U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE Washington, DC 20590 

Subject: Exemption request under Section 333 of the FAA Reform Act

Dear Sir or Madam: 

The purpose of this letter is to petition the Federal Aviation Administration for an exemption from certain Federal 

Aviation Regulations in order for the petitioner, Mois Family Tech LLC, to operate an Unmanned Aerial System 

(UAS) within the United States. Mois Family Tech LLC would like to offer its clients cost-effective aerial imaging

and other services for the public at large. Mois Family Tech LLC is well aware of the risks associated with operating 

unmanned aircraft, and as such, exercises due diligence in enforcing proper safety measures for safe operation. Mois 

Family Tech LLC is comprised of three well-seasoned operators with over 4,000 hours of combined UAS flight time 

operation. One of the three operators currently holds a current pilots license. 

Accordingly, and pursuant to 14 CFR §§ 11.61-.103 and Section 333 of the FAA Modernization and Reform Act 

of2012, PL 112-95 (Feb. 14, 2012), the petitioner is submitting the following information with this request: 

Identity of Petitioner:

Petitioner

 

Mois Family Tech LLC 

636 Stephenson Avenue, Suite A

Savannah, GA 31405

 

Description of Operations:

A. The UAS(s) that are the Subject of this Petition.

 Mois Family Tech LLC is the owner of a DJI Phantom 3 Professional, The Duas_X8 Octocopter, and the 

Duas_Y6. Please see attachments for pictures of stated aircraft. The Phantom 3 requires little introduction, as it has 

been the subject of many petitions to date. 

 The Phantom 3 Professional is a quad-copter with a camera mounted beneath it, piloted via an RC Transmitter 

operating in the 2.4GHz and 5.8GHz Frequencies, and a portable ground station ran on iPad Mini Tablet. The DJI 

Phantom 3 Professional weighs approximately 1256 grams ready to fly. The DJI Phantom 3 Professional is a widely

known unmanned aircraft, and is the same type of aircraft that has recently received numerous grants of exemption by

the FAA.

 The Subject UAS is equipped with lost-link capability, which enables the Phantom 3 to enter a fail-safe Return-toHome Mode in the event that the link between the aircraft and the ground station is lost. The Phantom 3 also 

incorporates a built in failsafe that initiates a return to home location in the event the battery hits critical level. The 

onboard system also calculates the amount of battery life it needs in order to return home and will not allow the 

operator to fly too far horizontally, or vertically. The Subject UAS can operate for a total of approximately 25 
minutes on one battery charge. The Phantom 3 Professional also has programmable altitude and radius limits to 

establish a restricted operational area.

The Duas_X8 and the Duas_Y6 are professional grade aircrafts built by DebonAir UAS. Both aircraft utilize coaxial 

rotor designs. The Duas_X8 has eight motors, while the Duas_Y6 has six. Both aircraft are built around the proven 

Pixhawk flight controller manufactured by 3D Robotics, and can be found in the 3D Robotics Iris, which has been 

previously granted exemptions. 

Below is a list of basic aircraft specifications for the Duas X8 and Y6: 

1. Both aircrafts measure 1000mm in diameter, smaller than the DJI S1000

2. Both aircrafts weigh less than 20 pounds with their respective loads, which is less than a loaded DJI S1000

3. Both aircrafts measure no more than 24 inches tall

4. Both aircrafts utilize only one 6S 16A LiPo battery at a time, as opposed to the two that are typically carried by 

other approved UAS systems of comparable size or larger.

5. Both Aircrafts use the high precision UBlox M8N GPS receivers that track not only GPS satellites, but GLONASS 

as well for the highest level of positioning. 

6. Both Aircrafts utilize standardized ground control station software that provide the operators with real time flight 

date such as airspeed, altitude, battery level, magnetic heading, air pressure, air temperature, GPS location, RSSI, and 

sensor malfunction alarms. 

7. Both aircrafts will soon be outfitted with parachute supported failsafe systems to provide an added measure of 

safety. 

8. Both systems use high efficiency and high quality brushless drives made by a reputable industry manufacturer 

who makes the drives for many of the UAS already granted exemption.

9. Both aircrafts feature multiple proven failsafes that will land the aircrafts, return them to their launch, or 

predetermined rally points if/when triggered. Failsafes include, low battery failsafe, loss of RC control failsafe, loss 

of ground control station signal failsafe, geofence failsafe and altitude failsafes. There is also a crash detection 

failsafe which kills power to all motors when a predetermined angular rate is detected, such as if the aircraft were to 

flip over 180 degrees during loss of control. The ground control station also warns the operator via voice synthesized 

speech when critical altitudes, or air speeds are breached. We have spared no expense in implementing proper 

failsafes for safe operation, and we will continue to implement them as development permits. 

10. Both aircrafts have proper red and green navigation lights, which are visible during day or night operation. 

11. Both aircrafts will be utilized to carry 3-axis brushless gimbals for camera operation, carrying GH4 cameras 

only. The GH4 offers imaging capabilities not found on smaller systems such as the Phantom 3 Professional. 

12. Both aircrafts were built by arguably one of the most experienced commercial UAS builders currently available. 

The quality of these systems are arguably higher than most of the systems that have been approved. In our 

experience due to their lower weight over a DJI S1000, their industry proven 3D Robotics autopilots, hardware, and 

quality of build, they are simply much safer systems for UAS applications than anything comparable in their class. 

13. Please see attached images for the subject aircrafts. Mois Family Tech LLC will be more than happy to provide 

the FAA with any additional information on these aircrafts if there is a question of there safety or reliability. 
B. The UAS Pilots in Command. 

Mois Family Tech LLC employs three highly qualified pilots who have an estimated 4,000 or more hours combined 

flight time operating large and small UAS. Two of which have arguably more documented time operating UAS than 

many previous petitioners. 

Pilots are as follows:

Benjamin Mois

-Home45 Downie Ct.

Richmond Hill, GA 31324

-Office636 Stephenson Avenue, Suite A

Savannah, GA 31405

Kevan Stone

575 Dalcross Drive

Richmond Hill, GA 31324

Todd Hill

415 Barnes Street

Florence, AL 35630

Benjamin Mois is the owner and operator of Mois Family Tech LLC. Mr. Mois has over 700 hours of flight time 

experience operating small and large UAS aircraft. Mr. Mois is well versed in the safe operation of these UAS 

aircrafts and with the subject overall. 

Kevan Stone is a well-seasoned UAS operator. Mr. Stone has extensive experience operating small and large UAS 

for Northrop Grumman. Mr. Stone also holds a valid pilots license. Mr. Stone's credentials are as follows:

· Pilot License - Kevan Michael Stone - Certificate #3149975 - Date of Issue, 8 JUN 2006

· 1,200 hours as a UAS Fixed-Wing Internal & External Flight Instructor - Hunter UAS MQ-5B, 

 Hermes 450 UAS. 

· UAV Systems Specialist - Shadow 200

· 1,400 hours as a UAS Payload (EO/IR) Operator

· 5 Combat Tours (4+ years in theatre) serving in Iraq & Afghanistan 

· 800+ hours as a Multi-Rotor Pilot 

· 20 years of R/C Piloting experience; Fixed-Wing, Single/ Mulit-Rotor, and Turbine Aircraft

· Current FAA Class 2 Medical Certificate
· Designated Mission Commander & Aviation Safety Pilot

Todd Hill has been developing small and large fully autonomous UAS systems from the ground up since 2008. He 

has estimated over 2,000 hours of flight time operating small and large automated UAS, from fixed wing to 

multirotor aircraft. Mr. Hill has been operating remote aircraft for more than 25 years. Mr. Hill is currently the 

owner of DebonAir UAS, which specializes in making small and large custom UAS. He is highly knowledgeable in 

the technology behind most UAS on the market, particularly the open source APM project, and DJI products. Mr. 

Hill has been a member of the DIY Drones community at diydrones.com since 2011, where many of its long time 

members advocate the safe and responsible use of UAS. He has helped countless individuals in understanding how 

unmanned systems work, as well as how to properly operate them, and do so safely. He has personally designed, 

fabricated, and built a large number of small and large fully automated UAS systems for various buyers around the 

world. 

C. UAS Operating Procedures and Intended Mission Profile.

Mois Family Tech LLC has worked with multiple sellers of real property and real estate brokerages in the 

Savannah/Richmond Hill area on a contract basis to photograph homes listed for sale along with properties and land. 

Mois Family Tech LLC intends to use the Subject UAS to conduct aerial photography for listing brokers and 

corporate clients.

- Mois Family Tech LLC intends to use its UAS for the inspection of Public Utilities, such as power line inspection 

and maintenance as well as LED lighting inspections and photographing on clear nights. 

- Mois Family Tech LLC intends to use its UAS in the area of agriculture, by providing high resolution imaging data 

via the use aerial spectroscopy. 

- Mois Family Tech LLC intends to use its UAS to assist local government departments in search and rescue efforts

day or night with FLIR and other camera systems.

- Mois Family Tech LLC intends to use its UAS for closed set filming. 

- The vast majority of the petitioner's operations will be conducted in the Savannah, GA area, however, Business is 

expected to mainly encompass the South Eastern states to include Georgia, North and South Carolina, Alabama, 

Florida, Tennessee, and Mississippi. 

Mois Family Tech LLC will adopt the following UAS Operating Procedures:

1. All missions will be conducted within class G airspace, typically exceeding 400 feet AGL as indicated by onboard 

flight data. 

2. Each mission will consist of one flight. 

3. Each flight will consist of one PIC and one observer to maintain VLOS. 

4. When operating the subject UAS Mois Family Tech LLC will insure that no persons are within 100' of the subject 

aircraft while in flight. 

5. Mois Family Tech LLC personnel will activate and use the UAS's GCS system to monitor flight data real time, to

insure the system is functioning properly and failsafes enabled. 

6. Mois Family Tech LLC personnel will insure that geofencing measures are enabled within the flight controller to 

further insure against an aircraft flyaway. 
7. If any flight were to ever occur within the airspace of a specific airport or controlled airspace, Mois Family Tech

LLC shall obtain the permission of that control tower to operate in that airspace or from the appropriate control 

authority. 

8. In the event that any mission will occur within five miles of an airport, Mois Family Tech LLC shall ensure the 

airport is notified of the prospective flight plan. 

9. Mois Family Tech LLC will conduct all flights in favorable weather, primarily during daylight hours, but also at 

night when needed or requested by utilities or government agencies. 

10. All required permissions will be obtained from relevant parties for which the UAS will be operating over. 

11. Only the operators previously mentioned will operate the subject UAS. 

Specific Sections of 14 CFR From Which Petitioner Seeks an Exemption.

Mois Family Tech LLC requests an exemption from the following FARs: 

14 CFR 21, Subpart H; Certification procedures for products and parts, Airworthiness Certificates 

14 CFR 36; Noise standards: Type and airworthiness 

14 CFR 45.23; Display of marks; general 

14 CFR 61; Certification: Pilots, flight instructors, and ground instructors 

14 CFR 91.7; Civil aircraft airworthiness

14 CFR 91.9; Civil aircraft flight manual, marking, and placard requirements 

14 CFR 91.103; Preflight action 

14 CFR 91.105; Flight crewmembers at stations 

14 CFR 91.109; Flight instruction 

14 CFR 91.119; Minimum safe altitudes 

14 CFR 91.121; Altimeter settings 

14 CFR 91.151; Fuel requirements for flights in VFR conditions 

14 CFR 91.1 73; ATC clearance and flight plan in IFR conditions 

14 CFR 91.203; Civil aircraft: Certifications required 

14 CFR 91.207; Emergency locator transmitters

14 CFR 91, Subpart E; Maintenance 
UAS Safety

Concerns for safely operating small and large UAS in the national airspace and their potential hazards are a growing 

concern. Mois Family Tech LLC is committed to doing its part to help integrate these systems into the NAS using 

the safest means at our disposal. While both small and large UAS can pose a risk to larger aircraft, or people if used 

inappropriately, they are by far much safer at performing the applications petitioned for than any of the traditional 

means. Our UAS(s) do not burn fossil fuels to fly, which emit harmful emissions. They do not pose a risk to the 

operator's life in the event of a failure, as full size passenger aircraft do. In the event that a UAS were to completely

fail and fall to the ground striking a house or car, they pose little to no threat to the occupants as passenger aircraft do. 

At a time when our nation's economy is struggling to gain its footing amidst global economic woes, it is detrimental 

that companies, businesses, and individuals be given the ability to utilize resources that only stand to reduce their 

total operating costs. Small UAS are a resource at our disposal that can do just that in many sectors in our economy

and are needed to further aid technological progress within industries. 

Conclusion

Mois Family Tech LLC appreciates all consideration given for this petition. Feel free to contact us should there be a 

need for additional information. At Mois Family Tech LLC, we understand the challenges being faced while

integrating UAS into the national airspace and we are committed to doing whatever the FAA deems necessary to

achieve this goal. Thank you for your time and we look forward to your response. 

Respectfully Submitted, 

Benjamin Mois