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 Sy stem (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 currentl y holds a current pilots license. Accordingl y, and pursuant to 14 CFR §§ 11.61

- .103 and Section 333 of the FAA Modernizati on and Reform Act of2012, PL112

- 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 DJ I 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 subje ct 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 DJ I Phantom 3 Professional weighs approximately 1256 grams ready to fly . The DJ I Phantom 3 Professional is a widely known unmanned aircraft, and is the same ty pe of aircraft that has recentl y 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

- to
Home 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 initiat es a return to home location in the event the battery hits critical level. The onboard s ys tem also calculates the amount of battery life it needs in order to return home and will not allow the operator to fl y too far horizontally , or verticall y. The Subj ect UAS can operate for a total of approximately 25minutes 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 aircraft s 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 b y 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 aircraft s measure 1000mm in diameter, smaller than the DJ I S1000 2. Both aircraft s weigh less than 20 pounds with their respective loads, which is less than a loaded DJIS1000 3. Both aircraft s measure no more than 24 inches tall 4. Both aircraft s utilize only one 6S 16A LiPo battery at a time, as opposed to the two that are t ypically carried b y other approved UAS s ys tems of comparable size or larger. 5. Both Aircraft s use the high precision UBlox M8N GPS receivers that track not only GPS satellites, but GL ONAS S as well for the highest level of positioning. 6. Both Aircraft s 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 t emperature, GPS location, RSSI , and sensor malfunction alarms. 7. Both aircraft s will soon be outfitted with parachute supported failsafe sy stems to provide an added measure of safet y. 8. Both sy stems 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 aircraft s feature multiple proven failsafes that will land the aircrafts , return them to their launch, or predetermined rall y 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 failsafe s . 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 aircraft s have proper red and green navigation lights, which are visible during day or n ight operat ion. 11. Both aircraft s will be utilized to carry 3

- axis b rushless gimbals for camera operation, carrying GH4 cameras only . The GH4 offers imaging capabilities not found on smaller sy stems such as the Phantom 3 Professional. 12 . Both aircraft s were b uilt by arguabl y one of the most experienced commercial UAS builders currentl y available. The quality

of these s ys tems are arguabl y higher than most of the systems that have been approved. In our experience due to their lower weight over a DJ I S1000, the ir industry proven 3D Robotics autopilots, hardware, and quality of build, they

are simply

much safer s ys tems for UAS applications than any thing comparable in their class. 13 . Please see attached images for the subject aircraft s . Mois Family Tech LLC will be more than happy to provide the FAA with an y additional information on these aircraft s if there is a question of there safet y or reliability.**B. The UAS Pilots in Command.**  Mois Family

Tech LLC employ s three highl y qualified pilots who hav e 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**

**- Home**  **** 45 Downie Ct. Richmond Hill, GA 31324

**- Office**  **** 636 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 ove r 7 00 hours of flight time experience operating small and large UAS aircraft. Mr. Mois is well verse d in the safe operation of these UAS aircraft s and with the subject overall

. **Kevan Stone** is a well

- seasoned UAS operator. Mr. Stone has extensive experien ce operating small and large UAS for Northrop Grumman. Mr. Stone also holds a valid pilots license. Mr. Stone's credentials are as follows: · Pilot L icense

- Kevan Michael Stone

- Certificate #3149975

- Date of Issue, 8 JUN 2006 · 1,200 ho urs as a UAS Fixed

- Wing Internal & External Flight Instructor

- Hunter UAS MQ

- 5B, Hermes 450 UAS. · UAV S ys tems Specialist

- Shadow 200 · 1,400 hours as a UAS Payload (EO/IR) Operator · 5 Combat Tours (4+ years in theatre) serving in Iraq & Afghanistan · 8 00+ 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 Mis sion Commander & Aviation Safety Pilot **Todd Hill** has been developing small and large fully autonomous UAS sy stems 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 currentl y the owner of DebonAir UAS, which specializes in making small and large custom UAS. He is highl y knowledgeable in the technology

behind most UAS on the market, particularl y the open source APM project, and DJ I products. Mr. Hill has been a member of the DIY Drones community at di ydrones.com since 2011, where man y of its long time members advocate the safe and re sponsible use of UAS. He has helped countless individuals in understanding how unmanned s ys tems work, as well as how to properly operate them, and do so safel y. He has personally designed, fabricated, and built a large number of small and large full y aut omated UAS sy stems 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 photograph y 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 re scue efforts day or night with FLIR and other camera s ys tems
.

- 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, h owever, 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, t ypically 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 PI C and one observer to maintain VLOS. 4. When operating the subject UAS M ois 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 sy stem to monitor flight data real time, to insure the s ys tem is functioning pr operly 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 fl yaway.7. If an y 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 an y m ission will occur wi thin 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 flight s 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 Se ctions 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 : Ty pe 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 setti ngs 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, Subp art E; Maintenance**UAS Safety** Concerns for safel y operating small and large UAS in the national airspace and their potential hazards are a growing concern. Mois Family

Tech LLC i s committed to doing its part to help integrate these s ys tems into the NA S using the safest means at our disposal. While both small and large UAS can pose a risk to larger aircraft, or people if used inappropriatel y , 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 completel y 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 econom y is struggling to gain its footing amidst global economic woes, it is detrimental that compan ies, businesses, and individuals be given the ability to utilize resources that onl y 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 econom y and are needed to further aid t echnological 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 cha llenges being faced while integrating UA S into the national airspace and w e 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 M ois