From: Accurate Home Inspections Inc

4423 Secret Ln

Sumerduck VA 22742

DBA Aerial Inspections Inc.

Frederick Reid President

To: U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request- Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations from 14 C.F.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a)

& (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) &

(b); 91.405 (a); 91.407(a) (1); 91.409 (a) (1) & (2); 91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012, Pub. L. No. 

112-95,126 Stat. 11 (amending 49 U.S.C.) (hereinafter, the "Reform Act") and 14 C.F.R. Part 

11,Aerial Inspections Inc, operator of small unmanned aircraft systems (singularly a"sUAS" or 

cumulatively "sUASs") equipped to conduct professional aerial photography andinspection 

services, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") 

to allow commercial operation of its sUASs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 

333 ofthe Reform Act.

This application has been formatted to be wholly similar to previously approved 

applications. As described more fully below, the requested exemption would permit the 

operation of small, unmanned sUAS under controlled conditions in airspace that (i) is limited, 

(ii) is predetermined, (iii) is controlled as to access, and (iv) would provide safety enhancements 

to the already safe operations in the aerial photography and inspection industry presently using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation's responsibilities to " ... establish requirements for the safe operation 

of such aircraft systems in the national airspace system." Reform Act§ 333 (c).

The contact info for the applicant is as follows:

Accurate Home Inspections Inc. DBA Aerial Inspections Inc

Frederick P Reid President

4423 Secret Ln 

Sumerduck, VA 22742

703-328-5710 or 800-739-9919

inspectedbyfred@gmail.com

The Applicant hereby requests exemption from the following F ARs:

14 CPR Part 21
14 C.P.R. 45.23(b)

14 CPR 61.113 (a) & (b)

14 C.P.R. 91.7 (a)

14 CPR 91.9 (b) (2)

14 C.P.R. 91.103

14 C.P.R. 91.109

14 C.F. R. 91.119

14 C.P.R. 91.121

14 CPR 91.151 (a)

14 CPR 91.203 (a) & (b)

14 CPR 91.405 (a)

14 CPR 407 (a) (1)

14 CPR 409 (a) (1) & (2)

14 CPR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress' goal in passing Section

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems ("UAS") may operate safely in the national 

airspace system ("NAS") before completion of the rulemaking required under Section 332 of the 

Reform Act. In making this determination, the Secretary of Transportation is required to determine 

which types of unmanned aircraft systems do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of (i) the UAS's size, weight, speed, and operational 

capability, (ii) operation of the UAS in close proximity to airports and populated areas, and (iii) 

operation of the UAS within visual line of sight of the operator. Id. § 333 (b) (1). Lastly, if the 

Secretary of Transportation determines that such vehicles "may operate safely in the national 

airspace system, the Secretary of Transportation shall establish requirements for the safe operation of 

such aircraft in the national airspace system." !d. § 333 (c) (underline added). 1 The Federal Aviation 

Act, 49 U.S.C. (the "Act") expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting "civil aircraft," as the term is defined under §40102 of the 

Act that includes sUASs from the requirement that all civil aircraft must have a current airworthiness 

certificate.

1 The Applicant interprets this provision to place the duty on the Administrator to not only process applications for 

exemptions under Section 333 of the Reform Act, but for the Administrator to craft conditions for the safe operation 

of the U AS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements 

for approval.

The FAA Administrator may grant an exemption from a requirement of a regulation prescribedunder 

the Act if the Administrator finds the exemption in the public interest. 49 U.S.C. § 44701 (f). See 

also 49 USC§ 44711 (a); 49 USC§ 44704; 14 CFR § 91.203 (a) (1).

HCG's sUASs are rotorcraft, weighing 55 or fewer lbs. including payload. They will operate,

under normal conditions, at a speed of no more than 50 knots. They will operate only in line of sight 

and will operate only within the airspace above property owned, leased, or otherwise

controlled by HCG or its customers with permission from said customers prior to any operation of 

sUAS as described in the Safety Checklist, attached as Exhibit A (hereinafter, the Safety Checklist")? 

Such operations will ensure that the sUASs will, "not create a hazard to users of the national airspace 

system or the public." Reform Act§ 333 (b).

Given the small size of the sUASs involved, the total flight time of the Applicant, and the

proposed diligence for safety of people involved with the operation as well as any bystanders, the 
Applicant falls squarely within that zone of safety (an equivalent level of safety) in which

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the sUASs , approval of the

application presents no national security issue. Given the clear direction in Section 333 of the

Reform Act, the authority contained in the Act, as amended; the strong equivalent level of safety 

surrounding the proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with allowing UAS for 

aerial photography and inspection operations as opposed to full scale aircraft, the grant of the 

requested exemption is in the public interest. Accordingly, the 

Applicant respectfully requests that the FAA grant the requested exemption without delay.

The Applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe aerial 

photography and inspection operations conducted with conventional aircraft.

These limitations and conditions to which AHI Inc agrees to be bound when conducting commercial 

operations under an FAA issued exemption include:

1. Each sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of the PIC.

3. Maximum total flight time for each operational flight will be determinate on battery

capacity. Current battery technology for the sUAS allows for 18 minute operations for

the standard battery and 22 minutes for the extended life battery. Should battery

technology increase operational flight times, flights will be terminated at 20% battery as such, the 

maximum flight time will continue to increase. However, in any event, all

operational flights will be terminated at 20% of capacity remaining

2 Applicant submits this Safety Checklist as a confidential document under 14 C.F.R. 11.35 (b) as the entire

safety checklist contains proprietary information that the Applicant has not and will not share with others.

The safety checklist contains operating conditions and procedures that are not available to the public and are 

protected from release under the Freedom of Information Act, 5 U.S. C. 552 et seq.

.

4. Flights will be operated at an altitude of no more than 400 feet AGL unless prior approval

from Air Traffic Control is authorized and a Notice to Airmen (NOTAM) is filed and

published.

5. Minimum crew for each operation will consist of the sUAS pilot and a visual observer.

6. The sUAS pilot will be an FAA licensed airman with at least a sport or recreational

pilot's certificate and Class III airman medical certificate.

7. The sUAS pilot will be Pilot in Command ("PIC"). If a pilot certificate holder other than

the sUAS pilot, who possesses the necessary PIC qualifications, is also present during

operations that person can also be designated as PIC.

8. The sUASs will only operate over property with permission from the relevant property holders 

and not over publicly occupied property as set forth in the Safety Checklist.
9. A briefing between the sUAS pilot and observer will be conducted in regard to the

planned sUAS operations prior to each day's operations.

10. The Applicant will file a FAA Form 7711-1, or its equivalent, as modified in light ofthe

requested exemption, with the appropriate Flight Standards District Office ("FSDO").

11. The Applicant will submit a written Plan of Activities to the FSDO three days before the

proposed operations as required in Safety Checklist.

12. The sUAS pilot and observer will have been trained in operation of sUASs generally and

received up-to-date information on the particular sUAS to be operated as required in

Safety Checklist.

13. The sUAS pilot and observer will at all times be able to communicate by voice and/or

text.

14. Written and/or oral permission from the relevant property holders will be obtained.

15. All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

16. If the sUASs lose communications or lose their GPS signal, the sUASs will have

capability to return to and land at a pre-determined and pre-programmed location.

17. The sUASs will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

I. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR§ 91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. Section 44701 (f) of the Act and Section 333 ofthe Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate 

upon consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUASs operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed herein will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUASs to be operated hereunder are less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area as set out in the Safety Checklist. Unlike other civil aircraft, operations 

under this exemption will be tightly controlled and monitored by the Applicant pursuant to the 
Safety Checklist's requirements, and under the requirements and in compliance with local public 

safety requirements, to provide security for the area of operation as is now done with 

conventional aerial photography and inspections. The FAA will have advance notice of all 

operations. These safety enhancements provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the sUAS, due to its size, speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load.

II. 14 C.F.R. § 45.23 (b). Marking of the Aircraft

This regulation requires:

"When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable." 

Even though the sUASs will have no airworthiness certificate, an exemption may be needed as 

the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the sUASs, two-inch lettering will be 

impossible. The word "Experimental" will be placed in a visible location on the sUASs. 

The equivalent level of safety will be provided by having each sUAS marked in the visible 

location where the sUAS pilot, observer and others working with the sUAS will see the 

identification of the UAS as "Experimental." The FAA has issued the following exemptions to 

this regulation in Exemptions Nos. 10700, 8738, 10167 and 10167A.

In addition, the Applicant shall also ensure its sUASs are registered with the FAA and that 

thenationality marks relating to such sUASs are marked on the sUASs in a visible manner .

III. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUASs will 

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of 

current operations by requiring the PICs operating the sUASs to have a sport or recreational pilot's 

license rather than a commercial pilot's license to operate this sUASs. Unlike a conventional aircraft 

that carries the pilot and passengers, the sUASs are remotelycontrolled with no living thing on board. 

The area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Safety Checklist. The level of safety provided by the requirements 

included in the Safety Checklist exceeds that provided by a single individual holding a commercial 

pilot's certificate operating a conventional aircraft. 

The risks associated with the operation of the sUASs are so diminished from the level of risk
associated with commercial operations contemplated by Part 61 when drafted, that allowing

operations of the sUASs as requested with a sport or recreational pilot as the PIC exceeds the

present level of safety achieved by 14 C.F .R. §61.113 (a) & (b).

IV. 14 C.F.R. §91.7(a): Civil aircraft airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft and the requirements contained in the Safety Checklist for

maintenance and use of the Safety Checklist prior to each flight, an equivalent level of safety

will be provided.

V. 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides:

"No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft

Flight Manual, approved manual material, markings, and placards, or any combination

thereof."

The sUASs, given their size and configuration have no ability or place to carry such a flight

manual on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the sUASs.

The equivalent level of safety will be maintained by keeping the flight manual at the ground

control point to which the sUASs pilots flying the sUASs will have immediate access. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 

9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

VI. 14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA -approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. An equivalent level of safety will be provided as set forth in the Safety 

Checklist. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight.

VII. 14 C.F.R. § 91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls.Flight control is accomplished through the use of a control box that communicates with the 

aircraft via radio communications. The FAA has approved exemptions for flight training without 

fully functional dual controls for a number of aircraft and for flight instruction in experimental 

aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety is provided by the fact 

that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the 
aircraft.

VIII. 14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119( d)

allows helicopters, powered parachutes and weight-shift-control aircraft to be operated at less than 

the minimums prescribed because their low speed and responsive controls allow

operations to be conducted, "without hazard to persons or property on the surface ... ".As

sUAS possess similar flight and control characteristics, and as the exemption requests authority to 

operate at altitudes up to 400 AGL, an exemption may be needed to allow such operations. As set 

forth herein, except for the limited conditions stated in the Safety Checklist, the sUASs will never 

operate at higher than 400 AGL. It will however be operated in a restricted area, where buildings and 

people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUASs as

well as the locations where they are operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner, all affected 

individuals will be aware of the planned flight operations as set forth in the Safety Checklist. 

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operating at or below 500 AGL in the aerial 

photography and inspection industry. In addition, the low-altitudeoperations of the sUASs will 

ensure separation between these sUAS operations and the operations of conventional aircraft that 

must comply with Section 91.119.

IX. 14 C.F.R. § 91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain crmsmg altitude by

reference to an altimeter that is set " ... to the elevation of the departure airport or an appropriate 

altimeter setting available before departure." As the sUASs may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be 

achieved by the operator, pursuant to the Safety Checklist, confirming the altitude of the launch site 

shown on the GPS altitude indicator before flight.

X. 14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed - (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The current battery technology powering sUASs is much more limited than that of combustion 

powered flight. As such, the Applicant's sUASs can not presently and likely may never meet the 

reserve requirement in 14 CFR § 91.151. Given the limitations on the U AS's proposed flight area 

and the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight VFR conditions is reasonable. As no night flight will occur, that portion is inapplicable.

Applicant believes that an exemption from 14 CFR § 91.151 (a) falls within the scope of prior 

exemptions. See Exemption 1 0673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the sUASs in a tightly controlled area where only 
people and property owners or official representatives who have signed waivers will be allowed, with 

less than 3 0 minutes of reserve fuel, does not engender the type of risks that Section 91.151

(a) was intended to alleviate given the size, speed and limited operating area of the sUASs.

Applicant believes that an equivalent level of safety can be achieved by limiting flights based on 

expected battery life, currently 20 minutes, or 20% of battery power when future technology expands 

the battery life. This restriction would be more than adequate to return the sUASs to their planned 

landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808.

XI. 14 C.F.R. § 91.203 (a) and (b): Carrying Civil Aircraft Certification and

Registration

The regulation provides in pertinent part:

"(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it

has within it the following:

( 1) An appropriate and current airworthiness certificate ...

(b) No person may operate a civil aircraft unless the airworthiness certificate required

by paragraph (a) of this section or a special flight authorization issued under § 91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

The sUASs fully loaded weigh no more than 55 lbs. and are operated without an onboard pilot. 

As such, there is no ability or place to carry certification and registration documents, or to 

display them on the sUASs. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the sUASs pilots flying the sUASs will have 

immediate access to them; to the extent they are applicable to the sUASs. The FAA has issued 

numerous exemptions to this regulation. A representative sample of other exemptions includes 

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

XII. 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417 (a) & (b): Maintenance

Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

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

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

... ,"and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these 

sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will 

not apply to the sUASs as proposed to be operated by the Applicant. Maintenance will be 

accomplished by the Applicant pursuant to the flight manual and operating handbook as 

referenced in the Safety Checklist. An equivalent level of safety will be achieved because these 

sUASs are very limited in size and will carry a small payload and operate only in restricted areas 

for limited periods oftime. If mechanical issues arise, the sUASs can land immediately and will 

be operating from no higher than 400 feet AGL. As provided for in the Safety Checklist, the 

Applicant will ensure that the sUAS is in working order prior to initiating flight, perform 

required

maintenance, and keep a log of any maintenance performed. Moreover, the Applicant is the 

person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy

condition to provide the equivalent level of safety.
SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. § 21, subpart H; 14 C.F.R 45.23 (b); 14 C.F.R. §§ 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 

(a) (2); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to operate commercially small unmanned aircraft 

systems (55 lbs. or less) in aerial photography and inspection operations.

Approval of exemptions allowing commercial operations of sUASs in the aerial photography and 

inspection industry will enhance safety by reducing risk. Conventional aerial photography and 

inspection operations, using jet or piston power aircraft, operate at extremely low altitudes and in 

extreme proximity to people and structures; and present the risks associated with vehicles that weigh 

in the neighborhood of 4,000 lbs., carrying large amounts of jet A or other fuel. Such aircraft must 

fly to and from the aerial photography or inspection location. In contrast, a sUASs weighing fewer 

than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and 

lack of combustible fuel carried on board. The sUASs are carried to the aerial photography or 

inspection site and not flown. The sUASs will carry no passengers or crew and, therefore, cannot and 

will not expose them to the risks associated with manned aircraft flights.

The operation of sUASs, weighing less than 55 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the Applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile 

environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters or other manned aircraft operating in close proximity to the ground and people.

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, speed,

operating capabilities, proximity to airports and populated areas and operation within visual line of 

sight and national security - provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of Applicant's sUASs in the aerial

photography and inspection industry pursuant to the Safety Checklist appended hereto.

Sincerely,

Frederick Reid

Frederick Reid