Jan 12 Centrat Home 9895448007 ,,:::;t· , ..,.~f['' 

~~· .. :· 

page 2 

·,.~_;11d:rtffk4~!~ru_~J2tP~I1111'11J.Qf.Ir.i!h~P.ortation Exemptlon.·Reqoest Pursuant to Section 333 of 

the FAA ,. «. • .. ·~ .~~ - :: ' \. '.,, «• 

·"'.'"t~1.:wi,f;t~'':':,.~ c~~~m, Act lf~fl fait .11 of ijj~'i=edetS.iAvlfrtion "·. · .. "./'·:,.)... ;::: :: .. ,;. ;·. { \ : .:~ <. , .... · '7,.0·:" "··. . >" ·~·;,!'";:. ' ' -j. 

Jan_uary 10, 2016 

Michael Raines 

Central Home Inspections 

9780 Green Rd 

Farwell, Ml 48622 

.t.n•P~(;~~~.b .. t~."Q-~_,,@g_m~J.t.~~om 

U.S Department of Transportation Docket Management System 

1200 New Jersey Ave., SE Washington DC 20590 

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

11 of the Federal Aviation Regulations from: 14 CFA 21 subpart H; 14 CFA 

45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 

91.103; 14 CFR 91.109; 14 CFA 91.119(c); 14 CFR 91.121; 14 CFR 91.151 (a); 

14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 

91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

The exemption is in the public interest. Pursuant to the authority contained in 49 

U.S.C. 106(1), 40113, and 44701. 

Dear Sir or Madam: 

Pursuant to S~tioQ 333 of the FAA Modernization and Reform Act of 2012 (the 

.•.!R~form Act 11) an~ 14 CFA Part 11 of Unmanned Aircraft Systems (UAS), 

Mlcha~l A,alne~ h~reby applies for~ e~tlf11Ption from the listed F,~cleral Aviation 

Regulations (

11.Ej\Rsi1

) to allow commerciai operation of Designated IJAS, 

provideq s.1.1c.~ operations are conducted .Within and under the conditions outlined 

herein_~r ~~. !.r'~Y be established ~y 'h~ FAA as required by Section 333. 
12 2016 

: :;~W~~i";'t~~ 

Home Inspections"' .. ~~95448007 

.. ~ "~:~·-~\~ 

Thank you in advance for your consideration. 

page 3 

_ll!: de?;~~~pt;'··"' •.. :~,~~e~n'fGP.mrnerciat~pe~l\t~_Q,,Of.E~:n UAS, a~ describ~ h~rein, ~hich_ are equipp~d with 

virh~;-i:,t.rife~;-. , ~-.. :f.~ ~~t:~t~amtra(s) ~~nd sensgrs, would provtde profes~ional servrces 1n the folloWing · · · ... · ·areas: · · .. · · · · · 

1. Real Estate 

2. Education and Special Events 

3. Vldeography I Photography 

4. Search and Rescue 

5. Roof Inspections 

6. Construction Site Work 

7. Residential/ Commercial Building Inspections 

8. Weddings 

9. Public and Private Events 

As described fully below, the requested exemption would permit the operation of. 

designated UAS as set forth in this document under controlled conditions in the 

NAS that would be a) limited b) controlled c) predetermined and d) safe. Approval 

of this exemption would Increase public awareness of UAS operations and 

enhance safety to aid in fulfilling the Secretary of Transportation's (the FAA 

Administrator's) responsibilities to ...... establish requirements for the safe 

operation of such aircraft systems in the national airspace system." 

The name and address of the applicant is 

Michael Raines 

Central Home Inspections 

9780 Green Rd 

Farwell, Ml 48822 

1nspe~tth9.?hou~J*_mail.c.~m 

from which the exemption Is requested: 14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

_ · · 14 CFA 61.113 (a) & (b)' 

: 14 CFR 91.7 (a) 

14 CFR 91.9 (b) {2) 

.c "-"'"·-<.tlr' ,~- ·:0?&-.tt~~H:,+;' i 14 CFR 91 ; 1 03 . ·. 

··14 CFR 91.1 09 . '•"' ,.,,, ... ,,,,,i•f!i··· ... '' •·· .... ···(~ ·-~i,l-;,. ~ ..., 

--·--,..~~""~"i'""', 4 CFR 91. 119 (c) ~'~'~":Ah"'"·"· 

-~~~~4: g~~ :~. ~ ~~ (~j~-,;~~ ·· ---~~::~i ~ · ·~~~t14 cF.R e1 :2o:f (a>'~~~~~-R~E .. ,~~\, 
12:27PM 

< '!:~j~~~;;;t~:~·~~'~.j~ 

Inspections 9895448007 ·· "." 

14 CFA 91.405 (a) 

14 CFR 91.407 (a) 

14 QFR 91.409 (a) 

14 CFR91.417 (a) 

< ' .~~ 

page 4 

As in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

· FAA-2014-0352), 11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 

11112 to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213 to Aeryon 

labs, Inc. (see Docket No. FAA-2014-Q642), and 12645 to Allied Drones (see 

Docket No. FAA-2014-0804), There is enhanced safety achieved using an 

unmanned aircraft (UA) with the specifications described by the petitioner and 

carrying no passengers or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to flammable fuel~ gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the 

pubUc interest. 

Michael Raines Will operate one or more of the Following model UAS 

DJI Phantom 3 Pro 

Safety requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed . 

operations and the public benefit, reduction in environmental impacts, including 

but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public Interest. Accordingly, the applican1 graciously requests 

that the FAA grant the requested.exemption. 

AlRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

"' . Tt)e operation limitations proposed for an equivalent or higher level of safety 

;because operations wUI further enhance the safety of the persons and/or property 

,using conventional aircraft. These limitations and conditions to which the 

. , ... fipp,icant ag~~~s to adher.e to when conducting commercial operations under the 

·-- "''"'i!~~~·:;:~:FAA,.issLied exemption as set forth in the Flight Operations Manual (FOM) 

... ; )f1Pilfctf;!: , ,•- .<;· j ' '•'"*'~'-"~·;~"·'•'1·''' 
Home 

~· . . . .· '' 

'·:·.~~~1 ~erTb~~ Y~S,;dep~nding oh the mOdel In operation. will have a maximum 

·. operat!ng speed of no rriore than 50mph. 

3. Flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS 

model in operation, but will not exceed 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time whichever occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground 

Level {AGL) and not more than 200 feet above an elevated plaHorm from which 

fflm.ing is planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one 

Visual Observer (VO), and may include a third, but separate, Camera Operator (CO)~ 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have 

logged a minimum of 20 hours on the designated UAS. 

a. A safety briefing will be performed prior to each day1s flights consisting of all 

the days• Production activities. 

9. All flight aCtivities witl be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions 

.(VMC) only. ,,:;·' 

11. The flights will occur in Class G airspace no closer than a mile radius of the 

,·:r·>:Q!Q_Qraphic ce~t~,~/Airport J1efere11c~ .. ~()int (ARP) of a tower controlled or .. ~.;~~uncontroiiE§(fairJ)Ort.;<~ ,.€ : ··~ '· , · 

.;)~~ '•0\~ ·~· •. ·'. • ; 

12. Flights· Wiu'n6fiie"closer than as mile radius of the geographic center/Airport. n • ' •• ~~-::·:ltt~·~l~}~~;~ .. l ·~ . . . • ;·~;·;:~,){r(-' 

.:. ·, ·': .• ,~~~"1"t~!::~-:,~.'~"f,;;i,;•3•. . _,. ~ 't '.~:~::~;~~f&~~'? ...•... ;;". ; ... 
. '

2016 12:27PM 

;. · ;y~f;~::iif'~~~-~:·}" ·, page '·s· '··· 

. 13.~The,operatorwill do a pre check of aircraft prior to each flight. And log each fli(Jht. .. .. . . 

~- .1:4. T~t(Qper~tc>cwill obtain verballwrtnen consent of all persons involved with the 

"''"", .... , ••. ,.,.r:.1:.,." ... ~~/:irPianned operation and ensure that only consenting persons wllf be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet based 

upon an equivalent level of safety determination, as U.S. Department of 

Transportation required under the FOM. With the advanced permission of the 

FSDO, operations at closer range may be approved. 

15. The PIC and VO will have been trained in operation of UAS and receive up to 

date Information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio at atl 

times. 

17. The PIC will abide by all rules 

18. If the UAS loses communications with the remote controller or loses GPS 

signal, the UAS will have the capability to return to a predetermined 

location wlthJn a designated location and land autonomously. 

19. The UAS will have the capability to abort a flight in case of emergencies with 

an automated .. Return Home and Land11 function. 

20. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies such as low battery. 

21. Any incident, accident, or flight operation that transgresses the lateral or 

, verti9~""~Q.~ndaries of the operational area as defined by the applicable COA 

: must bereported to the FAA's UAS Integration Office (AFS-80) within 24 hours . 

. '.Accidents must be reported to the National Transportation Safety Board (NTSB) 

,per instructions contained on the NJSB Web site: www.ntsb.gov. -~;:t;:~~r~~~,f)··~. c , '\~~~-~, <.". '/'' . 

,.,,·.u·",,-•. ~··.·.·" < ,.rlt-:~~1fiMJ%R·;,f~~~ Part·2t,_.~~~p~Q,Jj}:~~Jr~orthiness Certlfl~aJ~~.14 C.F.R. §91.203 (a) 

.. , i:i·:~ii.~(~.~.~~~QP~~:t-i, ent1tl~~d AJr~~~~.lJ.!!~Certlflcates, ~stabll~hes the procedural 

. :: ":~·· ~tirequlrements for the issuaficEf'ot airworthiness eertificates as required by FAR 
Jan 12 2016 12:28PM Centrat Home ~~~Ncins 9895448007 page 7 

"~;§9t.203 (a) (1). Given,the size and limited operating area associated with the 

r:r·aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H 

.,- ."".-.,_,.,, •. <J, ,j.;lif"zfiyffi~@ts t~~ ~~qulr.~ments ot an equivaltnt level of safety under Part 11 and 

~u;H~,<,zteitn ;''i~ec1iOIJ ~,S~,of the"Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) 

.~ ~~nd Seet1Qn33s of the ·Reform Act both authorize the FAA to exempt aircraft from 

. · -~ 'r~ ·•~""·n "'.the req'uirement ,for an ain.vorthlness certificate, upon consideration of the size. 

weight, speed, operational capability. and proximity to airports and populated 

areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate 'In the 

res1ricted environment and under the conditions proposed 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 

UAS to be operated hereunder is less than 551bs. fully loaded. carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuelsJ and 

operates exclusively within a secured and designated area. Unlike other civil 

aircraft, operations under_ this exemption will be tightly controlled and monitored 

by. both the operator and under the requirements and in compliance with local 

public safety requirements. These safety enhancements provide a greater degree 

of safety to the pubtic and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.A. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no 

credible threat 1o national security posed by the UAS, due to its size, speed of 

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

fuels, and tnability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The reg~lation requires: ~hen 

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 opera1or must also display on that aircraft 

near each entrance to the cabin, cockpit, or pilot station, in tatters not less than 2 

inches nor more than 6 inches high, the words "limitedr ••restricted! 111ight sport/' 

"experimental/' or "provisional! as applicable. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: When 

... , 'Y'· marks include only ~he 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 

:~"'7··· 11f:i~r,.,~,Oh.~oJranp~ -to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the 'NOrds 111imitedf 11 restricted1 111igh1 

sp()rtf11S}Cp~rlrnentalf or "provisional/as applicable. Even though the UAS will 

haveJl~~:(~rthiness certificate, an ~xemption may be needed as the UAS will 

have ~ ie.nJr~nce to the cabin, -cockpit or pilot station on which the word 

"Experirm~nt,aP•, can be, placed. Givenjhe size of the UAS, two inch lettering. will 

be impossible. The word .. Experimental .. will be placed on the fuselage in 
,

, 

Jan 12 2016 '''12:29PM Centrat Home Inspections 9895448007 page 8 

·;~;i:,~®.mpliance with §45.29·(f). US Department of Transportation February 20,2015 

·.r;r"fh$ equivalent level of safety will be provided by having the UAS marked on its 

;;)i·ii\Jt. >:; ·~>~~Ju$~1~ge as r~qui,r~d by ;§45.29 (f) \Vhere the pilot, observer and others working 

· ~ ... ~A:~i:.Pu~·~~;:W~thJhe UA~·wiU lee the identification of the UAS as "Experimental." 14 C.F.A. § 

.'fif.113 (a) ~lld (b The pro"posed UAS operations may achieve an equivalent level 

·l!•tr· ·~1f~'~.) :Of safety as ,achieved by current Regulations because the applicant's UAS do not 

carry any pilots or passengers nor property. The risks attendant to the It is 

believed that the operation and limitations set forth in the FOM will equate to the 

sate operation of the UAS. 

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 for maintenance and use of safety checktists prior to 

each flight, an equivalent level of safety will be provided. 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 Manuat 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 manuat materiat markings, and placards. or any combination thereof. 

The UAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, no1 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 flight manual at the 

ground control point where the pilot flying the UAS will have immediate access to 

it. 

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in 

command to take cenain actions before flight to insure the safety of flight. As 

F:~A _approved rotorcraft flight manuals witl not be provided for the aircraft an 

exemption will be needed. The PIC will take.all actions as stated in the FOM in 

Section 4 under Normal Procedures including but not limited to reviewing 

weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. 

14 C. F. A. §91.109: Flight Instruction. Section 91.103 provides that no person 

maY.PP,~r~t~;~~ ,c;ivil aircraft (except a manned free baltoon) that is being used for 

flight instruction unless that aircraft has fully 1unctioning dual controls. UAS and 

remotely, pl~ot~d aircraft, by their design do not have fully functional dual controls. 

Flight qo_ntu>l. is accomplished through the use of a control box that 

communic$t~s :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. The equi~alent tevet of 
Jan 12 26: ~r! 

')>~':ft1;~~& .'~"""~~· 

Centrat Home Inj~~g~dns 9895448007 ,; -;;;~j>, ,,,· 

page 9 

.. ,.,." •• ~,,;~; tJ('>·· ,:-~;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 . 

.. :1.4 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 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. As this exemption Is for a UAS that is a helicopter and the exemption 

requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which filming is planned, an exemption may be 

needed to aflow such operations. As set forth herein, the UAS will never operate 

at higher than 400 AGL with the exception that in circumstances where the UAS 

is used to survey or photograph a structure whose height exceeds 400 feet AGL, 

the UAS will not be operated more than 200 feet above the highest point on the 

structure. It will however be operated in a restricted area with security perimeter, 

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, and speed of the UAS 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 of the advance notice to the property owner and participants in the 

filming activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighting far 

more than the maxi mum SSibs. Proposed herein and the lack of flammable fuel, 

any risk associated with these operations is tar less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, 

the low altitude operations of the UAS will ensure separation between these UAS 

operations and the operations of conventional aircraft that must comply with 

Section 91.119. 

14 C. F. R. §91.121 Altimeter Settings. This regulation requires each person 

. pperating an 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 UAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an U.S. exemption may be 

needed. An equival~nt level of safety will be achieved by the operator, pursuant 

to the safety check list and live flight data monitoring, confirming the attitude of 

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

14 C.FJ=t~.§ 9~1'·:~-151 (a): Fuel Requirements for Flight in VFR Conditions Section 

91.151 (atprohibits an individual from beginning "a flight in an airplane under 

VFR.®,nijllJQ.r:l~unless (considering wind and forecast weather conditions) there 

is enougtiihl~ttp fly to the first point ·ol intended landing, and. assuming normal 

cruis~~g~p.~~(t~:{1) Du_r.ing the day. tcffly· after that for at least 30 minutes; or (2) 

At night, to ·ny after that for at least 45 minutes. 11 The applicant believes that an 
Jan 12 page 10 

<·'"· .• ~>exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions . 

. :'qp~r.@,~ng the l)AS ina tightly controlled area where only people and property 

_.., ... ,u"''·'·'··.· "'t;,:;i~~~.f1~~;d .. ~~·OWIJ~f:~:'orotticj~ll~Pr~ntatives who have signed waivers will be allowed does 

, t.:<; ·~~: ~,~~} ~~"t;OQ(~figenderJt:te typ~, of risks .tha1 Section 91.151 (a) was intended to alleviate 

· · ·. ·.given, the siz• and speed of the small UAS. The applicant believes that .an 

· ·h··,,,,,H,equivalent level of safety can be achieved by limiting flights to 30 minutes or 25o/o 

of battery power· whichever happens first. This restriction would be more than 

adequate to return the UAS to its planned landing zone from anywhere in its 

limited operating area. 

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 UAS fully loaded weighs well under the proposed 551 b limit and is 

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 UAS. An 

equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the UAS will have immediate access to 

them. to the extent they are applicable to the UAS. 

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

Inspections. These regulations require that an aircraft operator or owner "shan 

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.sh~U inspect pr 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 applicant. Maintenance will be accomplished 

by the operator pursuant to the flight manual and operating handbook. An 

equivalent level of safety wiU be achieved because the UAS is very limited in size 

··and will carry a small payload and operate only in restricted areas for a limited 

period of time. If mechanical issues arise the UAS can land immediately and will 

~,,>~' .. ·;'"""· :,,,~;~.~ •.• K« ·"'')';·'";~lbe op~~~Jjng f!9.r!l rtQ.nigher than 400 feet AGL. The operator will ensure 1hat the · · · · ·~ UAS is in working order prior to initiating flight, perform required maintenance, 

.and keep a I()Q,Qtany maintenance performed. Moreover, the operator Is the 

. pen:;on mq§t!.@mili~r with the aircraft ~ndbest suited to maintain the aircraft in an 

airworthy CQflQitJ9n ~o provide the equivalent level of safety. An equivalent level of 

,safety will ~,La~ieved because maintenance and Inspections will be performed 

.,_,....,., in accordancEf'With the UAS Manufacturer's User Manual. As provided in the 
Jan 12 2016 ,·,~~i~)?~~1):·,:'_:, 

Centrat Home Inspec~qns:~ '9895448007 1.' :~} :. -~,. -

page 11 

:FO..,t and a fink on last P.age, the operator Will ensure that the UAS is in working 

,- o_rder prior to initiating flight and perform required maintenance needed. 

Addttlonallnformatlon. 

The applicant Michael Raines believes this exemption request and associated 

safety considerations adequately satisfy criteria provtded in Section 333 of the 

Reform Act of 2012, providing sufficient justification for the granting of 

commercial operations of the applicant's UAS. I also feel its in the public's 

interest on granting the exemption, as we can educate them at the same time. 

And all the positive sides of the new technology and the level of safety. 

The applicant Michael Raines requests your. respective approval of this Section 

333 exemption petition request. 

Thank you for your attention in this matter. Please notify Michael Raines of your 

actions. and or approvals. Thank you, for your interest in this request. 

Michael Raines