# • MCMAHON HELICOPTER SERVICES Mach 20,2015 U.S. Department ofTransportation Docket Management System 1200 New JerseyAve., SE Washington, DC 20590 Dear Sir or Madam: Our company, McMahon Helicopter Services, Inc. (MHS), an FAA licensed Air Carrier1 and Repair Stationz, hereby applies for an exemption from certain Federal Aviation Regulations (FARs) listed in this letter -with explanations- pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 to further develop and operate our small Unmanned Aircraft Systems (UAS) commercially. Ifgranted, the exemption would allow us to conductaerial work for our clients in the energy industry, motion picture/television industries, and real-estate industries, who frequently require low-level aerial images utilizing various sensors and equipment- all of which we currently carry oututilizing our certified aircraft. As described more thoroughly belowand in our UAS Operations Manual3, any commercial or experimental operation involving UAS would be conducted by MHS with safety standards that meet or exceed the current safety standards for our certified aircraft. This request is ofa very similar nature to previous requests your departmenthas received and granted exemptions to on September 25, 2014 through March 19, 2015. We ask that all confidential information enclosed such as operations manuals, aircraft flight manuals, procedures, etc., are not published or shared as they contain proprietaryinformation. For the record, the applicant name, address, and contact information is as follows: Company Name: Contact Name: Address:
Phone: Fax: Email: McMahon Helicopter Services, Inc. Nicholas McMahon Executive Heliport Building 8351 Ronda Drive Canton, MI 48187 1-734-459-5980 1-734-459-5980 nick@mcmahonhelicopters.com

1 

### Acopy ofthe MHS Air Carrier Certificate is enclosed. 2 

### Acopy ofthe MHS Repair Station Certificate is enclosed. 3 

### Acopy ofthe MHS UAS Operations Manual is enclosed and is confidential.The regulations we wish to requestto be exempted from for UAS operations are: 91.199 (b) and (c) 91.121 91.215(b)(2) 91.407(a)(1) 91.409(a)(1) and (a)(2) 

### Regulations and Explanations While conducting our research, we have concluded thatthe above regulations are applicable to anyaircraft operations and not specific to aircraft category or class. As you have previously concluded, these regulations will require an alternative ruling or exemption in orderto conduct UAS operations. We have also concluded that there are several regulations, which will surely applyto our UAS operations, but currently only applyto specific categories ofaircraft- such as altitude restrictions and placards. We have included guidelines for these regulations based on your previously approved exemptions for other UAS operators in our confidential, proprietaryUAS Operations Manual, which outlines our company's UAS operatingprocedures. 

### 91.199(b) and (c)- 

### Minimum Safe Altitudes over CongestedAreas &

### otherthan CongestedAreas Explanation: Since the UAS will notbe operated above 400 feetAGL, it cannot comply with parts (b) and (c) ofthis section.


### 91.121 Altimeter Settings Explanation: The aircraft does nothave a pitot static system and relies on GPS for altitude readings. 

### 91.215(b)(2) ATC Transponderand altitude reporting equipmentand use Explanation: Under this subpart, no aircraft can operate within the Mode Cveil without a propertransponder and Mode Ccapabilities. The UAS does not have a payload capacity or power system sufficientto supportthis requirement. 

### 91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding, or alteration Explanation: The FAA has not defined the qualifications ofa UAS technician under part 43.7.

### 91.409(a)(1) and (a)(2) 

### Inspections Explanation: (a)(1) The FAA has not defined the qualifications ofa UAS technician under part43.7. (a)(2) The FAA does not issue airworthiness certificates for our UAS systems. 

### Public Benefit This requested exemption would enable MHS to develop newtechnologies, UAS operational methods, and workwith the FAA to help integrate UAS operations into the National Airspace System -ultimatelyreducing the costs ofcertain aerial services we currently provide to businesses and consumers with our certified aircraft. This exemption would also enable MHS to operate in locations and ataltitudes that otherwise maybe potentially hazardous for certified aircraft due to the size ofthe helicopters, proximityto obstructions, and other factors. Additionally, the UAS will significantlyreduce carbon emissions and the noise footprint created byturbine and piston powered aircraft performing similar tasks. Reducing noise levels in any environmentimproves ease ofcommunication on the ground and also reduces or eliminates complaints by non-participants. 

### Safety Standards Ifgranted this exemption, MHS will meet or exceed the samehigh-level, FAA Approved, safety standards in which we already operate our certifiedaircraft. As detailed in ourUAS Operations Manual, MHS will notify the FAA in advance ofUAS operations, utilize air-toground radios for communication with other air traffic as an additional safety method when necessary, utilize spotters, and operate within a controlled access environment. Further, given the small size and weight ofthe UAS (weightis under SSlbs.), the lack ofcombustible fuel, lack ofonboard pilot or passengers, the UAS poses less ofa potential risk to persons or propertythan a certified aircraft when operated in a controlled environmentperforming certain tasks. It should be noted thatas an Air Carrier, MHS understands the importance ofthe United States National Airspace System (NAS), MHS abides bythe rules thatthe DOT and FAA mandate, and MHS understands the magnitude ofthe responsibility required while operating Unmanned Aerial Systems in a commercial aviation environment. We are looking forward to integrating UAS into our company operations and also helping the FAA integrate these systems into the NAS. Please feel free to call or email me with any questions.

Nicholas McMahon President McMahon Helicopter Services, Inc.UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION



# ~tr **~gencp** 

# ((ertfftcate

BUBR632C 

# Yht;v,cedf-/,cale'



## ~~titMued-lo' McM'A:ffON HELICOPTER SERVICES, INC.



### ~wet**,I.U4ineMt,a~~,itv** EXECUTIVEHELIPORT

8351 RONDA DRIVE CANTON. MT 4R1 R7 

## ,ujtow Jindin!f/Mat

## ttU't07anr?Jation'

**,cofftfilt"e.i~** 

## ,in'

# a/t/Jte4-jtectJ/ 

# ,wiCk

**~the' ffiefjUWtefflena~** 

# ,of,tkffede'Jlab



## ~iatiom/ f!le!lulatwm /Jlelatin!l'



## ,to~ 

# £he·· tl!daUt4hfftenC



## ~an~ **s;t;_~ ~en~;**  

# ,and

**a~** tlm'lfwtae'JlerP

**LiJ~ tOjte'Jlale~**  an1

## ,ajtfi'JloV-ecb REPAIR STATION

LIMITED AIRFRAME LIMITED POWERPLANT LIMITED ACCESSORIES 

## ffl.ia/

# teedr/icak

**an~~**,canceled;4U4fiendedtO'Jl','JleV-ohed;

**4halt~conlinuet**

**~n 1** 



## ~ct INDEFINITELY

**0>aw~:** JlTNE 13, 1986



# /!Lt7&~ R- APRIL 10, 2008 CARL R. WELKE, ACTINGMANAGER, DTW FSDO 1:1li5

**~crtifiratt** is nOt 1.rransftr9bl£, AND ANY MAJOR CHANGE IN THE BASIC FACILITIES, OR IN THE LOCATION THEREOF, SHALL BE IMMEDIATELY REPORTED TO THE APPROPRIATE REGIONAL OFFICE OF THE FEDERAL AVIATION ADMINISTRATION Any alteration ofthis certificate is punishable by afine ofnot exceeding $1,000, or imprisonment not exceeding3 years, or both

FAA Form B000--4 (1-67) SUPERSEDES FAA FORM 390.

# ,, ) US. Department

. ofTranspartation

Federal Aviation Administration 

# Air Carrier Certificate This certifies 

# that

MCMAHON HELICOPTER SERVICES, INC. 8351 RONDA DRIVE CANTON, MICHIGAN 48187


### has met the requirements of the Federal Aviation Act of 1958, as amended, and the rules, regulations, and standards prescribed thereunder for the issuance of this certificate and is hereby authorized to operate as an air carrier and conduct common carriage operations in

- accordance with said Act and the rules, regulations, and standards prescribed thereunder

. Jand the terms, conditions, and limitations contained in the approved operations specifications.

\ 

### This certificate is not transferable and, unless sooner surrendered. suspended, or revoked,

shall continue in effect indefinitely.

Certificate number: BUBA632C Effective date: JANUARY 16, 1981 REISSUED: MAY 12, 1989 Issued at:_-=GL=2=3"-----------

FAA Form 8430-18 (6-87) By Direction of the Administrator.

(Signature) ./ ' MANAGER (Title) GREAT LAKES REGION/DTW FSDO (Region I Office)