United States Department of Transportation 

Docket Management System 

i 200 New Jersey Ave., SE 

West Building Ground Floor Room Wi 2-i 40 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform 

Act of 2012 

Aloha Sir or Madam: 

We are writing pursuant to the FAA Modernization and Reform Act of 

20i 2 (the "Reform Act") and the procedures contained in i 4 CFR i i, to 

request that UAS Maui, an owner and operator of small unmanned 

aircraft, be exempted from the Federal Aviation Regulations listed below 

so that UAS Maui may operate its small unmanned aircraft/lightweight 

unmanned aircraft systems commercially in airspace regulated by the 

FAA; as long as such operations are conducted within and under the 

conditions outlined heron or as may be established by the FAA as 

required by Section 333. 

As identified and described herein, Mr. William Kaunoa Ah Chan is the 

owner of UAS Maui, Mr. Ah Chan has been a lifelong resident of the 

State of Hawaii and since childhood has been flying with his father over all 

of the major Hawaiian Islands primarily fish spotting. He has accumulated 

over 5,000 flight hours in single engine airplanes and has operated model 

aircraft his entire life. Being a native Hawaiian he recognizes the value of 

unobtrusive lightweight unmanned aerial systems. He has a thorough 

understanding of the airspace system and is fully aware of the wind and 

weather associated with operating UAV's within the State of Hawaii. 

UAS Maui's has the experience, skill set and knowledge to safely operate 

UAV's and would like to provide the following Commercial 

services: Ground and Flight Instruction, Aerial PhotographyNideo and 

aerial survey and site mapping. We are a very compliant company and 

find it necessary to request a Certificate of Waiver or Authorization to 

meet the legal requirements of the FAR's. 
UAS Maui exemption request would permit its operation of lightweight, 

unmanned (remotely controlled in line of sight) aerial systems outside of 

B, C and D airspace at or below 400AGL. 

The Extent of Relief UAS Maui Seeks and the Reason it seeks such relief: 

UAS Maui submits this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs 

operating to prevent UAS Maui contemplated commercial operations 

within the national airspace system. The Reform Act in Section 332 

provides for such integration of civil unmanned aircraft systems into our 

national airspace system as it is in the public's interest to do so. UAS 

Maui's lightweight UAV/UAS meet the definition of "small unmanned 

aircraft" as defined in Section 331 and therefore the integration of UAS 

Maui's lightweight UAV/UAS are expressly contemplated by the Reform 

Act. UAS Maui would like to operate its lightweight UAV/UAS prior to the 

time period by which the Reform act requires the FAA to promulgate rules 

governing such craft. 

The Reform Act guides the Secretary in determining the types of UASs 

that may operate safely in our national airspace system. Considerations 

include: 

The weight, size, speed and overall capabilities of the UAS; Whether the 

UAS will be operated by line of sight. 

112 P .L. 95 § 333 (a). Each of these items militates in favor of an 

exemption for UAS Maui. 

UAS Maui utilizes four counter-rotating propellers for extreme balance, 

control and stability. They each weigh less than 55 pounds, including 

payload. Each of UAS Maui's small unmanned aircraft are designed to 

primarily hover in place and operate at less than 50 knots maximum 

speed. They are capable of vertical and horizontal operations but 

operate only within the line of sight of the remote control pilot. In addition 

to the remote control pilot, UAS Maui uses a visual observe/technician, 

so at a minimum two UAS Maui personnel govern the safe flight of the 

aircraft at all times. 
Utilizing battery power and not combustible fuels, flights generally last 

between five and twenty minutes. UAS Maui does not operate its aircraft 

with less than 30°/o battery power capacity. Safety systems in place 

include a GPS mode that allows UAS Maui's aircraft to hover in place if 

communication with the radio control pilot is lost and then slowly descend 

when the battery life gets to 25°/o. Further, UAS Maui's aircraft software 

will not allow operations within 5 miles of airports or within restricted 

areas. 

UAS Maui intends to operate in sparsely populated areas without hazard 

to persons or property on the surface. In the event non-participating 

public enters our operational area we will cease operations until all nonparticipating public is cleared of the area. 

Reasons why UAS Maui's exemption will not adversely affect safety or 

how the exemption will provide a level of safety at least equal to the 

existing rule. By granting the exemption and permitting UAS Maui to 

operate we can log more flight time in FAA controlled airspace which will 

allow us to innovate and implement new and as of yet undiscovered 

safety protocols. In addition, UAS Maui submits the following 

representations: 

UAS Maui UASs weigh less than 55 pounds 

UAS Maui only operates at or below 400 feet 

UAS Maui will only operate for 5-25 minutes per flight 

UAS Maui lands its UASs when they reach 30°/o battery life 

UAS Maui will only operate while maintaining line of sight to UASs 

UAS Maui will operate with a remote control pilot and a spotter/technician 

UAS Maui UASs have a GPS flight modes whereby they hover and then 

slowly land if communication with the remote control pilot is lost or battery 

life is below 25°/o 

UAS Maui will only operate in secured areas that are strictly controlled, 

are away from airports and populated areas 

UAS Maui conducts extensive briefings prior to flight, during which safety 

carries primary importance 

UAS Maui will log all flights 

UAS Maui always obtains all necessary permissions and permits prior to 
operation and will abort/suspend operations should a safety breach or 

potential danger develops 

The following are the regulations that UAS Maui are requesting an 

exemption: 

A. 14 CFR 21 and 14 CFR 91 Airworthiness Certificates, Manuals and 

the like. 

14 CFR 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in 

relation to FAR 91.203 (a) (1 ). The size, weight and enclosed operational 

area of UAS Maui UASs permits exemption from Part 21 because UAS 

Maui UASs meet an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 USC 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation 

permit the FAA to exempt UASs from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability 

and proximity to areas such as airports and dense populations. UAS 

Maui UASs meet or exceed each of the elements. 

14 CFR 91.7 Prohibits the Operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by the FARs, this regulation is inapplicable. 

14 CFR 91.9 (b)(2) requires an aircraft flight manual in the aircraft. As 

there are no pilots or passengers, and given the size on the UASs, this 

Regulation is inapplicable. An equivalent level of safety will be achieved 

by maintaining a manual at the home base and having the manual in the 

pilots possession when operating. The FAA has previously issued 

exemptions to this regulation in Exemption# 8607, 8737, 8738,9299, 

9299A, 9565, 95658, 1 0167A, 10602, 10700 and 32827. 

14 CFR 91.121 regarding altimeter settings is inapplicable insofar as UAS 

Maui UASs will utilize electronic global positioning systems and internal 

gyroscopes to provide spatial coordination. 
i 4 CFR 9i. i Si (a) & (b) Fuel requirements for flight in VFR conditions, not 

applicable due to the fact that we will not be using fuel and only using 

battery power down to 30°/o. 

i 4 CFR 9i .203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same 

reasons described above. The equivalent level of safety will be achieved 

by maintaining such certifications and registrations at UAS Maui home 

base. 

B. i 4 CFR 45.23 Marking of the aircraft 

Applicable codes of Federal Regulation require aircraft to be marked 

according to certain specifications. UAS Maui UASs are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases .. Further, two-inch lettering is 

difficult to place on such small aircraft. Regardless, UAS Maui will mark 

its UASs in the largest possible lettering by placing the word 

"EXPERIMENTAL" on its fuselage as required by i 4 CFR 45.29 (f) so that 

the pilot, spotter/technician and others working with the UAV will see the 

markings. The FAA has previously issued exemptions to this regulation 

through Exemptions# 8738, i Oi 67,10167 A and 10700. 

C. 14 CFR 61.113 Private Pilot Privileges and Limitations, PIC 

Pursuant to i 4 CFR 61.113 (a) & (b), private pilots are limited to noncommercial operations. UAS Maui can achieve an equivalent level of 

safety as achieved by current regulations because UAS Maui UASs do not 

carry any pilots or passengers. Further, while helpful, a pilot license will 

not ensure remote control piloting skills, though UAS Maui pilot vetting 

and training programs will. Further, private pilot licensees will operate 

UAS Maui UASs with the same skill. Further, the risks attendant to the 

operation of UAS Maui UASs is far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR 61, et seq. Thus, allowing UAS 

Maui to operate its UASs with a private as the pilot in control will exceed 

current safety levels in relation to 14 CFR 61.113 (a) & (b). 

D. 14 CFR 91.119 Minimum safe altitudes 
14 CFR 91.119 prescribes safe altitudes for the operation of civil aircraft. 

It allows helicopters to be operated at lower altitudes in certain conditions. 

UAS Maui UASs will never operate at an altitude greater than 400 AGL. 

UAS Maui will, however, operate its UASs in sparsely populated areas 

and never endanger the person or property of another, we will also cease 

operations if non-participating public enters our operational area, this will 

enable us to provide a level of safety at least equivalent to those in 

relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of UAS Maui UASs , an equivalent level of 

safety will be achieved. 

E. 14 CFR 91.405(a); 407(a)(1); 409(a)(1 )&(2); 417(a)&(b): 

Maintenance Inspections 

The above-cited regulations require, amongst other things, aircraft 

owners and operators to "have (the) aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as 

provided in paragraph© of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter." 

These regulations only apply to aircraft with an airworthiness certificate. 

They will not, therefore, apply to UAS Maui should its requested 

exemption be granted. UAS Maui conducts an extensive maintenance 

program that involves regular software updates and constant inspection 

for assessment of any damaged hardware. Therefore, an equivalent 

level of safety will be achieved. 

F. Summary 

UAS Maui seeks an exemption from the following Regulations: 14 CFR 

21, subpart H, 14 CFR 45.23(b), 14 CFR 61.113 (a) & (b), 14 CFR 

91.7(a), 14 CFR 91.9(b)(2), 14 CFR 91.1 09(a), 14 CFR 91.119, 14 CFR 

91.121, 14 CFR 91.151 (a)&(b), 14 CFR 91.203(a)&(b), 14 CFR 

91.205(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1 ), 14 CFR 91.409(a) 

(1 )&(2), 14 CFR 91.417(a)&(b) to commercially operate its fleet of small 

unmanned vehicles and lightweight unmanned aircraft systems for flight 

instruction, aerial photography/video, aerial survey and site mapping. We 
would like to also conduct our own research and to develop economic 

platforms for law enforcement, search & rescue, and disaster relief 

operations. 

Granting UAS Maui request for exemption will reduce current risk levels 

and thereby enhance safety. Currently, the uses outlined above relies 

primarily on the use of larger aircraft running on combustible fuels. UAS 

Maui craft do not contain potentially explosive fuels, are smaller, lighter 

and more maneuverable than conventional manned aircraft. Further, 

UAS Maui provides a level of safety at least equal to existing rules and in 

nearly every instance, greater than existing rules. It is far safer to operate 

a battery powered lightweight UAS than a manned helicopter. The 

potential loss of life is diminished because UASs carry no people, we only 

operate in sparsely populated areas and the extreme maneuverability 

allow our remote control pilots to avoid hazards. UAS Maui have 

operated and will continue to operate at and above current safety 

standards. 

UAS Maui respectfully requests that the FAA grant its exemption request 

without delay. 

Sincerely, 

William Kaunoa AhChan