October 1, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

ELECTRONIC SUBMISSION

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (herein referred to as Reform

Act) and 14 CFR Part 11, Ott Home Inspections hereby applies for an exemption from the listed Federal 

Aviation Regulations (FARs) to allow commercial operation of sUAS for inspection, surveying, data 

collection, photography, and cinematography, 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.

Ott Home Inspections is an inspection company that provides inspection, surveying, data collection, 

photography, and cinematography services in the United States. The company leverages the capacities 

of mapping software, GPS systems, and surveying equipment to provide these services to industries and 

individuals that rely on them for regulatory compliance, public safety, and asset management. Being 

positioned in this highly competitive industry requires a significant investment in the aforementioned 

software and hardware products, but to also be aware of forthcoming technological developments. The 

sUAS is among a group of several technological developments that Ott Home Inspections considers to be 

a tool that will have a positive impact on the way we perform data collection, photogrammetry, and 

visual documentation methodologies, all of which are services we provide for our customers.

As detailed in this document, the requested exemption would permit the operation of sUAS under

controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access and 4)

would provide safety enhancements to the already best practices safety protocols followed by Ott Home 

Inspections. 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.” Section 333(c) Reform Act.
The name and address of the applicant is:

Ott Home Inspections dba Casey Ott Home Inspections, LLC

Casey Ott

1912 Covey Trace

LaGrange, KY 40031

502-298-5411

caseyotthomeinspections@gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21

14 CFR 45.23(b)

14 CFR 61.113(a) & (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.111(a)

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a) & (b)

14 CFR 91.405(a)

14 CFR 407(a)(1)

14 CFR 409(a)(2)

14 CFR 417(a) & (b)
AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority

includes exempting civil aircraft, as the term is defined under §40101 of the Act, including sUASs, from

the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under

subsection (a) or (b) of this section or any sections §44702-44716 of this title if the Administrator finds

the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14

CFR 91.203(a)(1).

Section 333(b) of the Reform Act assist the Secretary in determining whether sUASs may operate in the

national airspace system without creating a hazard to the user, the public, or a threat to national

security. In making this determination, the Secretary must consider:

 The sUAS’ size, weight, speed and operational capability;

 Whether the sUAS operates within the visual line of sight of the operator;

 Whether the sUAS operates outside of highly populated areas and away from close proximity to

airports.

Reform Act 333(a). If the Secretary determines that a sUAS “may operate safely in the national airspace

system, the Secretary shall establish requirements for the safe operation of such aircraft in the national

airspace system.” Id. 333(c).

Ott Home Inspections’ sUAS Specifications

Ott Home Inspections’ sUAS consist of the following characteristics that illustrate its minimal impact to

human beings, manned aircraft, and infrastructure:

1. DJI Phantom:

 Weight: 1280 g

 Diagonal Size: 590 mm

 Max Speed: 16m/s

 Max altitude: 6000 m above sea level

 Max distance:2000 m
The sUAS will operate only in the pilot’s or visual observer’s visual line of sight at all times. Such

operations will insure that the sUAS will “not create a hazard to users of the national airspace system or

the public.” Reform Act Section 333(b).

Given the small size of the sUAS involved and the restricted environment within which they will operate,

our application falls squarely within the zone of safety (an equivalent level of safety) in which Congress

envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commence

immediately. Also due to the small size of the UAS and the low altitudes in which our sUAS will operate,

approval of the application presents no national security issue.

The sUAS can be operated entirely by a touch-screen, map-based interface. This means the operator

only needs to command the system where to go, and the system does all the flying for the operator. The

sUAS can be operated in both semi and fully autonomous flight modes, with the operator simply clicking

on a map to create a pre-planned flight path for a flight. In addition, the operator can create no fly zones

or maximum flight ranges and altitudes so the system cannot enter areas deemed unsafe or

unnecessary to fly over.

The sUAS has built-in intelligent fault handling which allows it to detect a system fault while in the air

and automatically fly back to its take-off location and land. Faults that can be detected include: loss of

communication and low battery levels. All flight operations are global positioning system (GPS) 

controlled, making the system easy to navigate. At any point if the operator is not explicitly commanding 

the system to move, the system automatically holds its GPS position. The flight control system employs 

not only GPS positioning but a variety of sensors including sonar, barometric pressure, temperature, 

wind speed and others to ensure stability so long as wind thresholds are not exceeded. Also a flight 

termination link – to prevent a “fly away” or other potentially dangerous situation – is available to the 

operator.

DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR Part 21, Subpart H: Airworthiness certificates

Subpart H, 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 Ott Home Inspections, 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. The Federal Aviation Act 

(49 USC §44701(f)) and Section 333 of the 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 sUAS operated without an airworthiness certificate, 

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

conventional aircraft operating with an airworthiness certificate without the restrictions and conditions

proposed.

14 CFR 45.23(b): Marking of the aircraft

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport category

aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted,” 

“lightsport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station.

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

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be

placed. Given the size of the sUAS, 2 inch lettering will be impossible. Ott Home Inspections will mark 

the sUAS with the organization’s name and address. 

14 CFR 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

Sections 61.113(a) and (b) limit private pilots to non-commercial operations. Because the sUAS will not

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current

operations by requiring the pilot operating the aircraft to have completed a UAS flight training course of

100 hours before flying a sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the

sUAS is remotely controlled with no living thing or cargo on board. The area of operation is controlled

and restricted, and all flights are planned and coordinated in advance. The risks associated with the

operation of the small UAS are so diminished from the level of risk associated with commercial

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested

exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b).

14 CFR 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 for maintenance and use of safety checklists prior to each flight an equivalent level of

safety will be provided.

14 CFR 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements

The sUAS, given its size and configuration has 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 aircraft. The equivalent level of safety will be maintained by keeping the User 

Manual at the ground control point where the pilot flying the sUAS will have immediate access to it.

14 CFR 91.103: Preflight action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of

flight. An exemption is needed from this requirement as the pilot will take separate preflight actions,

including checking for weather conditions, checking flight battery requirements, checking takeoff and

landing distances, and all other actions in the safety checklists. These actions will provide an equivalent

level of safety.

14 CFR 91.109: Flight instruction

Section 91.103 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. By design, 

sUASs and remotely piloted aircraft 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 equivalent level of safety is provided by the fact that neither a pilot nor

passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the

controller and by the size and speed of the aircraft.

14 CFR 91.111(a): Operating near another aircraft

Section 91.111(a) establishes that no person may operate an aircraft so close to another aircraft as to

create a collision hazard. Occasionally, sUAS engage in simultaneous flight routines that employ more

than one (1) sUAS in a tightly controlled, patterned flight plan based on onboard GPS positioning

navigation systems. This method of data collection employs interferometric capture sequences,

requiring more than one measurement sensor during the flight routine.

14 CFR 91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating the

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is

for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and vertical landing, which

will typically operate at altitudes of 200 feet above ground level (AGL), so an exemption may be needed

to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and all operations

will occur during daylight hours under Visual Meteorological Conditions (VMC) only.

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS as well as

the location where it is operated. No flight will be taken without the permission of the property owner

or local officials. Because advance notice to the property owner and any onsite personnel, as well as the

precautions outlined below, all affected individuals will be aware of the planned flight operations.

Flight operations will be conducted away from all non-participating persons (persons other than the 

pilot in command (PIC) or visual observer (VO)), vessels, vehicles and structures, unless: Barriers or 

structures are present that sufficiently protect non-participating persons from debris in the event of an 

accident. The PIC will ensure that non-participating persons remain under such protection. If a situation 

arises where non-participating persons leave such protection and are within affected range sUAS, flight 

operations will cease immediately and/or; The aircraft is operated near vessels, vehicles or structures 

where the land owner/controller has granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and; Operations near the PIC or VO do not present an undue 

hazard to the PIC or VO, per 14 CFR 91.119(a).

The sUAS will remain within visual line of sight of the PIC or VO. Flight operations will be conducted at

least 5 miles from an airport and away from any densely populated area. The PIC or VO will provide 

notification to the local Flight Standards District Office and airport controller of all operations within 5 

miles of an airport. The FAA will have advance notice of all operations through the filing of notices-toairmen.

Compared to flight operations with aircraft or rotorcraft weighing far more than the sUAS proposed

herein and carrying flammable fuel, any risk associated with our operations is far less than those

presently presented with helicopters and other conventional aircraft operating at or below 500 feet

AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these UAS

operations and the operations of conventional aircraft that must comply with Section 91.119.
14 CFR 91.121: Altimeter Settings

This regulation requires each person operating the aircraft to maintain cruising 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 sUAS 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 PIC

confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151(a): Fuel requirements for flight in VFR conditions

Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Our sUAS is limited

to operations in controlled environments and has a limited flight time which require an exemption from

14 CFR 91.151(a).

The battery powering the sUAS provides approximately 25 minutes of powered flight. This would render

the sUAS unable to meet the 30 minute reserve requirement in 14 CFR 91.151. Given the limitations on

the sUAS’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.

An equivalent level of safety can be achieved by limiting flights to 20 minutes, or enough battery reserve

to ensure that the sUAS lands at the ground station with at least 20% of battery power (as determined

by the onboard monitoring system and the PIC), whichever happens first. This restriction would be more

than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating

area.

14 CFR 91.203(a) & (b): Carrying civil aircraft certification and registration

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore,

there is no ability or place to carry certification and registration documents or to display them on the

sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to

the sUAS.

14 CFR 91.405(a); 407(a)(1); 409(a)(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 Ott Home Inspections. Maintenance will be accomplished by the operator

pursuant to the manufacturer’s recommendations. 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 of time. If mechanical issues arise, the sUAS can land immediately and will be

operating from no higher than 400 feet AGL. The operator 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 operator 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.

PUBLIC INTEREST

Approval of exemptions allowing commercial operations of sUASs for inspection, surveying, data 

collection, photography, and cinematography enhances safety while reducing risk. Manned aircraft 

monitoring and surveying creates a greater risk because the craft are much larger, have combustible 

fuel, and carry an onboard human pilot. In contrast, a sUAS weighing less than 5 pounds and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried 

on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights.

Conducting aerial surveys with the sUAS, instead of manned aircraft, will greatly benefit the public by

drastically reducing the levels of air and noise pollution generated during traditional aerial survey flight

operations. By using battery power and electric motors, the sUAS produces no air pollution and is a

viable, environmentally conscious alternative to the cabin class, six cylinder internal combustion twin

engine aircraft that are typically utilized for aerial surveys, while burning approximately 20-30 gallons

per hour of leaded aviation fuel. The sUAS, while reducing the carbon footprint of aerial surveys, also

reduces noise pollution as it is propelled by battery powered electric motors rather than an internal

combustion engine.

EQUIVALENT LEVEL OF SAFETY
Ott Home Inspections proposes that the exemption requested herein apply to civil aircraft that have the

characteristics and that operate within 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 protocols

followed by aerial survey operations conducted with helicopters and other conventional aircraft. Ott 

Home Inspections will be bound by the following limitations when conducting its sUAS operations under 

an FAA issued exemption:

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 20 minutes. Flights will be terminated at 

20% battery power reserve should that occur prior to the 20 minute limit.

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

5. Flight operations will be conducted 5 miles from an airport and away from any densely populated 

area, which are depicted in yellow on VFR sectional charts.

6. Flight operations within 5 miles of an airport require notification and approval from the local

Flight Standards District Office and airport controller.

7. Flight operations will occur during daylight hours and under visual meteorological conditions only.

8. The FAA will have advance notice of all operations through the filing of notices-to-airmen.

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

10. The pilot and visual observer will have been trained in the operation of the sUAS.

11. The pilot and visual observer will at all times be able to communicate by voice and/or text.

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

13. Flight operations will be conducted away from all non-participating persons, vessels, vehicles and 

structures unless:

a. Barriers or structures are present that sufficiently protect non-participating persons from debris in the 

event of an accident. The pilot will ensure that non-participating persons remain under such protection. 
If a situation arises where non-participating persons leave such protection and are near the area of the 

sUAS, flight operations will cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has 

granted permission and the PIC has made a safety assessment of the risk of operating closer to those 

objects and;

c. Operations near the pilot or visual observer do not present an undue hazard to the pilot or visual 

observer.

14. If the sUAS loses communication or loses its GPS signal, the sUAS will have the capability to return to 

a safe, pre-determined location and land.

15. The sUAS will have the capability to abort flight in case of unpredicted obstacles or emergencies.

PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent

and knowledge. Images taken will be of individuals who have also consented to being filmed or

otherwise have agreed to be in the area where aerial photography will take place.

FEDERAL REGISTER SUMMARY

Mr. Casey Ott, Ott Home inspections, 1912 Covey Trace LaGrange, KY 40031, petitioned the FAA on 

behalf of Ott Home Inspections for an exemption from part 21 and §§ 45.23(b), 61.113(a) and (b), 

91.7(a), 91.9(b)(2), 91.103, 91.109, 91.111(a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

407(a)(1), 409(a)(2), 417(a) and (b) of Title 14, Code of the Federal Regulations (14 CFR). The exemption 

would allow commercial operation of small Unmanned Aircraft Systems (sUASs) for inspection, 

surveying, data collection, photography, and cinematography. *******

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – 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 Ott Home Inspections’ sUAS for inspection, surveying, 

data collection, photography, and cinematography. 

Sincerely,

Casey Ott

Ott Home Inspections