United States Department of Transportation Docket Management System i200 New JerseyAve., SE West Building Ground Floor Room Wi2-i40 Washington, DC 20590

Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act of 2012

Aloha Siror Madam:

We are writing pursuantto the FAA Modernization and Reform Act of 20i2 (the "Reform Act") and the procedures contained in i4 CFR i i,to request that UAS Maui, an owner and operatorof small unmanned aircraft, be exempted from the Federal Aviation Regulations listed below
so that UAS Maui mayoperate its small unmanned aircraft/lightweight unmanned aircraft systems commercially in airspace regulated bythe FAA; as long as such operations are conducted within and underthe conditions outlined heron or as may be established bythe FAA as required by Section 333.

As identified and described herein, Mr. William KaunoaAh Chan is the
owner of UAS Maui, Mr. Ah Chan has been a lifelong resident ofthe State of Hawaii and since childhood has been flying with his father over all of the major Hawaiian Islands primarilyfish 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 athorough understanding of the airspace system and is fully aware ofthe wind and weather associated with operating UAV'swithin the State of Hawaii.

UAS Maui's hasthe experience, skill set and knowledge to safelyoperate UAV's and would liketo providethe following Commercial services: Ground and Flight Instruction, Aerial PhotographyNideo and aerial survey and site mapping. We are avery compliant companyand find it necessaryto request aCertificate of Waiver orAuthorization to meetthe legal requirements ofthe 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 Dairspace at or below 400AGL.

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

UAS Maui submits this application in accordancewith the Reform Act, 112 P.L. 95 

### §§331-334, seeking relieffrom 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 interestto do so. UAS Maui's lightweight UAV/UAS meetthe definition of "small unmanned aircraft" as defined in Section 331 and thereforethe integration of UAS Maui's lightweight UAV/UAS are expressly contemplated bythe Reform Act. UAS Maui would liketo operate its lightweight UAV/UAS priorto the time period by which the Reform act requires the FAA to promulgate rules governing such craft.

The Reform Act guidesthe Secretary in determiningthe types of UASs that may operate safely in our national airspace system. Considerations include: The weight, size, speed and overall capabilities ofthe UAS; Whetherthe 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 utilizesfour 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 ofvertical and horizontal operations but operate onlywithin the line of sightofthe remote control pilot. In addition to the remote control pilot, UAS Maui uses avisual observe/technician,
so at a minimum two UAS Maui personnel govern the safe flight ofthe 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. Safetysystems in place include aGPS mode that allows UAS Maui's aircraftto hover in place if communication with the radio control pilot is lost and then slowlydescend when the battery life getsto 25°/o. Further, UAS Maui's aircraft software will not allow operations within 5 miles of airports orwithin restricted
areas.

UAS Maui intendsto operate in sparsely populated areas without hazard to persons or property on the surface. In the event non-participating public enters our operational areawe will cease operations until all nonparticipating public is cleared ofthe area.

Reasons why UAS Maui's exemption will not adversely affect safetyor how the exemption will provide a level of safetyat least equal to the existing rule. By granting the exemption and permitting UAS Maui to operate we can log more flighttime in FAA controlled airspace which will allow us to innovate and implement new and as of yet undiscovered safety protocols. In addition, UAS Maui submitsthe following representations:

UAS Maui UASs weigh lessthan 55 pounds UAS Maui onlyoperates at or below 400feet UAS Maui will onlyoperate for 5-25 minutes perflight UAS Maui lands its UASs when they reach 30°/o battery life UAS Maui will only operate while maintaining line of sightto UASs UAS Maui will operate with a remote control pilot and a spotter/technician UAS Maui UASs have aGPS flight modes wherebythey 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 awayfrom airports and populated areas UAS Maui conducts extensive briefings priorto flight, during which safety carries primary importance UAS Maui will log all flights UAS Maui always obtains all necessary permissions and permits priortooperation and will abort/suspend operations should asafety breach or potential danger develops

Thefollowing are the regulations that UAS Maui are requesting an exemption:

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

14 CFR 21, Subpart H, entitled Airworthiness Certificates, setsforth requirements for procurementof 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 pursuantto Section 333 of the Reform Act. The FAA is authorized to exempt aircraftfrom the airworthiness certificate requirement under both the Act (49 USC 44701 (f)) and Section 333 ofthe Reform Act. Both pieces of legislation permitthe FAAto exempt UASsfrom the airworthiness certificate requirement in consideration ofthe weight, size, speed, maneuverability and proximityto areas such as airports and dense populations. UAS Maui UASs meet or exceed each ofthe elements.

14 CFR 91.7 Prohibitsthe Operation of an aircraftwithout an airworthiness certificate. As no such certificate will be applicable in the form contemplated bythe FARs, this regulation is inapplicable.

14 CFR 91.9 (b)(2) requires an aircraftflight 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 safetywill be achieved by maintaining a manual atthe home base and having the manual in the pilots possession when operating. The FAA has previously issued exemptionsto this regulation in Exemption#8607, 8737, 8738,9299, 9299A, 9565, 95658, 10167A, 10602, 10700 and 32827.

14 CFR 91.121 regarding altimeter settings is inapplicable insofar as UAS Maui UASswill utilize electronic global positioning systems and internal gyroscopesto provide spatial coordination.

### i 4 CFR 

### 9i.iSi(a) & (b) Fuel requirementsfor flight in VFR conditions, not applicable dueto thefactthat we will not be using fuel and only using battery powerdown to 

### 30°/o.

i 4 CFR 

### 9i.203 (a) and (b) providesforthe carrying of civil aircraft certifications and registrations. They are inapplicableforthe same
reasons described above. The equivalent level of safetywill be achieved by maintaining such certifications and registrations at UAS Maui home base.

B. 

### i 4 CFR 

### 45.23 Marking ofthe aircraft
Applicable codes of Federal Regulation require aircraftto be marked according to certain specifications. UAS Maui UASsare, bydefinition, unmanned. Theytherefore do not have a cabin, cockpit or pilot station on which to mark certain words or phrases

.. Further, two-inch lettering is difficultto 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 othersworking with the UAVwill seethe markings. The FAA has previously issued exemptionsto this regulation through Exemptions#

### 8738,iOi67,10167A and 

### 10700.

C. 

### 14CFR 

### 61.113 Private Pilot Privileges and Limitations, PIC

Pursuantto 

### i 4 CFR 

### 61.113 (a) & (b), private pilots are limited to noncommercial operations. UAS Maui can achieve an equivalent level of safetyas achieved bycurrent 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 pilotvetting and training programs will. Further, private pilot licensees will operate UAS Maui UASs with the same skill. Further, the risks attendantto the operation of UAS Maui UASs is far lessthan the risk levels inherent in the commercial activities outlined in 

### 14CFR 

### 61, et seq. Thus, allowing UAS Maui to operate its UASswith a private asthe pilot in control will exceed current safety levels in relation to 

### 14CFR 

### 61.113 (a) & (b).

D. 

### 14CFR 

### 91.119 Minimum safe altitudes14 CFR 91.119 prescribes safe altitudes forthe operation of civil aircraft. It allows helicoptersto be operated at loweraltitudes in certain conditions. UAS Maui UASs will neveroperate at an altitude greaterthan 400 AGL. UAS Maui will, however, operate its UASs in sparsely populated areas and never endangerthe person or propertyof 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 equivalentto those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of UAS Maui UASs
,an equivalent level of safetywill 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 otherthings, aircraft
owners and operatorsto "have (the) aircraft inspected as prescribed in subpart Eof this part and shall between required inspections, except as provided in paragraph©ofthis section, have discrepancies repaired as prescribed in part 43 of this chapter."

These regulations only applyto aircraftwith an airworthiness certificate. Theywill not, therefore, applyto 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 safetywill be achieved.

F. Summary

UAS Maui seeks an exemption from the following Regulations: 14CFR 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 91.109(a), 14 CFR 91.119, 14CFR 91.121, 14 CFR 91.151(a)&(b), 14 CFR 91.203(a)&(b), 14CFR 91.205(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14CFR 91.409(a) (1)&(2), 14 CFR 91.417(a)&(b) to commerciallyoperate its fleet of small unmannedvehicles and lightweight unmanned aircraft systemsforflight instruction, aerial photography/video, aerial survey and site mapping. Wewould liketo also conduct our own research and to develop economic platforms for law enforcement, search 

### &rescue, and disaster relief operations.
Granting UAS Maui requestfor exemption will reduce current risk levels and thereby enhance safety. Currently, the uses outlined above relies primarilyon the use of larger aircraft running on combustible fuels. UAS Maui craft do not contain potentially explosivefuels, are smaller, lighter and more maneuverablethan conventional manned aircraft. Further, UAS Maui provides a level of safety at least equal to existing rules and in nearlyevery instance, greaterthan existing rules. It is far saferto 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