MCMAHON • 

HELICOPTER SERVICES 

Mach 20,2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 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- pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 to further develop and operate our small Unmanned 

Aircraft Systems (UAS) commercially. 

If granted, the exemption would allow us to conduct aerial 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 out utilizing our certified aircraft. As described more thoroughly 

below and 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 of a very similar nature to previous requests your department has 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 proprietary information. 

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 A copy of the MHS Air Carrier Certificate is enclosed. 

2 A copy of the MHS Repair Station Certificate is enclosed. 

3 A copy of the MHS UAS Operations Manual is enclosed and is confidential. 
The regulations we wish to request to 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 that the above regulations are applicable 

to any aircraft operations and not specific to aircraft category or class. As you have 

previously concluded, these regulations will require an alternative ruling or exemption in 

order to conduct UAS operations. We have also concluded that there are several regulations, 

which will surely apply to our UAS operations, but currently only apply to specific 

categories of aircraft- 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, proprietary UAS Operations Manual, which outlines our 

company's UAS operating procedures. 

91.199(b) and (c)- Minimum Safe Altitudes over Congested Areas & other than 

Congested Areas 

Explanation: Since the UAS will not be operated above 400 feet AGL, it cannot comply with 

parts (b) and (c) of this section. 

91.121 Altimeter Settings 

Explanation: The aircraft does not have a pitot static system and relies on GPS for altitude 

readings. 

91.215(b)(2) ATC Transponder and altitude reporting equipment and use 

Explanation: Under this subpart, no aircraft can operate within the Mode C veil without a 

proper transponder and Mode C capabilities. The UAS does not have a payload capacity or 

power system sufficient to support this requirement. 

91.407(a)(1) Operation after maintenance, preventative maintenance, rebuilding, or 

alteration 

Explanation: The FAA has not defined the qualifications of a UAS technician under part 

43.7. 
91.409(a)(1) and (a)(2) Inspections 

Explanation: (a)(1) The FAA has not defined the qualifications of a UAS technician under 

part 43.7. 

(a)(2) The FAA does not issue airworthiness certificates for our UAS systems. 

Public Benefit 

This requested exemption would enable MHS to develop new technologies, UAS operational 

methods, and work with the FAA to help integrate UAS operations into the National 

Airspace System -ultimately reducing the costs of certain aerial services we currently 

provide to businesses and consumers with our certified aircraft. This exemption would also 

enable MHS to operate in locations and at altitudes that otherwise may be potentially 

hazardous for certified aircraft due to the size of the helicopters, proximity to obstructions, 

and other factors. Additionally, the UAS will significantly reduce carbon emissions and the 

noise footprint created by turbine and piston powered aircraft performing similar tasks. 

Reducing noise levels in any environment improves ease of communication on the ground 

and also reduces or eliminates complaints by non-participants. 

Safety Standards 

If granted this exemption, MHS will meet or exceed the same high-level, FAA Approved, 

safety standards in which we already operate our certified aircraft. As detailed in our UAS 

Operations Manual, MHS will notify the FAA in advance of UAS 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 of the UAS (weight is under SSlbs.), the lack of combustible 

fuel, lack of on board pilot or passengers, the UAS poses less of a potential risk to persons or 

property than a certified aircraft when operated in a controlled environment performing 

certain tasks. 

It should be noted that as an Air Carrier, MHS understands the importance of the United 

States National Airspace System (NAS), MHS abides by the rules that the DOT and FAA 

mandate, and MHS understands the magnitude of the 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 

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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 of this certificate is punishable by a fine of not exceeding $1,000, or imprisonment not exceeding 3 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)