over which the sUAS will be operated, and public access is restricted. It also has exclusive use of significant portions of land adjacent to the infrastructure and structures that will be the objects of evaluation and analysis. DFAM’s Clients tightly control access to land and have the ability to assure that no individuals unassociated with the planned operations are o n the affected land. As such, the risk of injury is minimal. DFAM does not contemplate conducting operations over congested areas, so relief is not requested from paragraph (b).14 C.F.R. 91.121

14 C.F.R. §91.121 Altimeter Settings This regulation requi res each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.”

***** As the sUAS may not have a barom etric altimeter, but instead a GPS altitude readout, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altit ude indicator before flight. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display. This altitude information will be generated by equipme nt installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.
14 C.F.R. 91.151 §91.151 Fuel requirements for flight in VFR conditions. (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first poi nt of intended landing and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

***** Operating the sUAS in a pre

- defined area with less than 30 minutes of reserve fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it has to be flown to an alternate airport or circle the planned airport in the event of unanticipated conditions. DFAM does not intend to use the sUAS or point

-to

- po int flights and will not operate the sUAS beyond visual line of sight. Nor will the sUAS require an airport in order to land. Rather, DFAM will operate the sUAS using pre

- planned flight paths (taking into account weather conditions) designed to allow the s UAS to fly to the point of intended landing. As such, there is no need for a time based excess fuel requirement. Rather it should be sufficient to require only as much additional excess flight capacity as necessary to safely land the sUAS. We believe that a 25% battery reserve is more than sufficient to meet this objective.14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1) & (2) and 14 C.F.R. 91.417(a) & (b)§91.405

Maintenance required. Each owner or operator of an aircraft

– (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;

***** §91.407 Operation after mai ntenance, preventive maintenance, rebuilding, or alteration. (a) No person may operate any aircraft that has undergone maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service by a person authorized under§43.7 of this chapter;

***** §91.409 Inspections. (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had __ (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

***** §91.417 (a) & (b)

* **** DFAM believes that an exemption from these three maintenance requirements is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no ind ividuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to service inspections required by §91.409(a). DFAM will maintain the aircraft as instructed in the owner’s ma nual and ASTM F2909, whereapplicable, and will not operate the aircraft until it has reasonably determined that any needed repairs

have been made. However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) a nd 417(a) & (b), we believe an exemption from these provisions is appropriate. With my extensive background in both aviation as a ATP pilot with 11,000 hours and being involved in the model radio control hobby for 25 plus years I feel I can use the knowled ge I have create a business to provide a safe and efficient operation of these drones, I will have rules in place to assure the public will be protected and safe. Offering these services will provide fast and efficient ways to perform these requests avoidi ng people to climb up to dangerous heights. I feel this business will provide a service that until now the technology has not allowed. Because of the advancements in the aerial drones equipment and components this can be done safe and in a very controlled manner. Understanding the airspace rule and regulations is extremely important along with having the proper operating rules in place will assure safe operations. If you grant me approval I will provide the model and S/N of my drone to be used in the busine ss so I can receive a registration number to attach to it.

Please do not hesitate to contact me at the phone number or via the e

- mail address provided above should you have any questions or concerns.

Sincerely, Timothy P Lehman
Just Aviation LLC